Privacy policy
Introduction
With the following data protection declaration we would like to inform you about the types of personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent. The data protection declaration 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 also referred to collectively as "online offer").
The terms used are not gender-specific.
Status: July 22, 2020
Table of contents
Introduction
Responsible
Overview of the processing operations
Relevant legal bases
Security measures
Transmission and disclosure of personal data
Data processing in third countries
Use of cookies
Commercial and business services
Provision of the online offer and web hosting
Contact
online marketing
deletion of data
Amendment and update of the privacy policy
Rights of data subjects
Definitions of terms
Responsible
Dr. Rüdiger Christoph Sura,
Park 4,
10785 Berlin
Germany
Authorized representatives: Dr. Rüdiger Christoph Sura
E-mail address: office@rcsura.com
Imprint: rcsura.com/imprint
Overview of the processing operations
The following table summarises the types of data processed and the purposes of their processing, and refers to the data subjects.
Types of data processed
inventory data (e.g. names, addresses).
Content data (e.g. text entries, photographs, videos).
Contact data (e.g. e-mail, telephone numbers).
Meta/communication data (e.g. device information, IP addresses).
Usage data (e.g. websites visited, interest in content, access times).
Contract data (e.g. subject matter of contract, duration, customer category).
Payment data (e.g. bank details, invoices, payment history).
Categories of affected persons
Business and contractual partners.
Interested parties.
communication partners.
customers.
Users (e.g. website visitors, users of online services).
Purposes of processing
Visit action evaluation.
Office and organizational procedures.
Interest based and behavioral marketing.
Contact requests and communication.
Conversion measurement (measuring the effectiveness of marketing measures).
Profiling (creation of user profiles).
remarketing.
Reach measurement (e.g. access statistics, recognition of returning visitors).
Tracking (e.g. interest/behavioural profiling, use of cookies).
Contractual performance and service.
Administration and answering of inquiries.
Applicable legal basis
In the following, we provide the legal basis of the basic data protection regulation (DSGVO), on the basis of which we process personal data. Please note that in addition to the regulations of the DSGVO, national data protection regulations may apply in your or our country of residence and domicile. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.
Consent (Art. 6 para. 1 sentence 1 letter a DSGVO) - The data subject has given his or her consent to the processing of personal data relating to him or her for one or more specific purposes.
Fulfilment of a contract and pre-contractual requests (Art. 6 para. 1 sentence 1 letter b. FADP) - Processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject.
Legal obligation (Art. 6 para. 1 sentence 1 letter c. FADP) - The processing is necessary for the performance of a legal obligation to which the controller is subject.
Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. FADP) - The processing is necessary to safeguard the legitimate interests of the controller or of a third party, unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data outweigh these.
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National data protection regulations in Germany: In addition to the data protection regulations of the basic data protection regulation, national regulations on data protection apply in Germany. These include in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to deletion, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision making in individual cases including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (Section 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 implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection commensurate with the risk.
Such measures shall include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, safeguarding of availability and segregation of data relating to them. Furthermore, we have established procedures to ensure that data subjects' rights are exercised, data is deleted, and responses are made to any threats to the data. 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, by designing technology and by using data protection-friendly default settings.
SSL encryption (https): To protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.
Transmission and disclosure of personal data
In the course of our processing of personal data, it may happen that the data is transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. The 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 observe the legal requirements and in particular conclude appropriate contracts or agreements with the recipients of your data which serve to protect 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 the use of services of third parties or the disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements.
Subject to express consent or transmission required by contract or by law, we will only process the data or have it processed in third countries with a recognised level of data protection, a 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 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).
Use of cookies
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 is primarily used to store information about a user during or after his visit within an online offer. The stored information may include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was viewed. The term "cookies" also includes other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also referred to as "user IDs")
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The following cookie types and functions are distinguished:
Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users used for reach measurement or marketing purposes can also be stored in such a cookie.
First-party cookies: First-party cookies are set by us.
Third party cookies (also: third party cookies): Third party cookies are mainly used by advertisers (so-called third parties) to process user information.
Necessary (also: essential or absolutely necessary) cookies: Cookies can be absolutely necessary for the operation of a website (e.g. to store logins or other user entries or for security reasons).
Statistical, marketing and personalization cookies: Furthermore, cookies are generally also used in the context of range measurement and when the interests of a user or his behavior (e.g. viewing certain content, using functions, etc.) are stored in a user profile on individual web pages. Such profiles are used to show users e.g. content that corresponds to their potential interests. This procedure is also known as "tracking", i.e. following the potential interests of users. . If we use cookies or "tracking" technologies, we will inform you separately in our privacy policy or when you give your consent.
Information on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for your consent. If this is the case 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 aid of cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfil our contractual obligations.
Duration of storage: Unless we provide you with explicit information on the duration of storage of permanent cookies (e.g. within the framework of a so-called cookie opt-in), please assume that the storage period can be up to two years.
