This data protection declaration informs you about the type, scope and purpose of the processing of personal data (hereinafter referred to as "data") in the context of the provision of our services as well as within our online offer and the websites, functions and content connected with it as well as external online presences, such as our social media profiles (hereinafter jointly referred to as "online offer"). With regard to the terms used, such as "processing" or "controller", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
Glückssträhnen GmbH & Co. KG
E-mail address: firstname.lastname@example.org
Link to the imprint:
Types of data processed
- Inventory data (e.g., personal master data, names or addresses).
- Contact data (e.g., e-mail, phone numbers).
- Content data (e.g., text input, photographs, videos).
- Usage data (e.g., web pages visited, 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, we also refer to the data subjects collectively as "users").
Purpose of processing
- Making available the online offer, its functions and content.
- Responding to contact requests and communicating with users.
- Security measures.
- Reach measurement/marketing.
"Personal data" means 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 factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
"Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data.
"Pseudonymization" 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 such additional information is kept separately and is subject to technical and organizational measures which ensure that the personal data are not attributed to an identified or identifiable natural person.
"Profiling" means any automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location.
"Controller" means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
"Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller.
Relevant legal basis
The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 DSGVO;
The legal basis for processing for the fulfillment of our services and implementation of contractual measures as well as answering inquiries is Art. 6 (1) lit. b DSGVO;
The legal basis for processing to fulfill our legal obligations is Art. 6 (1) lit. c DSGVO;
In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) lit. d DSGVO serves as the legal basis.
The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Art. 6 (1) lit. e DSGVO.
The legal basis for processing to protect our legitimate interests is Art. 6 (1) lit. f DSGVO.
The processing of data for purposes other than those for which they were collected is determined by the requirements of Art. 6 (4) DSGVO.
The processing of special categories of data (according to Art. 9 (1) DSGVO) is determined according to the requirements of Art. 9 (2) DSGVO.
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the 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, in order to ensure a level of protection appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, entry into, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, deletion of data, and response to data compromise. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.
Cooperation with processors, joint controllers and third parties
If, in the course of our processing, we disclose data to other persons and companies (order processors, jointly responsible persons or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is necessary for the performance of the contract), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we disclose or transfer data to other companies in our group of companies or otherwise grant them access, this is done in particular for administrative purposes as a legitimate interest and, in addition, on a basis that complies with legal requirements.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this occurs in the context of the use of third-party services or disclosure, or transfer of data to other persons or companies, this will only occur if it is done for the fulfillment of 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 legal or contractual permissions, we process or leave the data in a third country only if the legal requirements are met. I.e. the processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to that of the EU (e.g. for the USA by the "Privacy Shield") or compliance with officially recognized special contractual obligations.
Rights of data subjects
You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
You have the right, in accordance with. the legal requirements, to request that the data concerning you be completed or that incorrect data concerning you be corrected.
You have the right, in accordance. with the legal requirements, to demand that data concerning you be deleted without delay, or alternatively, in accordance with the legal requirements, to demand restriction of the processing of the data.
You have the right to demand that the data concerning you that you have provided to us be received in accordance with the legal requirements and to demand that it be transferred to other persons responsible.
You also have the right, in accordance with the law, to lodge a complaint with the competent supervisory authority.
Right of withdrawal
You have the right to revoke any consent you have given with effect for the future.
Right of objection
You may object to the future processing of data relating to you at any time in accordance with the statutory provisions. The objection can be made in particular against processing for purposes of direct advertising.
Cookies and right to object in the case of direct advertising
Cookies" are small files that are stored on users' computers. Various data can be stored within the cookies. The primary purpose of a cookie is 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. Such a cookie may store, for example, the contents of a shopping cart in an online store or a login status. Cookies that remain stored even after the browser is closed are referred to as "permanent" or "persistent". For example, the login status can be stored if users visit them after several days. Likewise, the interests of users can be stored in such a cookie, which is used for range measurement or marketing purposes. Third-party cookies" are cookies that are offered by providers other than the responsible party that operates the online offer (otherwise, if they are only its 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
The data processed by us will be deleted or restricted in its processing in accordance with the legal requirements. Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory retention obligations.
If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.
We ask you to inform yourself regularly about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
In addition, we process
- Contract data (e.g., subject matter of the contract, term, customer category).
