Data Privacy Policy

1 General Information

 

1.1 Objective and Responsibility

1. This Data Privacy Statement is to inform you about the nature, scope and purpose of the processing of personal data related to our online service and the related websites, features and contents (hereinafter collectively referred to as ‘online service’ or ‘website’).
2. Details on data processing for the purpose of carrying out our business processes are described in section 3.
3. The online service is provided by Breidenbacher Hof (WPHG Düsseldorf Operating GmbH, Königsallee 11, D-40212 Düsseldorf, Germany) - hereinafter referred to as ‘provider’, ‘we’ or ‘us’ - who is also legally responsible under the data protection law.
4. Our online service is provided by der ALL-INKL.COM (Hauptstraße 68, D-02742 Friedersdorf).
5. You can reach out to our Data Protection Officer Sven Meyzis - IT.DS Beratung under the E-Mail address S.Meyzis@ITDSB.de and telephone 0049 40-21091514.
6. The term ‘user’ encompasses all customers, interested people, employees and visitors of our online service.

 

1.2 Legal Bases

We collect and process personal data based on the following legal grounds:
a. Consent in accordance with article 6 paragraph 1 lit. a General Data Protection Regulation (GDPR). Consent meaning any freely given, specific, informed and unambiguous indication of agreement, which could be in the form of a statement or any other unambiguous confirmatory act, given by the data’s subject consenting to the processing of personal data relating to him or her.
b. Necessity for the performance of a contract or in order to take steps prior to entering into a contract according to article 6 paragraph 1 lit. b GDPR, meaning the data is required in order for us to fulfil our contractual obligations towards you or to prepare the conclusion of a contract with you.
c. Processing to fulfil a legal obligation in accordance with article 6 paragraph 1 lit. c GDPR, meaning that e.g. the processing of data is required by law or other provisions.
d. Processing in order to protect legitimate interests in accordance with article 6 paragraph 1 lit. f GDPR, meaning that the processing is necessary to protect legitimate interests pursued by us or by a third party, unless such interests are overridden by your interests or fundamental rights and freedoms which require the protection of personal data.

 

1.3 Data Subject Rights

You have the following rights with regards to the processing of your data through us:
a. The right to lodge a complaint with a supervisory authority in accordance with article 13 paragraph 2 lit. d GDPR and article 14 paragraph 2 lit. e GDPR.
b. Right of access in accordance with article 15 GDPR
c. Right to rectification in accordance with article 16 GDPR
d. Right to erasure (‘right to be forgotten’) in accordance with article 17 GDPR
e. Right to restriction of processing in accordance with article 18 GDPR
f. Right to data portability in accordance with article 20 GDPR
g. Right to objection in accordance with article 21 GDPR
Notice: Users may object to the processing of their personal data in accordance with legal allowances at any time with effect for the future. The objection may in particular be made against processing for the purposes of direct marketing.
Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your place of residence, employment or the place of the alleged infringement, if you believe that the processing of your personal data violates the GDPR.

 

1.4 Data Erasure and Duration of Storage

The personal data of the data subject will be erased or blocked as soon as the purpose of the storage is inapplicable. Storage of data beyond that may occur if such storage is required by the European or national legislator in EU regulations, laws or other regulations to which the controller is subject. Blocking or erasure of data also takes place when a retention period mandated by the standards mentioned expires, unless the continued storage of data is required for the conclusion of a contract or the fulfilment of contractual obligations.

 

1.5 Security of Processing

1. We have implemented appropriate and state-of-the-art technical and organisational security measures (TOMs). Thus, the data that is processed by us is protected against accidental or intentional manipulation, loss, destruction and unauthorized access.
2. These security measures include in particular the encrypted transfer of data between your browser and our server.

 

1.6 Transfer of Data to Third Parties, Subcontractors and Third Party Providers

1. A transfer of personal data to third parties only occurs within the framework of legal requirements. We only disclose personal data of users to third parties, if this is required e.g. for billing purposes or other purposes, if the disclosure is necessary to ensure the fulfilment of contractual obligations towards the users.
2. If we engage subcontractors for our online service, we have made appropriate contractual arrangements as well as adequate technical and organizational measures with these companies.
3. If we use content, tools or other means from other companies (hereinafter collectively referred to as ‘third party providers’) whose registered offices are located in a third country, it is assumed that a transfer of data to the home countries of these third party providers occurs. The transfer of personal data to third countries takes place exclusively only, if an adequate level of data protection, the user’s consent or another legal permission is present.

 

2 Processing in the context of our online services

 

2.1 Collection of Information on the Use of the Online Service

1. When using our online service no personal or personally identifiable data is collected and stored in log files.

 

2.2 Contact Form and Contacting via E-Mail

1. When contacting us (via online form or e-mail), the data provided by the user will be processed exclusively for processing the inquiry and its handling.
2. Any other use of the data will only take place based on the given consent from the user.
3. The user data from the website forms are stored in our content management system (Contao) The statutory retention periods for business letters apply.

