INTRODUCTION
With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) 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 presence”).
The terms used are not gender-specific.
Die Stoffmacher GmbH
Bahnhofstraße 4
73235 Weilheim / Teck
Germany
Authorized Representatives: Christian Otto, Ulrich Bellinghausen
E info@die-stoffmacher.de
T +49 (0) 7023 9588 344
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
In the following, we communicate the legal bases of the General Data Protection Regulation (GDPR) on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection requirements in your or our country of residence and domicile may apply. Should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.
Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR) – The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
Performance of a contract and prior requests (Art. 6 para. 1 sentence 1 lit. b. GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, 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). The BDSG contains, in particular, special regulations on the right to information, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes, and transfer, as well as automated individual decision-making, including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, implementation, or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.
Security Measures
We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation, and the nature, scope, context, and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, to ensure a level of security 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, entry, disclosure, assurance of availability, and separation of data. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and responses to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software, and procedures in accordance with the principle of data protection by design and by default.
Transfer and Disclosure of Personal Data
In the context of our processing of personal data, it happens that the data is transferred to other bodies, companies, legally independent organizational units, or persons or disclosed to them. Recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks, or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.
Data Processing in Third Countries
If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of using third-party services or the disclosure or transfer of data to other persons, bodies, or companies, this only takes place in accordance with the legal requirements.
Subject to express consent or contractually or legally required transfer, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).
Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user’s computer. A cookie primarily serves to store information about a user during or after their visit within an online presence. The stored information may include, for example, the language settings on a website, the login status, a shopping cart, or the place where a video was watched. The term cookies also includes other technologies that fulfill the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”).
The following cookie types and functions are distinguished:
Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online presence and closed their browser.
Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be stored or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users used for reach measurement or marketing purposes can be stored in such a cookie.
First-party cookies: First-party cookies are set by us.
Third-party cookies: Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
Necessary (also: essential or strictly necessary) cookies: Cookies can, on the one hand, be strictly necessary for the operation of a website (e.g., to store logins or other user entries or for security reasons).
Statistics, marketing, and personalization cookies: Furthermore, cookies are usually also used in the context of reach measurement and when the interests of a user or their behavior (e.g., viewing certain content, using functions, etc.) are stored in a user profile on individual websites. Such profiles serve to show users, for example, content that corresponds to their potential interests. This process is also referred to as “tracking,” i.e., tracking the potential interests of users. Insofar as we use cookies or “tracking” technologies, we will inform you separately in our privacy policy or in the context of obtaining consent.
Notes on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask you for consent. If this applies and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g., in a commercial operation of our online presence and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.
Storage period: Unless we provide you with explicit information on the storage period of permanent cookies (e.g., in the context of a so-called cookie opt-in), please assume that the storage period can be up to two years.
General notes on withdrawal and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to withdraw consent given or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection by means of the settings of your browser, e.g., by deactivating the use of cookies (although this may also restrict the functionality of our online presence). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further objection notices in the context of the information on the service providers and cookies used.
Processing of cookie data on the basis of consent: We use a cookie consent management process in the context of which the users’ consent to the use of cookies, or the processing and providers mentioned in the context of the cookie consent management process, can be obtained and managed and withdrawn by the users. Here, the declaration of consent is stored in order not to have to repeat its query and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following notes apply: The duration of the storage of the consent can be up to two years. Here, a pseudonymous user identifier is formed and stored with the time of consent, information on the scope of the consent (e.g., which categories of cookies and/or service providers) as well as the browser, system, and end device used.
Processed data types: Usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
Data subjects: Users (e.g., website visitors, users of online services).
Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Provision of the online presence and web hosting
In order to be able to provide our online presence securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online presence can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.
The data processed in the context of providing the hosting offer may include all information concerning the users of our online presence that arises in the context of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the content of online presences to browsers, and all entries made within our online presence or from websites.
Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the accessed websites and files, date and time of access, transferred data volumes, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), and usually 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 utilization of the servers and their stability.
Processed data types: Content data (e.g., entries in online forms), usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
Data subjects: Users (e.g., website visitors, users of online services).
Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
When contacting us (e.g., via contact form, email, telephone, or via social media), the information of the inquiring persons is processed insofar as this is necessary to answer the contact inquiries and any requested measures.
The answering of contact inquiries in the context of contractual or pre-contractual relationships takes place to fulfill our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of legitimate interests in answering the inquiries.
Processed data types: Inventory data (e.g., names, addresses), contact data (e.g., email, telephone numbers), content data (e.g., entries in online forms).
Data subjects: Communication partners.
Purposes of processing: Contact requests and communication.
Legal bases: Performance of a contract and prior requests (Art. 6 para. 1 sentence 1 lit. b. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Web analysis (also referred to as “reach measurement”) serves to evaluate the visitor flows of our online presence and can include behavior, interests, or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online presence or its functions or content are used most frequently or invite reuse. Likewise, we can understand which areas require optimization.
In addition to web analysis, we can also use test procedures to, for example, test and optimize different versions of our online presence or its components.
For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar procedures with the same purpose can be used. This information may include, for example, content viewed, websites visited, and elements used there and technical information, such as the browser used, the computer system used, and information on usage times. If users have consented to the collection of their location data, these can also be processed depending on the provider.
