Privacy Policy

Privacy Policy

We are very pleased about your interest in our company. Data protection is of particularly high importance to the management of Sito Apartments. As a rule, the webpages of Sito Apartments can be used without providing any personal data. However, if a data subject wishes to use special services of our company via our website, the processing of personal data may become necessary. If such processing is necessary and there is no legal basis for it, we generally obtain the data subject’s consent.

The processing of personal data—such as the name, address, e-mail address or telephone number of a data subject—is always carried out in accordance with the General Data Protection Regulation (GDPR) and the country-specific data protection provisions applicable to Sito Apartments. By means of this privacy policy, our company wishes to inform the public about the nature, scope and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed of the rights to which they are entitled.

As the controller responsible for processing, Sito Apartments has implemented numerous technical and organisational measures to ensure the most comprehensive possible protection of personal data processed via this website. Nevertheless, internet-based data transmissions may in principle have security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transmit personal data to us by alternative means, for example by telephone.

1. Definitions

The privacy policy of Sito Apartments is based on the terminology used by the European legislator when adopting the General Data Protection Regulation (GDPR). Our privacy policy should be easy to read and understand for both the public and our customers and business partners. To ensure this, we would like to explain the terms used in advance.

In this privacy policy, we use, among others, the following terms:

a) Personal data
Personal data means any information relating to an identified or identifiable natural person (hereinafter referred to as the “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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Data subject
A data subject is any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.

c) Processing
Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing
Restriction of processing means the marking of stored personal data with the aim of limiting their future processing.

e) Profiling
Profiling means any form of automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

f) Pseudonymisation
Pseudonymisation means the processing of personal data in such a manner 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 organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g) Controller or controller responsible for the processing
Controller or controller responsible for the processing 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. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h) Processor
Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i) Recipient
Recipient means a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients.

j) Third party
Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

k) Consent
Consent means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name und Anschrift des für die Verarbeitung Verantwortlichen

Verantwortlicher im Sinne der Datenschutz-Grundverordnung, sonstiger in den Mitgliedstaaten der Europäischen Union geltenden Datenschutzgesetze und anderer Bestimmungen mit datenschutzrechtlichem Charakter ist die:

Sito Apartments

Bielefeldstrasse 1

6433 Oetz

Österreich

Tel.: +43 664 60 11 066

E-Mail: info@sito-oetz.at

Website: /

3. Cookies

The websites of Sito Apartments use cookies. Cookies are text files that are stored on a computer system via an Internet browser.

Many websites and servers use cookies. A large number of cookies contain what is known as a cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie has been stored. This allows visited Internet sites and servers to distinguish the individual browser of a data subject from other Internet browsers that contain other cookies. A specific Internet browser can thus be recognised and identified by means of its unique cookie ID.

By using cookies, Sito Apartments can provide users of this website with more user-friendly services that would not be possible without the use of cookies.

Through the use of cookies, the information and offers on our website can be optimised with the user in mind. Cookies enable us, as already mentioned, to recognise the users of our website. The purpose of this recognition is to make it easier for users to utilise our website. For example, the user of a website that uses cookies does not have to re-enter their login data each time they visit the site, because this is handled by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping basket in an online shop. The online shop remembers the items a customer has placed in the virtual shopping basket through a cookie.

The data subject can at any time prevent the setting of cookies by our website by adjusting the settings of the Internet browser used and can thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all commonly used Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable.

4. Collection of General Data and Information

Each time the website of Sito Apartments is accessed by a data subject or an automated system, the site collects a range of general data and information. This general data and information is stored in the server’s log files. The following data may be collected:
(1) the types and versions of browsers used,
(2) the operating system used by the accessing system,
(3) the website from which an accessing system reaches our website (known as the referrer),
(4) the subpages that are accessed via an accessing system on our website,
(5) the date and time of access to the website,
(6) an Internet Protocol (IP) address,
(7) the Internet service provider of the accessing system, and
(8) other similar data and information that serve to avert danger in the event of attacks on our IT systems.

