Data protection
This privacy policy explains the nature, scope and purpose of the processing of personal data (hereinafter referred to simply as ‘data’) within our online service and the associated websites, functions and content, as well as external online presences, such as our social media profiles. (hereinafter collectively referred to as the ‘online service’). With regard to the terms used, such as ‘personal data’ or its ‘processing’, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
Data controller
Delius Klasing
A brand of
Klambt Programmzeitschriften GmbH
Schillerstraße 81, 33609 Bielefeld
Management: R. Dienst, T. Ramms, N. Schumacher, R. Meyke
Business address: Rotweg 8, 76532 Baden-Baden
Registered office: Bielefeld
Registered at the Bielefeld Local Court under HRB 7332
VAT registration number: DE 123999126
Telephone number: 0521/559-0
Email address: info(at)delius-klasing.de
Data Protection Officer
Klambt Programmzeitschriften GmbH
Schillerstraße 81, 33609 Bielefeld
Email address: datenschutz(at)delius-klasing.de
Types of data processed:
Master data (e.g. names, addresses). Contact details (e.g. email, telephone numbers). Content data (e.g. product reviews). Contract data (e.g. subject matter of the contract, term, customer category). Payment data (e.g. bank details, payment history). Usage data (e.g. websites visited, interest in content, access times). Meta/communication data (e.g. device information, IP addresses).
Processing of special categories of data (Article 9(1) of the GDPR):
No special categories of data are processed. As a general rule, no special categories of data are processed, unless these are provided by users during processing, e.g. by entering them into online forms.
Categories of data subjects:
Visitors and users of the online service. Customers / prospective customers / suppliers. Hereinafter, we shall collectively refer to the data subjects as “users”.
Purpose of processing:
To provide and further develop the online service, its content and functions. To fulfil contractual obligations, provide services and manage customer relations. To respond to enquiries and communicate with users. Marketing, advertising and market research. Security measures.
As at 26 March 2024
1. Relevant legal bases
In accordance with Article 13 of the GDPR, we hereby inform you of the legal bases for our data processing activities. Where the legal basis is not specified in the privacy policy, the following applies: The legal basis for obtaining consent is Article 6(1)(a) and Article 7 of the GDPR; the legal basis for processing to fulfil our services, carry out contractual measures and respond to enquiries is Article 6(1)(b) of the GDPR; the legal basis for processing to fulfil our legal obligations is Article 6(1)(c) of the GDPR, and the legal basis for processing to safeguard our legitimate interests is Article 6(1)(f) of the GDPR. In the event that the vital interests of the data subject or of another natural person necessitate the processing of personal data, Article 6(1)(d) of the GDPR serves as the legal basis.
2. Changes and updates to the privacy policy
We ask that you keep yourself regularly informed about the content of our privacy policy. We will update the privacy policy as soon as changes to our data processing activities make this necessary. We will inform you as soon as the changes require any action on your part (e.g. consent) or any other individual notification.
3. Safety measures
3.1. In accordance with Article 32 of the GDPR, and taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, to ensure a level of protection appropriate to the risk; These measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, input of, disclosure of, and safeguarding the availability of the data, and its segregation. Furthermore, we have established procedures to ensure that data subjects’ rights are upheld, that data is erased, and that we respond to data breaches. Furthermore, we take the protection of personal data into account right from the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default (Article 25 of the GDPR).
3.2. The security measures include, in particular, the encrypted transmission of data between your browser and our server.
3.3. We strongly urge you to take every possible precaution yourself to protect your data whilst using the internet. Make it a habit to change your password frequently. We recommend using a combination of letters and numbers for your password and ensuring that you use a secure, SSL-enabled browser when browsing the internet. Where possible, log out completely after finishing using a computer that you do not use alone, and do not disclose your password to third parties.
3.4. Your personal data is stored using all available technical and organisational measures to ensure that it is not accessible to third parties. As we cannot guarantee complete data security when communicating by email, we recommend that you send confidential information by post.
4. Cooperation with data processors and third parties
4.1. Where, in the course of our data processing, we disclose data to other individuals and organisations (data processors or third parties), transfer it to them or otherwise grant them access to the data, this is done only on the basis of a legal authorisation (e.g. where the transfer of data to third parties, such as payment service providers, is necessary for the performance of a contract in accordance with Article 6(1)(b) of the GDPR), you have given your consent, a legal obligation requires it, or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
4.2. Where we engage third parties to process data on the basis of a so-called ‘data processing agreement’, this is done in accordance with Article 28 of the GDPR.
4.3. We only disclose personal data to third parties where this is necessary for the purposes of contract fulfilment, for example to the bank responsible for processing payments or to companies commissioned by us for our own purposes. These companies undertake not to pass on this data and to comply with this privacy policy. Your data will not be passed on for any other purposes, such as for advertising.