- Payment data (e.g., bank details, payment history)
of our customers, interested parties and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
Order processing in the online store and customer account
We process the data of our customers in the context of ordering processes in our online store 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 of the processing include our customers, prospective customers and other business partners. The processing is carried out for the purpose of providing contractual services in the context of operating an online store, billing, delivery and customer services. In this context, we use session cookies for storing the shopping cart content and permanent cookies for storing the login status.
Users can optionally create a user account, in which they can view their orders in particular. During the registration process, users are provided with the required mandatory information. User accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data with regard to the user account will be deleted, subject to their retention is necessary for commercial or tax reasons. Information in the customer account will remain until its deletion with subsequent archiving in the event of a legal obligation or our legitimate interests (e.g., in the event of litigation). It is the responsibility of the users to save their data in the event of termination before the end of the contract.
In the context of registration and renewed registrations as well as use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as those of users in protection against abuse and other unauthorized use. In principle, this data is not passed on to third parties, unless it is necessary for the pursuit of our legal claims as a legitimate interest or there is a legal obligation to do so.
Deletion takes place after expiry of legal warranty and other contractual rights or obligations (e.g., payment claims or performance obligations arising from contracts with customers), whereby the necessity of retaining the data is reviewed every three years; in the case of retention due to legal archiving obligations, deletion takes place after their expiry.
External payment service providers
In the context of the performance of contracts, we use the payment service providers on the basis of Art. 6 para. 1 lit. b. DSGVO. Furthermore, we use external payment service providers on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. DSGVO in order to offer our users effective and secure payment options.
The data processed by the payment service providers 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, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e. we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the payment service providers transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the terms and conditions and data protection information of the payment service providers.
For the payment transactions, the terms and conditions and data protection information of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of revocation, information and other data subject rights.
Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as organization of our operations, financial accounting and compliance with legal obligations, such as archiving. In this regard, 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. DSGVO, Art. 6 para. 1 lit. f. DSGVO. Customers, interested parties, 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, i.e. tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information mentioned in these processing activities.
In this context, we disclose or transfer data to the tax authorities, consultants, such as tax advisors or auditors, as well as other fee offices and payment service providers.
Furthermore, based on our business interests, we store information on suppliers, event organizers and other business partners, e.g. for the purpose of contacting them at a later date. This data, most of which is company-related, is generally stored permanently.
Business analyses and market research
In order to operate our business economically and to be able to recognize market trends and the wishes of contractual partners and users, we analyze the data we have on business transactions, contracts, inquiries, etc.. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. DSGVO, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offer.
The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we may take into account the profiles of registered users with details, for example, of the services they have used. The analyses serve us to increase the user-friendliness, the optimization of our offer and the business management. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with aggregated values.
If these analyses or profiles are personal, they will be deleted or anonymized upon termination of the user, otherwise after two years from the conclusion of the contract. Otherwise, the overall business analyses and general tendency analyses are created anonymously, if possible.
Participation in affiliate partner programs
Within our online offer, we use industry-standard tracking measures based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer) pursuant to Art. 6 (1) lit. f DSGVO, insofar as these are necessary for the operation of the affiliate system. In the following, we explain the technical background to users.
The services offered by our contractual partners may also be advertised and linked on other websites (so-called affiliate links or after-buy systems, if, for example, links or third-party services are offered after a contract has been concluded). The operators of the respective websites receive a commission if users follow the affiliate links and subsequently take advantage of the offers.
In summary, it is necessary for our online offer that we can track whether users who are interested in affiliate links and/or the offers available on our website subsequently take up the offers at the instigation of the affiliate links or our online platform. For this purpose, the affiliate links and our offers are supplemented by certain values, which may be part of the link or otherwise set, e.g. in a cookie. The values include in particular the source website (referrer), time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking-specific values such as advertising material ID, affiliate ID and categorizations.
The online identifiers of the users used by us are pseudonymous values. That is, the online identifiers themselves do not contain any personal data such as names or email addresses. They only help us to determine whether the same user who clicked on an affiliate link or became interested in an offer via our online offer has taken advantage of the offer, i.e. has concluded a contract with the provider, for example. However, the online identifier is personal to the extent that the partner company and also us, the online identifier together with other user data. Only in this way can the partner company tell us whether the user has taken advantage of the offer and we can, for example, pay out the bonus.
Amazon affiliate program
We are based on our legitimate interests (i.e. interest in the economic operation of our online offering within the meaning of Art. 6 para. 1 lit. f. DSGVO) participants in the affiliate program of Amazon EU, which was designed to provide a medium for websites, by means of which through the placement of advertisements and links to Amazon.co.uk advertising fees can be earned (so-called affiliate system). I.e. as an Amazon partner we earn on qualified purchases.