When using this general data and information, Sito Apartments does not draw any conclusions about the data subject. This information is rather needed to (1) deliver the contents of our website correctly, (2) optimise the contents of our website and the advertising for it, (3) ensure the long-term functionality of our IT systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyberattack. These anonymously collected data and information are therefore evaluated by Sito Apartments both statistically and with the aim of increasing data protection and data security in our company, in order ultimately to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

5. Subscription to Our Newsletter

On the website of Sito Apartments, users are given the opportunity to subscribe to our company’s newsletter. The input mask used for this purpose determines which personal data are transmitted to the controller when the newsletter is ordered.

Sito Apartments informs its customers and business partners at regular intervals by means of a newsletter about offers from the company. In principle, our newsletter can only be received by the data subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the newsletter mailing. For legal reasons, a confirmation e-mail will be sent to the e-mail address first entered by a data subject for newsletter delivery using the double opt-in procedure. This confirmation e-mail serves to verify whether the owner of the e-mail address, as the data subject, has authorised the receipt of the newsletter.

During registration for the newsletter, we also store the IP address assigned by the Internet service provider (ISP) of the computer system used by the data subject at the time of registration, as well as the date and time of registration. The collection of this data is necessary in order to be able to trace any possible misuse of a data subject’s e-mail address at a later date and therefore serves the legal protection of the controller.

The personal data collected as part of a newsletter registration will be used exclusively for sending our newsletter. Furthermore, subscribers to the newsletter may be informed by e-mail if this is necessary for the operation of the newsletter service or a related registration, such as in the case of changes to the newsletter offer or technical circumstances. There will be no disclosure of personal data collected as part of the newsletter service to third parties. Subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data that the data subject has given us for newsletter delivery may be revoked at any time. For the purpose of revoking consent, a corresponding link is provided in each newsletter. Furthermore, it is possible at any time to unsubscribe directly from the newsletter via the website of the controller or to inform the controller of this in another way.

6. Newsletter Tracking

The newsletters of Sito Apartments contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format, to enable log file recording and analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns. Based on the embedded tracking pixel, Sito Apartments can see whether and when an e-mail was opened by a data subject and which links in the e-mail were accessed by the data subject.

Personal data collected via the tracking pixels contained in the newsletters are stored and analysed by the controller in order to optimise the newsletter delivery and to better adapt the content of future newsletters to the interests of the data subject. These personal data are not passed on to third parties. Data subjects are entitled at any time to withdraw the separate consent given via the double opt-in procedure. After a withdrawal, these personal data will be deleted by the controller. Sito Apartments automatically interprets an unsubscription from the newsletter as a withdrawal of consent.

7. Contact via the Website

Due to legal regulations, the website of Sito Apartments contains information that enables a quick electronic contact to our company as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the controller are stored for the purpose of processing or contacting the data subject. There is no disclosure of these personal data to third parties.

8. Routine Erasure and Blocking of Personal Data

The controller processes and stores the personal data of the data subject only for the period necessary to achieve the purpose of storage, or insofar as this is granted by the European legislator or another legislator in laws or regulations to which the controller is subject.

If the storage purpose no longer applies, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or deleted in accordance with legal requirements.

9. Rights of the Data Subject

a) Right to confirmation
Every data subject has the right granted by the European legislator to obtain from the controller confirmation as to whether personal data concerning them are being processed. If a data subject wishes to exercise this right of confirmation, they may contact any employee of the controller at any time.

b) Right of access
Every data subject has the right granted by the European legislator to obtain from the controller, at any time and free of charge, information about the personal data stored concerning them and a copy of this information. Furthermore, the data subject has the right to be informed about:

  • the purposes of the processing,
  • the categories of personal data concerned,
  • the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations,
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period,
  • the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing concerning the data subject or to object to such processing,
  • the right to lodge a complaint with a supervisory authority,
  • where the personal data are not collected from the data subject, any available information as to their source,
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