4.4. Your personal data will not be disclosed to third parties unless you have given your express consent or we are obliged to disclose it, for example following a court order or an order from a public authority.
5. Transfers to third countries
Where we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)), or where this occurs in connection with the use of third-party services or the disclosure, or transfer of data to third parties, this will only take place if it is necessary to fulfil our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation, or on the basis of our legitimate interests. Subject to statutory or contractual authorisations, we shall only process data in a third country, or have it processed there, where the specific conditions set out in Articles 44 et seq. of the GDPR are met. This means that processing takes place, for example, on the basis of specific safeguards, such as an officially recognised determination that a level of data protection equivalent to that of the EU is in place, or compliance with officially recognised specific contractual obligations (so-called ‘standard contractual clauses’).
6. Rights of data subjects
6.1. You have the right to request confirmation as to whether the data in question is being processed, and to obtain access to that data, as well as further information and a copy of the data, in accordance with Article 15 of the GDPR.
6.2. In accordance with Article 16 of the GDPR, you have the right to request that data relating to you be completed or that any inaccurate data relating to you be rectified.
6.3. In accordance with Article 17 of the GDPR, you have the right to request that the data in question be erased without delay or, alternatively, in accordance with Article 18 of the GDPR, to request a restriction on the processing of the data.
6.4. You have the right to request, in accordance with Article 20 of the GDPR, to receive the personal data concerning you that you have provided to us and to request that it be transferred to other data controllers.
6.5. Furthermore, in accordance with Article 77 of the GDPR, you have the right to lodge a complaint with the relevant supervisory authority.
7. Right of withdrawal
You have the right to withdraw any consent you have given, in accordance with Article 7(3) of the GDPR, with effect for the future.
8. Right to object
You may object at any time to the future processing of your personal data in accordance with Article 21 of the GDPR. In particular, you may object to the processing of your personal data for the purposes of direct marketing.
9. Platforms and digital presences with registration and ordering functions
To register and place orders for products on all platforms and digital sites operated by Klambt Programmzeitschriften GmbH, you must be at least 16 years old.
10. Cookies and the right to object to direct marketing
We use temporary and permanent cookies, i.e. small files that are stored on users’ devices (for an explanation of the term and how they work, see the final section of this privacy policy). Some of these cookies serve security purposes or are necessary for the operation of our online service (e.g. to display the website) or to store the user’s choice when confirming the cookie banner. In addition, we or our technology partners use cookies for audience measurement and marketing purposes, as explained to users throughout this privacy policy.
A general objection to the use of cookies for online marketing purposes can be raised for a wide range of services – particularly in the case of tracking – via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, you can prevent cookies from being stored by disabling them in your browser settings. Please note that, in this case, you may not be able to use all the features of this website.
11. Deletion of data
11.1. The data we process will be erased or the processing of such data restricted in accordance with Articles 17 and 18 of the GDPR. Unless expressly stated otherwise in this privacy policy, the data stored by us will be erased as soon as it is no longer required for the purpose for which it was collected and there are no statutory retention obligations preventing its erasure. Where data is not erased because it is required for other, legally permissible purposes, its processing will be restricted. This means that the data will be blocked and not processed for any other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
11.2. In accordance with statutory requirements, records must be retained for a period of 6 years in particular, pursuant to Section 257(1) of the German Commercial Code (HGB) (commercial ledgers, inventories, opening balance sheets, annual accounts, commercial correspondence, accounting vouchers, etc.) and for 10 years in accordance with Section 147(1) of the German Fiscal Code (AO) (books, records, management reports, accounting vouchers, commercial and business correspondence, documents relevant to taxation, etc.).
12. Online shop
12.1. We process master data (e.g. names, addresses and contact details of users) and contractual data (e.g. services used, names of contact persons, payment details) for the purpose of fulfilling our contractual obligations and providing services in accordance with Article 6(1)(b) of the GDPR. The fields marked as mandatory in online forms are required for the conclusion of the contract.
12.2. Users may, if they wish, create a user account, which allows them, in particular, to view their orders. During the registration process, users are informed of the required mandatory details. User accounts are not public and cannot be indexed by search engines. Once users have closed their user account, their data relating to that account will be deleted, subject to any retention required for commercial or tax law purposes in accordance with Article 6(1)(c) of the GDPR. It is the users’ responsibility to back up their data prior to the termination of the contract. We are entitled to irrevocably delete all user data stored during the term of the contract.
12.3. As part of the registration process, subsequent logins and the use of our online services, we store the IP address and the time of the respective user action. This data is stored on the basis of our legitimate interests, as well as the users’ interest in protection against misuse and other unauthorised use. As a general rule, this data is not disclosed to third parties, unless it is necessary for the pursuit of our claims or there is a legal obligation to do so in accordance with Article 6(1)(c) of the GDPR.