General notes on revocation and objection (opt-out): Depending on whether processing is based on consent or legal permission, you have the option at any time to revoke any 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 service). 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 notices of objection in the context of the information on the service providers and cookies used.
Processing of cookie data based on consent: Before we process or have processed data in the context of the use of cookies, we ask users for their consent, which can be revoked at any time. Before consent has not been given, we will only use cookies that are absolutely necessary for the operation of our online service.
Processed types of data: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Affected persons: Users (e.g. website visitors, users of online services).
Legal basis: Consent (Art. 6 para. 1 sentence 1 letter a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 letter f. DSGVO).
Commercial and business services
We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as "contractual partners") within the scope of contractual and comparable legal relationships as well as associated measures and within the scope of communication with the contractual partners (or pre-contractual), e.g. to answer inquiries.
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We process these data in order to fulfil our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with these data and for the purposes of the business organisation. Within the framework of the applicable law, we only pass on the data of the contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations or with the consent of the persons concerned (e.g. to participating telecommunication, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.
We will inform the contractual partners which data is required for the above-mentioned purposes before or within the scope of data collection, e.g. in online forms, by means of special marking (e.g. colours) or symbols (e.g. asterisks or similar), or personally.
We delete the data after expiry of legal warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be kept for legal archiving reasons (e.g., for tax purposes usually 10 years). We will delete data that has been disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, generally after the end of the order.
If we use third-party providers or platforms to provide our services, the terms and conditions and data protection information of the respective third-party providers or platforms apply in the relationship between the users and the providers.
Economic analyses and market research: For economic reasons and in order to be able to identify market trends, wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., whereby contractual partners, interested parties, customers, visitors and users of our online offer may fall into the group of persons concerned.
The analyses are carried out for the purpose of business management evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we can, if available, take into account the profiles of registered users including their details, e.g. on services used. The analyses serve solely to serve us and are not disclosed externally, unless they are anonymous analyses with summarised, i.e. anonymised, values. Furthermore, we respect the privacy of the users and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarized data).
Further information on commercial services: We process the data of our customers as well as clients (hereinafter uniformly referred to as "customers") in order to enable them to select, acquire or commission the selected services or works as well as related activities, as well as to pay for and deliver or execute or provide them.
The required information is identified as such in the context of the conclusion of an order, contract or comparable contract and includes the information required for the provision of services and invoicing as well as contact information in order to be able to make any necessary arrangements.
Processed data types: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Affected persons: Interested parties, business and contractual partners, customers.
Purposes of processing: Contractual services and performances, contact requests and communication, office and organisational procedures, administration and answering of requests, visit evaluation, interest based and behaviour related marketing, profiling (creation of user profiles).
Legal bases: Fulfilment of contract and pre-contractual enquiries (Art. 6 Paragraph 1 S. 1 lit. b. DSGVO), Legal obligation (Art. 6 Paragraph 1 S. 1 lit. c. DSGVO), Legitimate interests (Art. 6 Paragraph 1 S. 1 lit. f. DSGVO).
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Provision of the online offer and web hosting
In order to provide our online services securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online services can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, and security and technical maintenance services.
The data processed within the framework of the provision of the hosting offer may include all data relating to the users of our online offer, which are generated within the framework of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer 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 web pages and files accessed, 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, as a rule, IP addresses and the requesting provider.
The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the capacity utilisation of the servers and their stability.
Processed data types: Content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Affected persons: Users (e.g. website visitors, users of online services).
Purposes of processing: Contractual services and service.
Legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Used services and service providers:
Wix: hosting platform for websites; service provider: Wix.com ltd., Tel Aviv, 500 Terry A. Francois Boulevard, San Francisco, California 94158, USA; website: https://www.wix.com; privacy policy: https://de.wix.com/about/privacy.
Contact
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the data of the inquiring persons will be processed to the extent necessary to answer the contact inquiries and any requested measures.
The answering of contact inquiries within the scope of contractual or pre-contractual relations is carried out in order to fulfil our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interest in answering the inquiries.
Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos).
Persons concerned: communication partners.
Purposes of processing: contact requests and communication.
Legal basis: Fulfilment of contract and pre-contractual enquiries (Art. 6 Paragraph 1 S. 1 lit. b. DSGVO), legitimate interests (Art. 6 Paragraph 1 S. 1 lit. f. DSGVO).
Online marketing
We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as "Content") based on the potential interests of users and the measurement of its 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 user data relevant to the presentation of the aforementioned contents are stored. This information may include, for example, the content viewed, websites visited, online networks used, but also communication partners and technical details 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, this data may also be processed.
The IP addresses of users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect the users. In general, no clear user data (such as e-mail 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 procedures do not know the actual identity of the users, but only the information stored in their profiles.
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The information in the profiles is usually stored in the cookies or by similar methods. These cookies can later generally also be read out on other websites that use the same online marketing procedure, analysed for the purpose of presenting content and supplemented with additional data and stored on the server of the online marketing procedure provider.
As an exception, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing procedure we use and the network links the user profiles with the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.