The data subject also has the right to be informed as to whether personal data are transferred to a third country or an international organisation. Where this is the case, the data subject has the right to be informed of the appropriate safeguards relating to the transfer.
To exercise the right of access, the data subject may contact any employee of the controller at any time.

c) Right to rectification
Every data subject has the right granted by the European legislator to obtain without undue delay the rectification of inaccurate personal data concerning them. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of a supplementary statement.
To exercise the right to rectification, the data subject may contact any employee of the controller at any time.

d) Right to erasure (‘right to be forgotten’)
Every data subject has the right granted by the European legislator to obtain from the controller the erasure of personal data concerning them without undue delay where one of the following grounds applies and insofar as processing is not necessary:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • The data subject withdraws consent on which the processing is based according to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, and there is no other legal ground for the processing.
  • The data subject objects to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR.
  • The personal data have been unlawfully processed.
  • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
  • The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.

Where one of the above grounds applies and a data subject wishes to request the erasure of personal data stored by Sito Apartments, they may contact any employee of the controller at any time. The employee of Sito Apartments will ensure that the request for erasure is complied with without delay.

Where Sito Apartments has made the personal data public and is obliged pursuant to Article 17(1) GDPR to erase the personal data, Sito Apartments, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the published personal data that the data subject has requested the erasure by such controllers of any links to, or copies or replications of, those personal data, insofar as processing is not required. The employee of Sito Apartments will arrange what is necessary in the individual case.

e) Right to restriction of processing
Every data subject has the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead.
  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
  • The data subject has objected to processing pursuant to Article 21(1) GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by Sito Apartments, they may contact any employee of the controller at any time. The employee of Sito Apartments will arrange the restriction of processing.

f) Right to data portability
Every data subject has the right granted by the European legislator to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format. They also have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where the processing is based on consent pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR or on a contract pursuant to Article 6(1)(b) GDPR, and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
In exercising their right to data portability pursuant to Article 20(1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and insofar as this does not adversely affect the rights and freedoms of others.
To assert the right to data portability, the data subject may contact any employee of Sito Apartments at any time.

g) Right to object
Every data subject has the right granted by the European legislator to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them which is based on Article 6(1)(e) or (f) GDPR, including profiling based on those provisions.
Sito Apartments shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or the processing is for the establishment, exercise or defence of legal claims.

Where Sito Apartments processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning them for such marketing; this applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to processing for direct marketing purposes, Sito Apartments will no longer process the personal data for these purposes.

The data subject also has the right, on grounds relating to their particular situation, to object to processing of personal data concerning them for scientific or historical research purposes or statistical purposes pursuant to Article 89(1) GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

To exercise the right to object, the data subject may contact any employee of Sito Apartments directly. The data subject is also free, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise their right to object by automated means using technical specifications.

h) Automated individual decision-making, including profiling
Every data subject has the right granted by the European legislator not to be subject to a decision based solely on automated processing — including profiling — which produces legal effects concerning them or similarly significantly affects them, unless the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a controller; or (2) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or (3) is based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into or the performance of a contract between the data subject and the controller, or (2) is based on the data subject’s explicit consent, Sito Apartments shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view and to contest the decision.
If the data subject wishes to exercise rights concerning automated decision-making, they may contact an employee of the controller at any time.

i) Right to withdraw consent
Every data subject has the right granted by the European legislator to withdraw consent to the processing of personal data at any time.
If the data subject wishes to exercise the right to withdraw consent, they may contact an employee of the controller at any time.

10. Data Protection in Applications and the Application Process

The controller collects and processes the personal data of applicants for the purpose of handling the application procedure. Processing may also take place electronically, in particular if an applicant submits corresponding application documents by electronic means, for example by e-mail or via a web form on the website, to the controller. If the controller concludes an employment contract with an applicant, the data transmitted will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents will be automatically deleted two months after notification of the rejection decision, provided that no other legitimate interests of the controller conflict with such deletion. Another legitimate interest in this sense would be, for example, a duty to provide evidence in proceedings under the German General Equal Treatment Act (AGG).