12.4. We process usage data (e.g. the web pages visited on our website, interest in our products) and content data (e.g. entries in the contact form or user profile) for advertising purposes within a user profile, in order to display the user, for example, product recommendations based on the services they have used to date.
12.5. Data will be deleted once statutory warranty obligations and similar obligations have expired; the need to retain the data is reviewed every three years; in the case of statutory archiving obligations, the data shall be deleted upon expiry of such obligations (end of the retention periods under commercial law (6 years) and tax law (10 years)); information in the customer account shall remain until the account is deleted.
13. Making contact
13.1. When you contact us (via the contact form or by email), your personal data will be processed for the purpose of handling your enquiry and dealing with it in accordance with Article 6(1)(b) of the GDPR.
13.2 Users’ details may be stored in our Customer Relationship Management system (‘CRM system’) or a similar enquiry management system.
13.3. We delete enquiries once they are no longer required. We review the necessity of retaining them every two years; we store enquiries from customers who have a customer account permanently and refer to the information in the customer account regarding their deletion. Where statutory archiving obligations apply, deletion takes place once these have expired (at the end of the retention periods under commercial law (6 years) and tax law (10 years)).
13.4. On various online platforms operated by Klambt Programmzeitschriften GmbH, you have the option of contacting advertisers of classified adverts. This is done via a contact form integrated into the relevant platform. If you send a contact enquiry, the relevant advertiser will receive the information you have provided directly by email. The information you provide is not stored on Klambt Programmzeitschriften GmbH’s servers.
14. Comments and posts
14.1. When users leave comments or other contributions, their IP addresses are stored on the basis of our legitimate interests within the meaning of Article 6(1)(f) of the GDPR.
14.2. This is for our own protection in the event that someone posts unlawful content in comments or posts (insults, prohibited political propaganda, etc.). In such cases, we ourselves may be held liable for the comment or post and are therefore interested in the author’s identity.
15. Collection of access data and log files
15.1. On the basis of our legitimate interests within the meaning of Article 6(1)(f) of the GDPR, we collect data on every access to the server on which this service is hosted (so-called server log files). The access data includes the name of the webpage accessed, the file, the date and time of access, the amount of data transferred, confirmation of successful access, the browser type and version, the user’s operating system, the referrer URL (the previously visited page), IP address and the requesting provider.
15.2. Log file information is stored and deleted at regular intervals for security reasons (e.g. to investigate cases of misuse or fraud). Data which must be retained for evidential purposes is exempt from deletion until the relevant incident has been fully resolved.
16. Online presence on social media
16.1. On the basis of our legitimate interests within the meaning of Article 6(1)(f) of the GDPR, we maintain an online presence on social networks and platforms in order to communicate with customers, prospective customers and users active on those platforms and to provide them with information about our services. When accessing the respective networks and platforms, the terms and conditions and data processing policies of their respective operators apply.
16.2. Unless otherwise stated in our Privacy Policy, we process users’ data where they communicate with us via social networks and platforms, for example by posting on our online presence or sending us messages.
17. Cookies & Audience Measurement
17.1. Cookies are pieces of information that are transmitted by our web server or third-party web servers to users’ web browsers, where they are stored for later retrieval. Cookies may be small files or other forms of data storage.
17.2. We use ‘session cookies’, which are stored only for the duration of your current visit to our website (e.g. to save your login status or the shopping basket function, and thus to enable you to use our online service at all). A session cookie contains a randomly generated unique identification number, known as a session ID. A cookie also contains information about its origin and its storage period. These cookies cannot store any other data. Session cookies are deleted once you have finished using our online service and, for example, log out or close your browser.
17.3. Users are informed about the use of cookies in the context of pseudonymous audience measurement in this privacy policy.
17.4. If users do not wish to have cookies stored on their computer, they are asked to disable the relevant option in their browser’s settings. Stored cookies can be deleted via the browser’s settings. Disabling cookies may result in functional limitations to this online service.
17.5. You can opt out of the use of cookies for audience measurement and advertising purposes via the Network Advertising Initiative’s opt-out page (http://optout.networkadvertising.org/) and, in addition, via the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).