Note: Amazon and the Amazon logo are trademarks of Amazon.com, Inc. or one of its affiliates.
Users can create a user account. As part of the registration process, the required mandatory information is provided to users and processed on the basis of Art. 6 (1) lit. b DSGVO for purposes of providing the user account. The processed data includes in particular the login information (name, password as well as an email address). The data entered during registration is used for the purposes of using the user account and its purpose.
Users may be informed about information relevant to their user account, such as technical changes, by e-mail. If users have terminated their user account, their data relating to the user account will be deleted, subject to any legal obligation to retain it. It is the responsibility of users to back up their data upon termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract.
Within the scope of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as those of the users in protection against abuse and other unauthorized use. In principle, this data is not passed on to third parties, unless it is necessary for the pursuit of our claims or there is a legal obligation to do so pursuant to Art. 6 para. 1 lit. c. DSGVO. The IP addresses are anonymized or deleted after 7 days at the latest.
Comments and contributions
When users leave comments or other contributions, their IP addresses may be stored on the basis of our legitimate interests as defined in Art. 6 (1) lit. f. DSGVO are stored for 7 days. This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.
Furthermore, we reserve the right, on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. DSGVO, to process the information provided by users for the purpose of spam detection.
The personal information provided in the context of comments and contributions, any contact and website information as well as the content-related information will be stored permanently by us until the user objects.
Follow-up comments can be subscribed to by users with their consent pursuant to Art. 6 para. 1 lit. a DSGVO. Users will receive a confirmation email to verify that they are the owner of the email address entered. Users can unsubscribe from ongoing comment subscriptions at any time. The confirmation email will include instructions on how to unsubscribe. For the purposes of proving user consent, we store the time of subscription along with users' IP address and delete this information when users unsubscribe.
You can unsubscribe from receiving our subscription at any time, i.e. revoke your consents. We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to prove consent formerly given. The processing of this data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.
Retrieval of emojis and smilies
The use of emojis is based on our legitimate interests, i.e. interest in an attractive design of our online offer according to Art. 6 para. 1 lit. f. DSGVO.
When contacting us (e.g. via contact form, email, telephone or via social media), the user's details are used to process the contact request and its handling pursuant to Art. 6 para. 1 lit. b. (in the context of contractual/pre-contractual relations), Art. 6 para. 1 lit. f. (other requests) DSGVO processed... The user's details may be stored in a customer relationship management system ("CRM system") or comparable inquiry organization.
We delete the requests if they are no longer necessary. We review the necessity every two years; Furthermore, the legal archiving obligations apply.
Hosting and E-mail dispatch
The hosting services used by us serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services, which we use for the purpose of operating this online offer.
In doing so, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta data 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 pursuant to Art. 6 para. 1 lit. f DSGVO in conjunction with Art. 28 DSGVO. Art. 28 DSGVO (conclusion of order processing contract).
Collection of access data and log files
Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. In doing so, pseudonymous usage profiles of the users can be created from the processed data.
We only use Google Analytics with IP anonymization activated. This means that the IP address of users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user's browser is not merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
Users' personal data is deleted or anonymized after 14 months.
Online presences in social media
We maintain online presences within social networks and platforms in order to be able to communicate with customers, interested parties and users active there and to inform them about our services there.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users' rights. With regard to U.S. providers certified under the Privacy Shield, we point out that they thereby undertake to comply with the data protection standards of the EU.
Furthermore, user data is usually processed for market research and advertising purposes. For example, usage profiles can be created from the usage behavior and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behavior and interests of the users are stored. Furthermore, data may also be stored in the usage profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
The processing of the users' personal data is based on our legitimate interests in effectively informing users and communicating with users pursuant to Art. 6 para. 1 lit. f. DSGVO. If the users are asked by the respective providers of the platforms for consent to the aforementioned data processing, the legal basis of the processing is Art. 6 para. 1 lit. a., Art. 7 DSGVO.
For a detailed description of the respective processing and the opt-out options, please refer to the information of the providers linked below.
Also in the case of requests for information and the assertion of user rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
Integration of third-party services and content
Within our online offer, we use content or service providers on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. f. DSGVO) to integrate content or services offered by third-party providers, such as videos or fonts (hereinafter uniformly referred to as "content").
This always requires that the third-party providers of this content are aware of the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content. We endeavor to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.