11. Data Protection Provisions for the Use of Facebook

The controller has integrated components of the company Facebook on this website. Facebook is a social network.
A social network is an internet-based social meeting place, an online community which generally allows users to communicate and interact with each other in virtual space. A social network may serve as a platform for sharing opinions and experiences, or enables the internet community to provide personal or business-related information. Facebook allows users of the social network to create private profiles, upload photos and network via friend requests.

Provider: Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. If the data subject lives outside the USA or Canada, the controller for processing is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Each time one of the individual pages of this website operated by the controller and on which a Facebook component (Facebook plug-in) is integrated is called up, the internet browser on the data subject’s IT system is automatically prompted by the respective Facebook component to download a representation of the corresponding Facebook component from Facebook. A full overview of all Facebook plug-ins can be accessed at https://developers.facebook.com/docs/plugins/?locale=de_DE. In the course of this technical procedure, Facebook gains knowledge of which specific subpage of our website is visited by the data subject.

If the data subject is logged in to Facebook at the same time, Facebook recognises, with each visit to our website and for the entire duration of the respective stay on our website, which specific subpage is visited. This information is collected by the Facebook component and assigned by Facebook to the respective Facebook account of the data subject. If the data subject clicks one of the Facebook buttons integrated on our website, such as the “Like” button, or posts a comment, Facebook assigns this information to the data subject’s personal Facebook account and stores this personal data.

Facebook receives information via the Facebook component that the data subject has visited our website whenever the data subject is logged in to Facebook at the time of calling up our website; this occurs regardless of whether the data subject clicks the Facebook component or not. If such transmission of information to Facebook is not desired by the data subject, the data subject can prevent this by logging out of their Facebook account before accessing our website.

Facebook’s data policy, available at https://de-de.facebook.com/about/privacy/, provides information about the collection, processing and use of personal data by Facebook. It also explains what settings Facebook offers to protect the privacy of the data subject. In addition, various applications are available to suppress data transmission to Facebook. Such applications can be used by the data subject to suppress data transmission to Facebook.

12. Data Protection Provisions for the Use of Google Analytics (with Anonymisation Function)

The controller has integrated the component Google Analytics (with anonymisation function) on this website. Google Analytics is a web analytics service. Web analytics involves the collection, gathering and evaluation of data about the behaviour of visitors to websites (e.g. referrers, subpages accessed, frequency and dwell time). It is primarily used for optimising a website and for cost–benefit analysis of internet advertising.

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

For web analytics via Google Analytics, the controller uses the add-on “_gat._anonymizeIp”. By means of this add-on, the IP address of the data subject’s internet connection is shortened and anonymised by Google when access to our webpages originates in a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is the analysis of visitor flows on our website. Google uses the data and information obtained, inter alia, to evaluate the use of our website, to compile online reports on website activity for us and to provide other services relating to the use of our website.

Google Analytics sets a cookie on the data subject’s IT system. With the setting of the cookie, Google is enabled to analyse the use of our website. Each time one of the individual pages of this website, which is operated by the controller and on which a Google Analytics component has been integrated, is called up, the internet browser on the data subject’s IT system is automatically prompted by the respective Google Analytics component to transmit data to Google for the purpose of online analysis. In the course of this technical procedure, Google obtains knowledge of personal data, such as the IP address of the data subject, which enables Google, inter alia, to trace the origin of visitors and clicks and subsequently to facilitate commission settlements.

By means of the cookie, personal information such as the time of access, the location from which access originated and the frequency of visits to our website by the data subject is stored. With each visit to our webpages, these personal data, including the IP address of the internet connection used by the data subject, are transmitted to Google in the United States of America and stored there. Google may pass these personal data collected via the technical procedure to third parties.