18. Cookies
On the websites listed below, we use ConsentManager to give you the option to decide for yourself, in detail, in which cases you wish to consent to tracking via cookies and other technologies – for the purpose of displaying content relevant to you and advertising tailored to your interests. You can access the settings for each website via a button on the left-hand side at the bottom of the page. Websites that offer you the option to adjust your settings via the consentmanager:
We have implemented the consent management tool ‘consentmanager’ (www.consentmanager.net) consentmanager AB (Håltgelvågen 1b, 72348 Västerås, Sweden, info@consentmanager.net) have been integrated into our websites to request consent for data processing or the use of cookies or similar functions. Using ‘consentmanager’, you have the option to give or withhold your consent for certain features of our website, e.g. for the purposes of integrating external elements, embedding streaming content, statistical analysis, audience measurement and personalised advertising. Using “consentmanager”, you can give or withhold your consent for all functions, or give your consent for individual purposes or individual functions. You can also change the settings you have made at a later date. The purpose of integrating “consentmanager” is to allow users of our website to decide on the aforementioned matters and to offer them the option to change settings they have already made whilst continuing to use our website. When using “consentmanager”, personal data and information about the devices used (IP address, language, browser, etc.) are processed and sent to consentmanager AB. Information about the settings you have chosen is also stored on your device.
The legal basis for the processing is Article 6(1), first sentence, point (c) of the GDPR in conjunction with Article 7(1) of the GDPR, insofar as the processing serves to fulfil the statutory obligations to provide evidence of consent having been given. In all other respects, Article 6(1), first sentence, point (f) of the GDPR is the relevant legal basis. Our legitimate interests in the processing lie in the storage of user settings and preferences regarding the use of cookies and the analysis of consent rates. No later than twenty-four months after the user settings have been configured, consent will be requested again. The user settings you have configured will then be stored again for this period, unless you delete the information about your user settings yourself beforehand from the designated storage capacities on your device.
You may object to the processing where such processing is based on Article 6(1), first sentence, point (f) of the GDPR. Your right to object applies where there are grounds relating to your particular situation. To lodge an objection, please contact us by email at info@consentmanager.net.
19. Google Analytics
19.1. We use Google Analytics, a web analytics service provided by Google LLC (“Google”), on the basis of our legitimate interests (i.e. our interest in the analysis, optimisation and commercial operation of our online offering within the meaning of Article 6(1)(f) of the GDPR). Google uses cookies. The information generated by the cookie regarding users’ use of the online service is usually transmitted to a Google server in the USA and stored there.
19.2. Google will use this information on our behalf to analyse how users utilise our online service, to compile reports on activity within this online service, and to provide us with other services relating to the use of this online service and internet usage. In doing so, pseudonymous user profiles may be created from the processed data.
19.3. We use Google Analytics to ensure that adverts placed within Google’s advertising services and those of its partners are shown only to users who have demonstrated an interest in our online offering or who exhibit certain characteristics (e.g. interests in specific topics or products, determined on the basis of the webpages visited), which we transmit to Google (so-called ‘remarketing’ or ‘Google Analytics audiences’). We also use Remarketing Audiences to ensure that our adverts match users’ potential interests and do not come across as intrusive.
19.4. We only use Google Analytics with IP anonymisation enabled. This means that users’ IP addresses are truncated by Google within Member States of the European Union or in other States party to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and truncated there.
19.5. The IP address transmitted by the user’s browser will not be combined with any other data held by Google. Users can prevent the storage of cookies by adjusting the settings in their browser software; users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online service, as well as prevent Google from processing this data, by downloading and installing the browser plug-in available via the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
19.6. For further information on Google’s use of data, as well as options for adjusting settings and opting out, please visit Google’s websites: https://www.google.com/intl/de/policies/privacy/partners (‘How Google uses data when you use our partners’ websites or apps’), https://policies.google.com/technologies/ads (‘Data use for advertising purposes’), https://adssettings.google.com/authenticated (“Manage the information Google uses to show you adverts”).
19.7. Furthermore, personal data will be anonymised or deleted after a period of 50 months
19.8 Piwik Pro
We use Piwik Pro, a web analytics service, on the basis of our legitimate interests (i.e. our interest in the analysis, optimisation and commercial operation of our online service within the meaning of Article 6(1)(f) of the GDPR). Piwik Pro uses cookies. The information generated by the cookie regarding users’ use of the online service is generally transmitted to a Piwik Pro server in Europe and stored there.
20. Google Re/Marketing Services
20.1. We use, on the basis of our legitimate interests (i.e. our interest in the analysis, optimising and ensuring the efficient operation of our online service within the meaning of Article 6(1)(f) of the GDPR) the marketing and remarketing services (hereinafter ‘Google Marketing Services’) provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (‘Google’).
20.2. Google Marketing Services enable us to display adverts on and for our website in a more targeted manner, so as to present users only with adverts that are likely to match their interests. If, for example, a user is shown adverts for products they have shown an interest in on other websites, this is referred to as ‘remarketing’. For these purposes, when our website or other websites on which Google Marketing Services are active are accessed, a Google code is executed directly by Google, and so-called (re)marketing tags (invisible graphics or code, also known as ‘web beacons’) are embedded in the website. With the help of these, an individual cookie – i.e. a small file – is stored on the user’s device (comparable technologies may also be used instead of cookies). The cookies may be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which web pages the user has visited, what content they are interested in and which offers they have clicked on, as well as technical information about the browser and operating system, referring web pages, time of visit and further details regarding the use of the online service. The user’s IP address is also recorded; however, we would like to point out that, within the framework of Google Analytics, the IP address is truncated within Member States of the European Union or in other contracting states to the Agreement on the European Economic Area, and is only transferred in full to a Google server in the USA – where it is then truncated – in exceptional cases. The IP address is not merged with the user’s data held within other Google services. Google may also combine the aforementioned information with data from other sources. When the user subsequently visits other websites, they may be shown adverts tailored to their interests.
