Privacy statement
The list of processing activities comprises a collection of general information that is relevant to all processing methods described below, as well as specific details of individual processing processes in which personal data (hereinafter also referred to as “data” for short) is processed. This structure serves both to maintain clarity and to provide precise information. The general information explains basic principles and guidelines that apply to all processing activities, such as compliance with data protection principles, the legal basis for data processing, and how to deal with the rights of data subjects. The specific part of the directory provides detailed information on the individual processing processes, including the purpose of data processing, the categories of data concerned, the recipients of the data and, where applicable, the transfer of data to third countries. This directory serves as a central document to ensure transparency and traceability of data processing and is an essential element for meeting documentation requirements under the General Data Protection Regulation (GDPR).
Preamble
With the following privacy policy, we would like to explain to you what types of your personal data (hereinafter also referred to as “data” for short) we process for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).
The terms used are not gender-specific.
As of May 8, 2024
Table of contents
- preamble
- person responsible
- Overview of processing
- Relevant legal bases
- Safety measures
- Transfer of personal data
- International data transfers
- General information on data storage and deletion
- Rights of data subjects
- Provision of online services and web hosting
- Use of cookies
- Amendment and update
- Definitions of terms
Person responsible
Inna Mosor
Münsterplatz 32
79098 Freiburg
email address: art@innamosor.de
Telefon: +49 [0] 170 - 7227770
Overview of processing
The following overview summarizes the types of data processed and the purposes of their processing and refers to the persons concerned.
Types of data processed
- inventory data.
- contact details.
- Content data.
- usage data.
- Meta, communication and procedural data.
- log data.
Categories of affected persons
- communication partner.
- user.
Purposes of processing
- communication.
- safety measures.
- organizational and administrative procedures.
- feedback.
- Provision of our online offering and user-friendliness.
- Information technology infrastructure.
Relevant legal bases
Relevant legal bases under the GDPR: The following is an overview of the legal bases of the GDPR, on the basis of which we process personal data. Please note that, in addition to the provisions of the GDPR, national data protection requirements may apply in your or our country of residence or place of residence. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy.
- Consent (Article 6 (1) (a) GDPR) - The data subject has given consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
- Legitimate interests (Art. 6 (1) (f) GDPR) - processing is necessary to protect the legitimate interests of the controller or of a third party, provided that the interests, fundamental rights and freedoms of the data subject, which require the protection of personal data, do not prevail.
National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes in particular the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act — BDSG). In particular, the BDSG contains special rules on the right to information, the right to deletion, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission and automated decision-making in individual cases, including profiling. In addition, state data protection laws of the individual federal states may apply.
Safety measures
In accordance with legal requirements, taking into account the state of the art, implementation costs and the nature, scope, circumstances and purposes of processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organizational measures 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 physical and electronic access to the data as well as the access, input, transfer, availability and separation of data relating to it. We have also set up procedures that ensure the exercise of data subject rights, the deletion of data and responses to the data being compromised. In addition, 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 privacy-friendly default settings.
Securing online connections using TLS/SSL encryption technology (HTTPS): In order to protect user data transmitted via our online services from unauthorised access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the Internet. These technologies encrypt the information that is transferred between the website or app and the user's browser (or between two servers), which protects the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator for users that their data is transmitted securely and encrypted.
Transfer of personal data
As part of our processing of personal data, it may be transferred to or disclosed to other bodies, companies, legally independent organizational units or persons. Recipients of this data may include, for example, service providers tasked with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
International data transfers
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 if processing takes place as part of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with legal requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for data transfer. In addition, data transfers only take place if the level of data protection is otherwise ensured, in particular by standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), express consent or, in the case of contractual or legally required transfer (Art. 49 para. 1 GDPR). In addition, we will provide you with the principles of third-country transfers with the individual providers from the third country, with the adequacy decisions taking priority as the basis. Information on transfers to third countries and existing adequacy decisions can be found in the information offered by the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de
EU-US Trans-Atlantic Data Privacy Framework: As part of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection as secure for certain companies from the USA as part of the adequacy decision of 10.07.2023. The list of certified companies and further information about the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ Remove (in English). As part of the data protection policy, we will inform you which service providers we use are certified under the Data Privacy Framework.
General information on data storage and deletion
We delete personal data that we process in accordance with legal provisions as soon as the underlying consent is withdrawn or there is no further legal basis for processing. This applies to cases in which the original purpose of processing no longer applies or the data is no longer required. There are exceptions to this regulation when legal obligations or special interests require the data to be stored or archived for a longer period of time.