The data subject may, as stated above, prevent the setting of cookies by our website at any time by adjusting the settings of the internet browser used and thus permanently object to the setting of cookies. Such a setting would also prevent Google from setting a cookie on the data subject’s IT system. In addition, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the possibility of objecting to and preventing the collection of data generated by Google Analytics relating to the use of this website and the processing of these data by Google. To do this, the data subject must download and install a browser add-on under the link https://tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics via JavaScript that no data and information about visits to web pages may be transmitted to Google Analytics. The installation of the browser add-on is considered an objection by Google. If the data subject’s IT system is deleted, formatted or reinstalled at a later date, the data subject must reinstall the browser add-on to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the data subject or another person within their sphere of control, it is possible to reinstall or reactivate the browser add-on.

Further information and the applicable privacy provisions of Google may be retrieved at https://www.google.de/intl/de/policies/privacy/ and http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail at https://www.google.com/intl/de_de/analytics/.

13. Data Protection Provisions for the Use of Google Remarketing

The controller has integrated Google Remarketing services on this website. Google Remarketing is a function of Google Ads which enables a company to show advertising to internet users who have previously stayed on the company’s website. The integration of Google Remarketing therefore allows a company to create user-based advertising and to display interest-relevant advertisements to the internet user.

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The purpose of Google Remarketing is to display interest-relevant advertising. Google Remarketing allows us to display advertisements via the Google advertising network or to have them displayed on other websites tailored to the individual needs and interests of internet users.

Google Remarketing sets a cookie on the data subject’s IT system. With the setting of the cookie, Google is enabled to recognise the visitor to our website when they subsequently call up websites that are also members of the Google advertising network. With each call-up to a website on which Google Remarketing is integrated, the data subject’s internet browser automatically identifies itself to Google. In the course of this technical procedure, Google receives knowledge of personal data, such as the IP address or the user’s surfing behaviour, which Google uses, inter alia, to display interest-relevant advertising.

By means of the cookie, personal information — for example the websites visited by the data subject — is stored. Each time our webpages are visited, personal data, including the IP address of the internet connection used by the data subject, are therefore transmitted to Google in the United States of America and stored there. Google may pass these personal data collected via the technical procedure to third parties.

The data subject may prevent the setting of cookies by our website at any time, as already described, by means of an appropriate setting of the internet browser used and thus permanently object to the setting of cookies. Such a setting would also prevent Google from setting a cookie on the data subject’s IT system. In addition, a cookie already set by Google Analytics can be deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the possibility of objecting to interest-based advertising by Google. For this purpose, the data subject must call up the link www.google.de/settings/ads from each of the internet browsers they use and make the desired settings there.

Further information and the applicable privacy provisions of Google may be retrieved at https://www.google.de/intl/de/policies/privacy/.

14. Data Protection Provisions for the Use of Google Ads

The controller has integrated Google Ads on this website. Google Ads is an online advertising service that allows advertisers to place advertisements in Google’s search engine results and in the Google advertising network. Google Ads allows an advertiser to predefine specific keywords by means of which an advertisement will be displayed in Google’s search results only when the user retrieves a keyword-relevant search result. In the Google advertising network, the advertisements are distributed on topic-relevant websites using an automatic algorithm and subject to the previously defined keywords.

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

The purpose of Google Ads is to promote our website by displaying interest-relevant advertising on third-party websites and in Google’s search engine results, and to display third-party advertising on our website.

If a data subject arrives on our website via a Google advertisement, a so-called conversion cookie is placed on the data subject’s IT system by Google. A conversion cookie loses its validity after thirty days and is not used to identify the data subject. As long as the cookie has not expired, the conversion cookie is used to track whether certain subpages — for example the shopping basket of an online shop system — have been accessed on our website. The conversion cookie enables both us and Google to track whether a data subject who arrived on our website via an Ads advertisement generated a sale, i.e. completed or cancelled a purchase.

The data and information collected through the use of the conversion cookie are used by Google to compile visit statistics for our website. We then use these visit statistics to determine the total number of users who were referred to us via Ads advertisements, i.e. to determine the success or failure of the respective Ads advertisement and to optimise our Ads advertisements for the future. Neither our company nor other Google Ads advertisers receive information from Google that could identify the data subject.