20.3. Users’ data is processed pseudonymously within the framework of Google’s marketing services. This means that Google does not, for example, store or process users’ names or email addresses, but instead processes the relevant data on a cookie-by-cookie basis within pseudonymous user profiles. In other words, from Google’s perspective, the adverts are not managed and displayed for a specifically identified individual, but for the cookie holder, regardless of who that cookie holder is. This does not apply if a user has expressly authorised Google to process the data without this pseudonymisation. The information collected by Google Marketing Services about users is transmitted to Google and stored on Google’s servers in the USA.
20.4. The Google marketing services we use include, amongst others, the online advertising programme ‘Google AdWords’. In the case of Google AdWords, each AdWords customer is assigned a different ‘conversion cookie’. Cookies cannot therefore be tracked across the websites of AdWords customers. The information collected via the cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers are informed of the total number of users who clicked on their advert and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that could be used to personally identify users.
20.5. We may incorporate third-party advertisements using Google’s ‘AdSense’ marketing service. AdSense uses cookies to enable Google and its partner websites to display adverts based on users’ visits to this website or other websites on the internet.
20.6. We may also use ‘Google Tag Manager’ to integrate and manage Google’s analytics and marketing services on our website.
20.7. For further information on Google’s use of data for marketing purposes, please visit the overview page: https://policies.google.com/technologies/ads. Google’s privacy policy is available at https://policies.google.com/privacy.
20.8. If you wish to object to interest-based advertising via Google Marketing Services, you can use the settings and opt-out options provided by Google: https://adssettings.google.com/authenticated.
21. Use of the LiveRamp ID
Should you provide your email address whilst using our websites (for example, to subscribe to our newsletter), we will transmit your associated personal data (email address, IP address and details of your device) in pseudonymised (‘hashed’) form to our service provider, LiveRamp, Inc. If you subscribe to one of our newsletters and access one of our websites via a link within the newsletter, we will also transmit your email address and the associated information about your device in pseudonymised form to the service provider LiveRamp once you have accessed the website. Based on this information, LiveRamp generates an online ID which enables your recognition across the devices you use. However, no directly identifiable personal data is processed in this context. In particular, the data is not processed by the service provider LiveRamp for the purpose of identifying you.
The ID generated by LiveRamp is stored within a so-called Cookies stored on your device, enabling personalised advertising across different online platforms. The ID is also shared with our advertising partners and other third-party providers in order to provide you with interest-based content or targeted advertising (e.g. on the web, via email, on connected devices, in apps, etc.). Our partners may, in turn, also use the ID to link demographic or interest-based information that you have provided whilst interacting with the respective partner.
The data processing operations set out above, in particular the creation of the ID, will only take place if you have given your consent via our Consent Management Platform (‘CMP’). Please note that in the case of Processing It cannot be ruled out that your data may be transferred to the USA via the service provider LiveRamp. Further information on data protection at LiveRamp can be found in LiveRamp’s privacy policy at: https://liveramp.de/privacy/datenschutzerklarung-fur-die-liveramp-dienste/
(a) Purpose of data processing and legal basis, as well as, where applicable, legitimate interests and retention period
Data category: Metadata
LiveRamp, the service provider, does not store any data that directly relates to individuals. LiveRamp only stores so-called ‘metadata’, which does not allow for the direct identification of the data subject (such as the country code and a timestamp).
Purpose: to ensure that our online services are tailored to users’ needs, attractive, up-to-date and in keeping with current trends; to optimise and market our online services; to rectify errors; to ensure quality; and to detect fraud. Legal basis:
Article 6(1), first sentence, point (a) GDPR:Your consent in the context of your interaction with our Consent Management Platform (‘CMP’)
Article 6(1), first sentence, point (f) GDPR:Our legitimate interest is based, in particular, on our interest in marketing, providing, optimising, designing and continuously updating and improving our online services. Furthermore, our legitimate interest is based on ensuring the security of our products and on fraud prevention.
Retention period:
Personal data will be deleted as soon as their further Processing is no longer necessary for the relevant purpose and there are no statutory retention periods preventing its erasure. This is usually the case upon receipt of your withdrawal or your objection.