The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of the users (such as email addresses or names) are stored in the context of web analysis, A/B testing, and optimization, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.
Notes on legal bases: If we ask the users for their consent to the use of third-party providers, the legal basis for the processing of data is the consent. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e., interest in efficient, economic, and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Data subjects: Users (e.g., website visitors, users of online services).
Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors), tracking (e.g., interest/behavioral profiling, use of cookies), conversion measurement (measuring the effectiveness of marketing measures), profiling (creation of user profiles).
Security measures: IP masking (pseudonymization of the IP address).
Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the presentation of advertising and other content (collectively referred to as “content”) based on potential user interests and the measurement of their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the information relevant to the presentation of the aforementioned content about the user is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information, such as the browser used, the computer system used, and information on usage times. If users have consented to the collection of their location data, these can also be processed.
The IP addresses of the users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of the users (such as email addresses or names) are stored in the context of the online marketing process, but pseudonyms. This means that we, as well as the providers of the online marketing processes, do not know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is usually stored in cookies or by means of similar procedures. These cookies can later generally also be read on other websites that use the same online marketing process and analyzed for the purpose of presenting content, as well as supplemented with further data and stored on the server of the online marketing process provider.
Exceptionally, clear data can be assigned to the profiles. This is the case if the users are, for example, members of a social network whose online marketing process we use and the network connects the users’ profiles with the aforementioned information. We ask you to note that users can make additional agreements with the providers, e.g., by giving consent in the context of registration.
We generally only receive access to summarized information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e., for example, to a contract conclusion with us. The conversion measurement is used solely to analyze the success of our marketing measures.
Unless otherwise stated, we ask you to assume that cookies used are stored for a period of two years.
Notes on legal bases: If we ask the users for their consent to the use of third-party providers, the legal basis for the processing of data is the consent. Otherwise, the users’ data will be processed on the basis of our legitimate interests (i.e., interest in efficient, economic, and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Processed data types: Usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
Data subjects: Users (e.g., website visitors, users of online services), prospective customers.
Purposes of processing: Tracking (e.g., interest/behavioral profiling, use of cookies), remarketing, conversion measurement (measuring the effectiveness of marketing measures), interest-based and behavioral marketing, profiling (creation of user profiles), reach measurement (e.g., access statistics, recognition of returning visitors).
Security measures: IP masking (pseudonymization of the IP address).
Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Objection option (opt-out): We refer to the privacy notices of the respective providers and the objection options (so-called “opt-out”) specified for the providers. If no explicit opt-out option has been specified, there is, on the one hand, the possibility that you switch off cookies in the settings of your browser. However, this may restrict functions of our online presence. We therefore additionally recommend the following opt-out options, which are offered collectively for the respective areas: a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
d) Cross-regional: https://optout.aboutads.info.
Services and service providers used:
Google Analytics: Online marketing and web analysis; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com/intl/en/about/analytics/; privacy policy: https://policies.google.com/privacy; objection option (opt-out): opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=en, settings for the display of advertisements: https://adssettings.google.com/authenticated.
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about us.
We point out that user data may be processed outside the European Union. This may result in risks for users because, for example, the enforcement of user rights could be made more difficult.
Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on usage behavior and resulting user interests. The usage profiles can in turn be used to, for example, place advertisements within and outside the networks 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 the interests of the users are stored. Furthermore, data can also be stored in the usage profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
For a detailed description of the respective forms of processing and the objection options (opt-out), we refer to the privacy policies and information of the operators of the respective networks.
Also in the case of requests for information and the assertion of data subject rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the user data and can directly take appropriate measures and provide information. Should you nevertheless need help, you can contact us.
Facebook: Together with Facebook Ireland Ltd., we are responsible for the collection (but not the further processing) of data from visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content users view or interact with, or the actions they take (see under “Things you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see under “Device Information” in the Facebook Data Policy statement: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analysis services, so-called “Page Insights,” for page operators so that they receive insights into how people interact with their pages and with the content associated with them. We have concluded a special agreement with Facebook (“Information about Page Insights,” https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the data subject rights (i.e., users can, for example, direct information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information about Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data).
Processed data types: Inventory data (e.g., names, addresses), contact data (e.g., email, telephone numbers), content data (e.g., entries in online forms), usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
Data subjects: Users (e.g., website visitors, users of online services).
Purposes of processing: Contact requests and communication, tracking (e.g., interest/behavioral profiling, use of cookies), remarketing, reach measurement (e.g., access statistics, recognition of returning visitors).
Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Services and service providers used:
Instagram: Social network; service provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; website: https://www.instagram.com; privacy policy: https://instagram.com/about/legal/privacy.
Facebook: Social network; service provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; website: https://www.facebook.com; privacy policy: https://www.facebook.com/about/privacy; objection option (opt-out): settings for advertisements: https://www.facebook.com/settings?tab=ads.
LinkedIn: Social network; service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; website: https://www.linkedin.com; privacy policy: https://www.linkedin.com/legal/privacy-policy; objection option (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Xing: Social network; service provider: XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany; website: https://www.xing.de; privacy policy: https://privacy.xing.com/en/privacy-policy.