In particular, data that must be stored for commercial or tax reasons or whose storage is necessary to prosecute or protect the rights of other natural or legal persons must be archived accordingly.
Our privacy policy contains additional information on the storage and deletion of data that applies specifically to specific processing processes.
If there is more information about the storage period or deletion periods of a date, the longest period is always decisive.
If a period does not expressly start on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the deadline occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the deadline is the effective date of the termination or other termination of the legal relationship.
We process data that is no longer stored for the originally intended purpose, but due to legal requirements or other reasons, exclusively for the reasons that justify their storage.
Further information on processing processes, procedures and services:
- Retention and deletion of data: The following general deadlines apply for storage and archiving under German law:
- 10 years - Retention period for books and records, annual financial statements, inventories, management reports, opening balance sheet as well as the work instructions and other organizational documents, accounting documents and invoices required for their understanding (Section 147 para. 3 in conjunction with Paragraph 1 No. 1, 4 and 4a AO, Section 14b Paragraph 1 No. 1 No. 1 and 4 HGB).
- 6 years - Other business documents: received commercial or business letters, reproductions of the sent commercial or business letters, other documents insofar as they are relevant for taxation, e.g. hourly pay slips, operating statement sheets, calculation documents, price awards, but also payroll documents, insofar as they are not already accounting documents and cash strips (Section 147 (3) in conjunction with Paragraph 1 No. 2, 3, 5 AO, Section 257 Paragraph 1 No. 2 and 3, Paragraph 4 HGB).
- 3 years - Data necessary to consider potential warranty and compensation claims or similar contractual claims and rights and to process related inquiries, based on previous business experience and usual industry practices, is stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).
Rights of data subjects
Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:
- Right of objection: For reasons arising from your particular situation, you have the right to object at any time to the processing of personal data concerning you, which is carried out on the basis of Article 6 (1) (e) or (f) GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is associated with such direct marketing.
- Right of withdrawal in case of consent: You have the right to withdraw your consent at any time.
- Right to information: You have the right to request confirmation as to whether the relevant data is being processed and for information about this data as well as further information and a copy of the data in accordance with legal requirements.
- Right to rectification: In accordance with legal requirements, you have the right to request the completion of the data concerning you or the correction of incorrect data concerning you.
- Right to delete and restrict processing: In accordance with legal requirements, you have the right to request that data concerning you be deleted immediately or, alternatively, to request that the processing of the data be restricted in accordance with legal requirements.
- Right to data portability: You have the right to receive data concerning 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 supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you believe that the processing of personal data concerning you is contrary to the requirements of the GDPR.
Provision of online services and web hosting
We process user data in order to be able to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transfer the content and functions of our online services to the user's browser or device.
- Types of data processed: Usage data (e.g. page views and length of stay, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication and process data (e.g. IP addresses, time information, identification numbers, people involved). Log data (e.g. log files relating to logins or the retrieval of data or access times.).
- Affected persons: users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.).). safety measures.
- Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).
Further information on processing processes, procedures and services:
- Provision of online services on rented storage space: To provide our online service, we use storage space, computing capacity and software, which we rent or otherwise obtain from an appropriate server provider (also known as a “web host”); Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).
- Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files”. The server log files may include the address and name of the retrieved websites and files, date and time of retrieval, amount of data transferred, notification of successful retrieval, 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. The server log files can be used, on the one hand, for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and on the other hand to ensure the workload of the servers and their stability; Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is necessary for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
Use of cookies
Cookies are small text files or other memory notes that store information on end devices and read from them. For example, to save the login status in a user account, shopping cart content in an e-shop, the content accessed or functions used on an online offer. Cookies can also be used to address various concerns, such as the functionality, security and convenience of online offerings and to analyse visitor flows.
Information on consent: We use cookies in accordance with legal regulations. We therefore obtain prior consent from users, unless this is not required by law. In particular, permission is not required if the storage and reading of information, including cookies, is absolutely necessary to provide users with a telemedia service (i.e. our online offering) that they have expressly requested. The revocable consent is clearly communicated to them and contains information on the respective use of cookies.
Information on legal bases of data protection law: The data protection basis on which we process users' personal data using cookies depends on whether we ask them for consent. If users accept, the legal basis for using their data is their given consent. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in operating our online offering and improving its usability) or, if this is done as part of fulfilling our contractual obligations, if the use of cookies is necessary to meet our contractual obligations. We will explain the purposes for which we use cookies in the course of this privacy policy or as part of our consent and processing processes.