By means of the conversion cookie, personal information, such as the websites visited by the data subject, is stored. Each time our webpages are visited, personal data, including the IP address of the internet connection used by the data subject, are therefore transmitted to Google in the United States of America and stored there. Google may pass these personal data collected via the technical procedure to third parties.

The data subject may prevent the setting of cookies by our website at any time, as already described, by means of an appropriate setting of the internet browser used and thus permanently object to the setting of cookies. Such a setting would also prevent Google from setting a conversion cookie on the data subject’s IT system. In addition, a cookie already set by Google Ads can be deleted at any time via the internet browser or other software programs.

Furthermore, the data subject has the possibility of objecting to interest-based advertising by Google. For this purpose, the data subject must call up the link www.google.de/settings/ads from each of the internet browsers they use and make the desired settings there.

Further information and the applicable privacy provisions of Google may be retrieved at https://www.google.de/intl/de/policies/privacy/.

15. Data Protection Provisions for the Use of Instagram

The controller has integrated components of the Instagram service on this website. Instagram is a service to be classified as an audiovisual platform that enables users to share photos and videos and also to distribute such data on other social networks.

Provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

Each time one of the individual pages of this website operated by the controller and on which an Instagram component (Insta button) is integrated is called up, the internet browser on the data subject’s IT system is automatically prompted by the respective Instagram component to download a representation of the corresponding component from Instagram. In the course of this technical procedure, Instagram gains knowledge of which specific subpage of our website is visited by the data subject.

If the data subject is logged in to Instagram at the same time, Instagram recognises, with each visit to our website and for the entire duration of the respective stay on our website, which specific subpage is visited. This information is collected by the Instagram component and assigned by Instagram to the respective Instagram account of the data subject. If the data subject clicks one of the Instagram buttons integrated on our website, the data and information thus transmitted are assigned to the data subject’s personal Instagram user account and stored and processed by Instagram.

Instagram receives information via the Instagram component that the data subject has visited our website whenever the data subject is logged in to Instagram at the time of calling up our website; this occurs regardless of whether the data subject clicks the Instagram component or not. If such transmission of information to Instagram is not desired by the data subject, they can prevent this by logging out of their Instagram account before accessing our website.

Further information and the applicable privacy provisions of Instagram may be retrieved at https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/.

16. Data Protection Provisions for the Use of Pinterest

The controller has integrated components of Pinterest Inc. on this website. Pinterest is a social network. A social network is an Internet-based social meeting place, an online community that generally enables users to communicate with one another and interact in virtual space. A social network can serve as a platform for sharing opinions and experiences or enables the Internet community to provide personal or company-related information. Among other things, Pinterest allows users of the social network to publish collections of images, individual images and descriptions on virtual pinboards (“pinning”), which can in turn be shared (“repinning”) or commented on by other users.

The operating company of Pinterest is Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland.

Each time one of the individual pages of this website operated by the controller and on which a Pinterest component (Pinterest plug-in) is integrated is called up, the Internet browser on the data subject’s IT system is automatically prompted by the respective Pinterest component to download a representation of the corresponding Pinterest component from Pinterest. More information about Pinterest can be found at https://pinterest.com/. In the course of this technical procedure, Pinterest gains knowledge of which specific subpage of our website is visited by the data subject.

If the data subject is logged in to Pinterest at the same time, Pinterest recognises, with each visit to our website by the data subject and for the entire duration of the respective stay, which specific subpage of our website the data subject visits. This information is collected by the Pinterest component and assigned by Pinterest to the respective Pinterest account of the data subject. If the data subject clicks one of the Pinterest buttons integrated on our website, Pinterest assigns this information to the data subject’s personal Pinterest user account and stores this personal data.

Pinterest receives information via the Pinterest component that the data subject has visited our website whenever the data subject is logged in to Pinterest at the time of calling up our website; this occurs regardless of whether the data subject clicks the Pinterest component or not. If such transmission of information to Pinterest is not desired by the data subject, this can be prevented by logging out of their Pinterest account before accessing our website.