As a matter of principle, we only obtain access to summarised information on the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyse 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 users for their consent to use third party providers, the legal basis for processing data is 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 draw your attention to the information on the use of cookies in this privacy policy.
Processed types of data: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Affected persons: Users (e.g. website visitors, users of online services), interested parties.
Purposes of processing: Tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, visitor action evaluation, interest/behavioural marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors).
Security measures: IP-Masking (pseudonymization of the IP address).
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Possibility of objection (opt-out): We refer to the data protection information of the respective providers and the possibilities of objection stated for the providers (so-called "opt-out"). If no explicit opt-out option has been specified, it is possible to switch off cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary form 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.
Used services and service providers:
Google Analytics: online marketing and web analytics; 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/de/about/analytics/; Privacy Policy: https://policies.google.com/privacy; Opt-Out: Opt-Out Plugin: https://tools.google.com/dlpage/gaoptout?hl=de, Ad Display Settings: https://adssettings.google.com/authenticated.
Deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as their consent permitted for processing is revoked or other permissions cease to apply (e.g. if the purpose for which the data were processed ceases to apply or if they are not necessary for the purpose).
Unless the data are deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that 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 or that must be stored for the purpose of asserting, exercising or defending legal claims or protecting the rights of another natural or legal person.
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Further information on the deletion of personal data can also be found in the individual data protection notes of this privacy policy.
Amendment and update of the data protection declaration
We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes make it necessary for you to take action to cooperate (e.g. to give your consent) or to receive other individual notification.
If we provide addresses and contact information of companies and organisations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.
Rights of the persons concerned
As a data subject, you are entitled to various rights under the DSGVO, which result in particular from Art. 15 to 21 DSGVO:
Right of objection: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data relating to you which is carried out on the basis of Art. 6 paragraph 1 letter e or f FADP; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing, including profiling, insofar as it is linked to such direct marketing.
Right to withdraw consent: You have the right to withdraw any consent given at any time.
Right of access: You have the right to obtain confirmation as to whether or not data in question is being processed and to obtain information about such data and to receive further information and a copy of the data in accordance with the law.
Right of rectification: You have the right to ask for the completion of the data concerning you or the rectification of incorrect data concerning you, in accordance with the law.
Right to erasure and limitation of processing: You have the right to request that data concerning you be erased immediately in accordance with the law or, alternatively, that the processing of such data be limited in accordance with the law.
Right to data transferability: You have the right to obtain, in accordance with the law, data concerning you that you have provided to us in a structured, common and machine-readable format or to request that it be transferred to another responsible party.
Complaints to the supervisory authority: You also have the right, in accordance with the statutory provisions, to lodge a complaint with a supervisory authority, in particular in the Member State in which you have your habitual residence, your place of work or the place where the alleged infringement occurred, if you believe that the processing of personal data relating to you is in breach of the DPA.
Definitions of terms
This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined above all in Art. 4 DSGVO. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.
Conversion tracking: "Conversion tracking" refers to a procedure that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user's devices within the websites on which the marketing measures are carried out and then retrieved again on the target website. For example, we can use this to track whether the ads we have placed on other websites have been successful).
IP-Masking: "IP-Masking" is a method in which the last octet, i.e. the last two numbers of an IP address, are deleted so that the IP address can no longer be used to uniquely identify a person. IP masking is therefore a means of pseudonymising processing methods, especially in online marketing
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Interest-based and behavioral marketing: We speak of interest-based and/or behavioral marketing when the potential interests of users in ads and other content are predetermined as precisely as possible. This is done on the basis of information about their previous behaviour (e.g. visiting and staying on certain websites, buying behaviour or interaction with other users), which is stored in a so-called profile. As a rule, cookies are used for these purposes.
Conversion measurement: Conversion measurement is a method by which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users' devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this enables us to track whether the ads we have placed on other websites have been successful.
Personal data: "Personal data" shall mean any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); an identifiable 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. a cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Profiling: "Profiling" is any automated processing of personal data which consists of using personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information about age, gender, location and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behaviour or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, identify at what time visitors visit their website and what content they are interested in. This enables them to better adapt the contents of the website to the needs of their visitors. Pseudonymous cookies and web beacons are often used for the purpose of range analysis in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offering.
Remarketing: One speaks of "remarketing" or "retargeting", for example, when it is noted for advertising purposes in which products a user on a website was interested, in order to remind the user on other websites of these products, e.g. in advertisements.
Tracking: We speak of "tracking" when the behaviour of users can be traced across several online offers. As a rule, behavioral and interest information regarding the online offers used is stored in cookies or on servers of the providers of the tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
Person responsible: The term "person responsible" refers to the natural or legal person, public authority, institution or other body which, alone or jointly with others, decides on the purposes and means of processing personal data.
Processing: "processing" shall mean any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually all processing of data, whether it be collection, analysis, storage, communication or deletion.
Created with free data protection generator.de by Dr. Thomas Schwenke
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