In addition, there is the option to Processing To object to the processing of your personal data by LiveRamp: https://liveramp.de/privacy/datenschutzerklarung-fur-die-liveramp-dienste/
Metadata that cannot be linked to a specific individual, such as country codes and timestamps, is deleted after 12 months.
(b) Recipients of the personal data
Data concerned: all data referred to in point (a) of this section. Legal basis:Article 6(1)(a) and (f) of the GDPRRecipient category: LiveRamp SAS, 25 rue Anatole, 92300 Levallois-Perret, France. The recipient of the hashed email address is LiveRamp France; the hashed email address is deleted immediately after the pseudonymised ID has been created. The pseudonymised ID may then be transferred to other advertising partners on the basis of your consent.
22. Use of the EUID by the Trade Desk
If we have your email address, we will use it to create an additional advertising identifier (known as an EUID) using the technology provided by The Trade Desk. Instead of using your email address directly, the EUID is used to match information across different contexts and to share it with authorised websites and advertisers who are permitted to use the EUID for advertising purposes. The EUID is stored in a cookie on your device. It enables us and our advertising partners to recognise you across different platforms and devices and to provide you with personalised advertising. Your EUID may also be shared with our advertising partners and other third-party providers so that we can offer you content and advertising tailored to your interests. The processing operations mentioned above, in particular the creation of the EUID, take place only if you have given your consent via our Consent Management Platform (‘CMP’). For further information on data protection and data processing in connection with the creation of the EUID, please refer to the EUID Privacy Notice.
(a) Purpose of data processing, legal basis and, where applicable, legitimate interests; retention period
Data category: Metadata Purpose: to ensure that our online services are tailored to users’ needs, attractive, up-to-date and in keeping with current trends; to optimise and market our online services Legal basis:
Article 6(1), first sentence, point (a) GDPR:Your consent in connection with your interaction with our Consent Management Platform (‘CMP’)
Article 6(1), first sentence, point (f) GDPR:Our legitimate interest is based, in particular, on our interest in marketing, maintaining, optimising, designing and continuously updating and improving our online services. Furthermore, our legitimate interest is based on ensuring the security of our products and on fraud prevention.
Retention period:
Personal data will be deleted as soon as their further Processing is no longer necessary for the fulfilment of the relevant purpose and statutory retention periods do not preclude its erasure. This is usually the case upon receipt of your withdrawal or objection.
In addition, there is the option of Processing To object to the processing of your personal data by the Trade Desk: https://transparentadvertising.eu/privacy/
(b) Recipients of the personal data
Recipient category: The UK Trade Desk Ltd., 10th Floor, 1 Bartholomew Close, London EC1A 7BL, United Kingdom. Data concerned: all data referred to in point (a) of this section. Legal basis:Article 6(1)(a) of the GDPR
23. Information on joint responsibility pursuant to Article 26(2), second sentence GDPR in the field of online marketing through ‘BCN’
Below, we set out the key terms agreed between the parties listed below in the context of joint controllership pursuant to Article 26(1) GDPR were agreed.
(a) Data controllers involved
- Brand Community Network GmbH (“BCN”) – Online marketer (Party 1)
- We, as the website publisher (Party 2)
(b) Reason for joint responsibility
Party 1 and Party 2 work closely together in the provision of online advertising. This includes the Processing personal data of visitors to our website. The parties have jointly defined the processing procedures and areas of responsibility and are therefore jointly responsible for the protection of your personal data (Article 26 of the GDPR).
(c) Areas of responsibility under joint controllership
Party 1 provides the technical infrastructure, as well as various vendors and trackers, which are integrated into Party 2’s online services. This integration is carried out for the purposes of data collection and the delivery of advertising.
(d) Agreements between the parties
The parties have entered into agreements, within the framework of their joint responsibility, to set out who fulfils which obligations under the GDPR. This includes, in particular, safeguarding the rights of data subjects and fulfilling the information obligations set out in Articles 13 and 14 of the GDPR. This agreement is necessary as personal data is processed in different systems and areas of responsibility.
Area of responsibility | Person responsible
- Provision of technical infrastructure, tools and online marketing services | Party 1 In this area, Party 1 (the online marketer) assumes responsibility for the provision and management of the technical infrastructure, including the necessary software tools and systems for online advertising. In addition to the technical aspects, this also includes online marketing services, such as the management of advertising inventory, the selection and control of the advertising vendors and trackers used, and the monitoring and optimisation of advertising performance.
- Integration of technologies into the website | Part 2
- Recording and Processing the data | Party 1 and Party 2
(e) Implications for data subjects
Even where there is joint responsibility, the parties shall fulfil their data protection obligations in accordance with their respective areas of responsibility. Party 2 is responsible for the integration and initial data collection on the website, whilst Party 1 is responsible for the further Processing is responsible for the data.