The privacy policy published by Pinterest, available at https://about.pinterest.com/privacy-policy, provides information about the collection, processing and use of personal data by Pinterest.

17. Data Protection Provisions for the Use of Matomo

The controller has integrated the Matomo component on this website. Matomo is an open-source software tool for web analytics. Web analytics is the collection, gathering and evaluation of data on the behaviour of visitors to websites. A web analytics tool, inter alia, collects data on the website from which a data subject came to a website (the so-called referrer), which subpages were accessed or how often and for what dwell time a subpage was viewed. Web analytics is primarily used for optimising a website and for cost–benefit analysis of Internet advertising.

The software is operated on the controller’s server; the data-protection-sensitive log files are stored exclusively on this server.

The purpose of the Matomo component is the analysis of visitor flows on our website. The controller uses the data and information obtained, inter alia, to evaluate the use of this website in order to compile online reports showing the activities on our websites.

Matomo sets a cookie on the data subject’s IT system. What cookies are has already been explained above. By setting the cookie, an analysis of the use of our website is enabled. With each call-up to one of the individual pages of this website, the Internet browser on the data subject’s IT system is automatically prompted by the Matomo component to transmit data to our server for the purpose of online analysis. In the course of this technical procedure, we obtain knowledge of personal data, such as the data subject’s IP address, which serves us, inter alia, to trace the origin of visitors and clicks.

By means of the cookie, personal information — for example the time of access, the location from which access originated and the frequency of visits to our website — is stored. With each visit to our webpages, these personal data, including the IP address of the Internet connection used by the data subject, are transmitted to our server and stored by us. We do not pass these personal data to third parties.

The data subject may, as stated above, prevent the setting of cookies by our website at any time by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Such a setting would also prevent Matomo from setting a cookie on the data subject’s IT system. In addition, a cookie already set by Matomo can be deleted at any time via the Internet browser or other software programs.

Furthermore, the data subject has the possibility of objecting to and preventing the collection of data generated by Matomo relating to the use of this website. To do this, the data subject must activate “Do Not Track” in their browser.

However, by setting the opt-out cookie, it may no longer be possible to use all functions of the controller’s websites in full.

Further information and the applicable data protection provisions of Matomo may be retrieved at https://matomo.org/privacy/.

18. Data Protection Provisions for the Use of Twitter

The controller has integrated components of Twitter on this website. Twitter is a multilingual, publicly accessible microblogging service on which users may publish and disseminate so-called tweets — short messages limited to 280 characters. These short messages are available to everyone, including people not registered with Twitter. The tweets are also displayed to the so-called followers of the respective user — other Twitter users who follow a user’s tweets. Twitter also enables the addressing of a wide audience via hashtags, links or retweets.

Provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland.

Each time one of the individual pages of this website operated by the controller and on which a Twitter component (Twitter button) is integrated is called up, the Internet browser on the data subject’s IT system is automatically prompted by the respective Twitter component to download a representation of the corresponding Twitter component from Twitter. Further information about the Twitter buttons can be accessed at https://about.twitter.com/de/resources/buttons. In the course of this technical procedure, Twitter gains knowledge of which specific subpage of our website is visited by the data subject. The purpose of integrating the Twitter component is to enable our users to share the content of this website, to make this website known in the digital world and to increase our visitor numbers.

If the data subject is logged in to Twitter at the same time, Twitter recognises, with each visit to our website by the data subject and for the entire duration of the respective stay, which specific subpage of our website the data subject visits. This information is collected by the Twitter component and assigned by Twitter to the respective Twitter account of the data subject. If the data subject clicks one of the Twitter buttons integrated on our website, the data and information thus transmitted are assigned to the data subject’s personal Twitter user account and stored and processed by Twitter.

Twitter receives information via the Twitter component that the data subject has visited our website whenever the data subject is logged in to Twitter at the time of calling up our website; this occurs regardless of whether the data subject clicks the Twitter component or not. If such transmission of information to Twitter is not desired by the data subject, this can be prevented by logging out of their Twitter account before accessing our website.