Storage period: With regard to storage time, the following types of cookies are differentiated:
- Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their device (e.g. browser or mobile application).
- Persistent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved and preferred content displayed directly when the user visits a website again. User data collected using cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g. when obtaining consent), they should assume that they are permanent and that the storage period can be up to two years.
General information on withdrawal and objection (opt-out): Users can withdraw their consent at any time and also declare an objection to processing in accordance with legal requirements, including using the privacy settings of their browser.
- Types of data processed: Meta, communication and process data (e.g. IP addresses, time information, identification numbers, persons involved).
- Affected persons: users (e.g. website visitors, users of online services).
- Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR). Consent (Art. 6 (1) (a) GDPR).
Further information on processing processes, procedures and services:
- Processing of cookie data based on consent: We use a consent management solution that obtains users' consent to the use of cookies or to the procedures and providers mentioned as part of the consent management solution. This procedure is used to obtain, log, manage and withdraw consent, in particular with regard to the use of cookies and comparable technologies, which are used to store, read and process information on users' devices. As part of this procedure, users' consent is obtained for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management process. Users also have the option to manage and withdraw their consent. The declarations of consent are stored in order to avoid a new request and to be able to provide proof of consent in accordance with legal requirements. The data is stored on the server side and/or in a cookie (so-called opt-in cookie) or using comparable technologies in order to be able to assign consent to a specific user or their device. If there is no specific information about the providers of consent management services, the following general information applies: The period of storage of consent is up to two years. This creates a pseudonymous user identifier, which is stored together with the time of consent, information on the scope of consent (e.g. relevant categories of cookies and/or service providers) and information about the browser, the system and the device used; Legal bases: Consent (Art. 6 (1) (a) GDPR).
Amendment and update
We ask you to regularly check the content of our privacy policy. We will adjust the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.
Definitions of terms
This section provides an overview of the terms used in this privacy statement. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended for understanding.
- Inventory data: Inventory data includes essential information that is necessary to identify and manage contract partners, user accounts, profiles and similar assignments. This data may include personal and demographic information such as names, contact information (addresses, telephone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Inventory data forms the basis for any formal interaction between people and services, facilities or systems by enabling unambiguous attribution and communication.
- Content data: Content data includes information that is generated in the course of creating, editing, and publishing all types of content. This category of data can include text, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not only limited to the actual content, but also includes metadata that provides information about the content itself, such as tags, descriptions, author information, and publication dates
- contact details: Contact data is essential information that enables communication with people or organizations. They include telephone numbers, postal addresses and email addresses, as well as means of communication such as social media handles and instant messaging identifiers.
- Meta, communication and process data: Meta, communication, and procedural data are categories that contain information about how data is processed, transmitted, and managed. Meta data, also known as data about data, includes information that describes the context, origin, and structure of other data. They can include information about the file size, creation date, author of a document, and change histories. Communication data records the exchange of information between users via various channels, such as email traffic, call logs, messages on social networks and chat histories, including the people involved, time stamps, and transmission channels. Procedural data describes the processes and operations within systems or organizations, including workflow documentation, logs of transactions and activities, and audit logs that are used to track and review operations.
- Usage data: Usage data refers to information that records how users interact with digital products, services, or platforms. This data includes a wide range of information that shows how users use applications, which features they prefer, how long they spend on specific pages, and which paths they use to navigate through an application. Usage data may also include frequency of use, time stamps of activities, IP addresses, device information, and location data. They are particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. In addition, usage data plays a decisive role in identifying trends, preferences and potential problem areas within digital offerings
- Personal data: “Personal data” is any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more special characteristics that express the physical, physiological, genetic, psychological, economic, are the cultural or social identity of that natural person.
- Log data: Log data is information about events or activities that have been logged on a system or network. This data typically includes information such as time stamps, IP addresses, user actions, error messages, and other details about the use or operation of a system. Log data is often used to analyze system issues, monitor security, or generate performance reports.
- responsible person: “Responsible person” is the natural or legal person, authority, agency or other body which, alone or together with others, decides on the purposes and means of processing personal data.
- processing: “Processing” means any process carried out with or without the aid of automated procedures or any such series of processes in connection with personal data. The term is broad and covers virtually any handling of data, whether collection, evaluation, storage, transmission or deletion.