(f) Exercising your rights as a data subject
To exercise your data protection rights under Articles 15 to 22 GDPR To exercise this right, you may contact the relevant party. Irrespective of this, you have the right to make enquiries relating to the joint Processing You can also put your enquiry directly to each party. Your enquiry will then be forwarded immediately to the relevant department.
24. Facebook and Facebook marketing services
24.1. Within our online service, we use the so-called ‘Facebook Pixel’ from the social network Facebook – operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are resident in the EU, by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”).
24.2. The Facebook Pixel enables Facebook, firstly, to identify visitors to our website as a target audience for the display of adverts (so-called “Facebook Ads”). Accordingly, we use the Facebook Pixel to ensure that the Facebook Ads we place are shown only to those Facebook users who have demonstrated an interest in our online offering or who share certain characteristics (e.g. interests in specific topics or products, determined on the basis of the webpages visited), which we transmit to Facebook (so-called ‘Custom Audiences’). We also use the Facebook Pixel to ensure that our Facebook Ads match users’ potential interests and do not come across as intrusive. Furthermore, with the help of the Facebook Pixel, we can track the effectiveness of Facebook adverts for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook advert (known as a ‘conversion’).
24.3. Facebook processes the data in accordance with its Data Use Policy. General information on the display of Facebook adverts can be found in Facebook’s Data Use Policy: https://www.facebook.com/policy.php. Specific information and details about the Facebook Pixel and how it works can be found in the Facebook Help Centre: https://www.facebook.com/business/help/651294705016616.
24.4. You can object to the collection of data by the Facebook Pixel and the use of your data to display Facebook adverts. To control the types of adverts shown to you on Facebook, you can visit the page set up by Facebook and follow the instructions on settings for usage-based advertising: https://www.facebook.com/settings?tab=ads. These settings apply across all platforms, i.e. they are applied to all devices, such as desktop computers or mobile devices.
24 May You can also opt out of the use of cookies for audience measurement and advertising purposes via the Network Advertising Initiative’s opt-out page (http://optout.networkadvertising.org/) and, in addition, the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).
25th Newsletter
25.1. The following information explains the content of our newsletter, as well as the procedures for subscription, distribution and statistical analysis, and your rights to object. By subscribing to our newsletter, you agree to receive it and to the procedures described.
25.2. Content of the newsletter: We send out newsletters, emails and other electronic communications containing promotional information (hereinafter ‘newsletters’) only with the consent of the recipients or where permitted by law. Where the content of the newsletter is specifically described as part of the subscription process, this content forms the basis for the user’s consent. In addition, our newsletters contain information about our products, offers, promotions and our company.
25.3. Double opt-in and logging: Subscription to our newsletter is carried out via a so-called double opt-in procedure. This means that, after signing up, you will receive an email asking you to confirm your subscription. This confirmation is necessary to ensure that nobody can sign up using someone else’s email address. Newsletter subscriptions are logged so that we can provide evidence of the subscription process in accordance with legal requirements. This includes recording the time of subscription and confirmation, as well as the IP address. Any changes to your data stored with the mailing service provider are also logged.
25.4. Mailing service provider: Newsletters are sent via Mailjet SAS, 13-13 bis, rue de l’Aubrac, 75012 Paris, France, on behalf of boote-magazin.de, hereinafter referred to as the ‘mailing service provider’. You can view the mailing service provider’s privacy policy here: https://www.mailjet.de/privacy-policy/ (boote-magazin.de)
25.5. Furthermore, according to the delivery service provider’s own information, it may use this data in pseudonymous form, i.e. without linking it to a specific user, to optimise or improve its own services, e.g. for the technical optimisation of the dispatch and presentation of the newsletter or for statistical purposes to determine which countries the recipients come from. However, the mailing service provider does not use the data of our newsletter recipients to contact them itself or to pass it on to third parties.
25.6. Registration details: To subscribe to the newsletter, simply provide your email address. We also ask you to provide a name, if you wish, so that we can address you personally in the newsletter.
25.7. Performance measurement – The newsletters contain a so-called ‘web beacon’, i.e. a pixel-sized file which is retrieved from the mailing service provider’s server when the newsletter is opened. As part of this retrieval, technical information – such as details about your browser and system – as well as your IP address and the time of retrieval are initially collected. This information is used to improve the services technically on the basis of the technical data, or to analyse target groups and their reading behaviour based on their access locations (which can be determined using the IP address) or access times. The statistical analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. Although this information can, for technical reasons, be attributed to individual newsletter recipients, it is neither our intention nor that of the email service provider to monitor individual users. Rather, the analyses help us to identify our users’ reading habits and tailor our content accordingly, or to send different content based on our users’ interests.