The applicable data protection provisions of Twitter can be retrieved at https://twitter.com/privacy?lang=de.

19. Data Protection Provisions for the Use of YouTube

The controller has integrated components of YouTube on this website. YouTube is an Internet video portal that enables video publishers to upload video clips free of charge and other users to view, rate and comment on them, also free of charge. YouTube permits the publication of all kinds of videos, so that complete films and TV programmes, as well as music videos, trailers or videos made by users themselves, can be viewed via the Internet portal.

Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.

Each time one of the individual pages of this website operated by the controller and on which a YouTube component (YouTube video) is integrated is called up, the Internet browser on the data subject’s IT system is automatically prompted by the respective YouTube component to download a representation of the corresponding YouTube component from YouTube. Further information about YouTube can be retrieved at https://www.youtube.com/yt/about/de/. In the course of this technical procedure, YouTube and Google gain knowledge of which specific subpage of our website is visited by the data subject.

If the data subject is logged in to YouTube at the same time, YouTube recognises, with the call-up of a subpage containing a YouTube video, which specific subpage of our website the data subject visits. This information is collected by YouTube and Google and assigned to the respective YouTube account of the data subject.

YouTube and Google receive information via the YouTube component that the data subject has visited our website whenever the data subject is logged in to YouTube at the time of calling up our website; this occurs regardless of whether the data subject clicks a YouTube video or not. If such transmission of information to YouTube and Google is not desired by the data subject, this can be prevented by logging out of their YouTube account before accessing our website.

The data protection provisions published by YouTube, which are available at https://www.google.de/intl/de/policies/privacy/, provide information about the collection, processing and use of personal data by YouTube and Google.

20. Legal Basis for Processing

Article 6(1)(a) GDPR serves our company as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party — as is the case, for example, with processing operations necessary for the supply of goods or the provision of any other service or consideration — the processing is based on Article 6(1)(b) GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of enquiries about our products or services. If our company is subject to a legal obligation by which processing of personal data is required — such as for the fulfilment of tax obligations — the processing is based on Article 6(1)(c) GDPR. In rare cases, the processing of personal data may be necessary in order to protect the vital interests of the data subject or of another natural person — for example, if a visitor were injured on our premises and their name, age, health insurance data or other vital information had to be passed on to a doctor, hospital or other third party. Then the processing would be based on Article 6(1)(d) GDPR. Finally, processing operations could be based on Article 6(1)(f) GDPR. This legal basis is used for processing operations which are not covered by any of the aforementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, provided that such interests are not overridden by the interests or fundamental rights and freedoms of the data subject. Such processing operations are particularly permitted because they have been specifically mentioned by the European legislator. In this respect, the legislator considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47, sentence 2 GDPR).

21. Legitimate Interests Pursued by the Controller or by a Third Party

Where the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is the conduct of our business for the well-being of all our employees and our shareholders.

22. Period for Which the Personal Data Will Be Stored

The criterion used to determine the period of storage of personal data is the respective statutory retention period. After expiry of that period, the corresponding data are routinely deleted, provided they are no longer necessary for the performance of a contract or the initiation of a contract.

23. Statutory or Contractual Requirements to Provide Personal Data; Necessity for Contract Conclusion; Obligation of the Data Subject to Provide Personal Data; Possible Consequences of Failure to Provide

We inform you that the provision of personal data is partly required by law (e.g. tax regulations) or may also result from contractual provisions (e.g. details of the contracting party). Sometimes it may be necessary for the conclusion of a contract that a data subject provides us with personal data which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company concludes a contract with them. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before personal data are provided by the data subject, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether the provision of personal data is required by law or contract, or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and the consequences of not providing the personal data.

24. Existence of Automated Decision-Making

As a responsible company, we do not use automatic decision-making or profiling.

This privacy policy was created using the Privacy Policy Generator of DGD Deutsche Gesellschaft für Datenschutz GmbH, which acts as External Data Protection Officer in Memmingen, in cooperation with the lawyer for data protection law Christian Solmecke.