25.8. The dispatch of the newsletter and the measurement of its effectiveness are carried out on the basis of the recipients’ consent in accordance with Article 6(1)(a), Article 7 of the GDPR in conjunction with Section 7(2)(3) of the Unfair Commercial Practices Act (UWG), or on the basis of statutory authorisation pursuant to Section 7(3) of the Unfair Commercial Practices Act (UWG).
25.9. The registration process is logged on the basis of our legitimate interests in accordance with Article 6(1)(f) of the GDPR and serves as proof of consent to receive the newsletter.
25 October. Cancellation/Withdrawal – Newsletter subscribers may cancel their subscription to our newsletter at any time, i.e. withdraw their consent. A link to cancel the newsletter can be found at the end of every newsletter. This will simultaneously revoke your consent to performance tracking. Unfortunately, it is not possible to withdraw consent for performance measurement separately; in this case, the entire newsletter subscription must be cancelled. Upon unsubscribing from the newsletter, personal data will be deleted unless its retention is required or justified by law, in which case its processing will be restricted solely to these exceptional purposes. In particular, we may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them for the purposes of sending the newsletter, in order to be able to provide evidence of consent previously given. The processing of this data is limited to the purpose of potentially defending against claims. An individual request for erasure may be made at any time, provided that the prior existence of consent is confirmed at the same time.
26. Integration of third-party services and content
26.1. Within our online offering, we rely on our legitimate interests (i.e. an interest in the analysis, optimisation and commercial operation of our online offering within the meaning of Article 6(1)(f) of the GDPR) to incorporate content or services from third-party providers in order to integrate their content and services, such as videos or fonts (hereinafter collectively referred to as “content”). This always requires the third-party providers of this content to collect users’ IP addresses, as they would be unable to send the content to users’ browsers without the IP address. The IP address is therefore necessary for the display of this content. We endeavour to use only such content where the respective providers use the IP address solely for the purpose of delivering the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as ‘web beacons’) for statistical or marketing purposes. These ‘pixel tags’ enable the analysis of information such as visitor traffic on the pages of this website. This pseudonymous information may also be stored in cookies on the user’s device and may include, amongst other things, technical information about the browser and operating system, referring websites, time of visit and further details regarding the use of our online service; it may also be linked to such information from other sources.
26.2 The following section provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and – in some cases, as already mentioned here – options to object (so-called ‘opt-out’ options):
- External fonts from Google, LLC, https://www.google.com/fonts (‘Google Fonts’). Google Fonts are integrated via a server request to Google (usually in the USA). Privacy policy: https://policies.google.com/privacy, opt-out: https://adssettings.google.com/authenticated.
- Maps provided by the ‘Google Maps’ service operated by the third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, opt-out: https://www.google.com/settings/ads/.
- A security feature for forms designed to identify bots, provided by the ‘Google reCAPTCHA’ service operated by the third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated
- Videos from the “YouTube” platform provided by the third-party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://policies.google.com/privacy, opt-out: https://adssettings.google.com/authenticated.
- Classified adverts on the ‘boat24.com’ boat marketplace operated by the third-party provider Marine Classified Media AG, Langstrasse 151, 8004 Zurich, Switzerland. Users can access the boat marketplace via a link to create adverts there, which will then appear on the websites of Klambt Programmzeitschriften GmbH. The terms of use and privacy policy of boat24.com apply to the linked boat marketplace.
- YieldKit: Some pages contain affiliate links. If you click on these links and subsequently make a purchase, we will receive a commission. For further information, please visit our partner YieldKit’s website. YieldKit records these transactions, but never collects personal data such as names or addresses. For further detailed information regarding the data stored and to opt out, please visit the website https://yieldkit.de/legal-notes/privacy-policy/
- We use the service provider Vercel to host and deliver the boote-magazin.de website. Vercel enables us to deliver the content of our websites more quickly. Vercel also offers security features that ensure our websites operate more securely.
For further information, please see Vercel’s privacy policy: https://vercel.com/legal/privacy-policy
26.3 Integration of third-party content / embeds
We embed third-party content on our websites. This may include, for example, videos from YouTube or Vimeo, or social media posts from Facebook or Instagram. This external content is disabled by default and can be enabled by clicking on it. Upon activation, cookies from the third-party provider may be set in your browser, and general background data, such as your IP address, may be transmitted to the provider. We have no control over how the providers process this data.
Below you will find a list of the providers of the external content integrated into our platforms, organised by website:
YouTube, Vimeo, Instagram, Google Maps, Facebook, Twitter, Cloudinary, Mailjet, Involve.me, Crossengage, Algolia, Pipedrive
27. Affiliate links
In some of our posts, we use what are known as affiliate links. These are linked to a marked. If you click on one of these affiliate links and make a purchase via that link, we receive a commission from the relevant online shop or supplier. This does not affect the price you pay.
We work with the following providers: AWIN, OUTTRA, Amazon, Belboon, Adcell, GOAFFPRO.