 

2.3 DoubleClick

1. Doubleclick by Google is a service of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google").
2. Doubleclick by Google uses cookies to present you with advertisements that are relevant to you. A pseudonymous identification number (ID) is assigned to your browser in order to check which ads have been displayed in your browser and which ads have been viewed. The cookies do not contain any personal information. The use of DoubleClick cookies only enables Google and its partner websites to display ads based on previous visits to our or other websites on the Internet. The information generated by the cookies is transmitted by Google to a server in the USA for analysis and stored there. Under no circumstances will Google combine your data with other data collected by Google.
3. You can find more information about DoubleClick by Google and data protection here: https://policies.google.com/technologies/ads?hl=de
4. The legal basis for the use of DoubleClick is your consent in accordance with Article 6 (1) (a) GDPR. You consent to the processing of the data collected about you by Google in the manner described above and for the stated purpose.

 

2.4 Google Analytics
1. We use "Google Analytics" on our website, a web analytics service provided by Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland (hereinafter referred to as "Google"). Google uses cookies, i.e. small text files that are stored on your terminal device and enable an analysis of your use of our website. The information generated by the cookie about the use of our website is usually transmitted to a Google server and stored there. If anonymisation of the IP address to be transmitted by the cookie is activated on the website ("IP anonymisation"), your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server outside the EU and shortened there. Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity and providing other services relating to website activity and internet usage. In doing so, pseudonymous usage profiles can be created from the processed data. The IP address transmitted when using Google Analytics will not be merged with other Google data.
2. We only use Google Analytics with the activated IP anonymisation described above. This means that your IP address is only processed by Google in a shortened form. This excludes the possibility of personal references.
3. We use Google Analytics to analyse the use of our website and to continuously improve individual functions and offers as well as the user experience. Through the statistical evaluation of user behaviour, we can improve our offer and make it more interesting for you as a user. The legal basis is Art. 6 para. 1 p. 1 lit. a) GDPR (consent).
4. You can also prevent the storage of cookies generated by Google Analytics by making the appropriate settings in your web browser. Please note that in this case you may not be able to use all the functions of our website. If you wish to prevent the collection of the data generated by the cookie and related to your user behaviour (including your IP address) as well as the processing of this data by Google, you can also download and install the web browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
5. In order to oblige Google to process the transmitted data only in accordance with our instructions and to comply with the applicable data protection regulations, we have concluded an order processing agreement with Google.
6. Information from the third-party provider: Google Ireland Limited, Google Building Gordon House, Barrow St, Dublin 4, Ireland.
7. For further information on the use of data by Google, on setting and objection options and on data protection, please refer to the following Google web pages:
Terms of use: https://marketingplatform.google.com/about/analytics/terms/en/
Overview of data protection: https://support.google.com/analytics/answer/6004245?hl=en&ref_topic=2919631
Privacy policy: https://policies.google.com/privacy?hl=de&gl=en
Data use by Google when you use websites or apps of our partners: https://policies.google.com/technologies/partner-sites?hl=en
Data use for advertising purposes: https://policies.google.com/technologies/ads?hl=en
Settings for personalised advertising by Google: https://adssettings.google.com
8. The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected.
9. deletion of user and event level data linked to cookies, user identifiers (e.g. User ID) and advertising IDs (e.g. DoubleClick cookies, Android advertising ID, IDFA [Apple identifier for advertisers]) will take place no later than 50 weeks after collection.

 

2.5 Google Tag Manager
1. We use the Google Tag Manager on our website. The Google Tag Manager is a service of Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.
2. Through the Google Tag Manager, we can integrate various codes and services on our website in an orderly and simplified manner. The Google Tag Manager implements the tags or "triggers" the embedded tags. When a tag is triggered, Google may process information (including personal data) and process it. In doing so, it cannot be ruled out that Google also transmits the information to a server in a third country.
3. In particular, the following personal data is processed by the Google Tag Manager:
•    Online identifiers (including cookie identifiers).
•    IP address
4. In addition, you can find more detailed information about the Google Tag Manager on the websites https://marketingplatform.google.com/about/analytics/tag-manager/use-policy/
as well as at
https://www.google.com/intl/de/policies/privacy/index.html (section "Data we receive based on your use of our services").
5. Furthermore, we have concluded an order processing contract with Google for the use of the Google Tag Manager (Art. 28 GDPR). Google processes the data on our behalf in order to trigger the stored tags and display the services on our website. Google may transfer this information to third parties if required by law or if third parties process this data on behalf of Google.
6. If you have deactivated individual tracking services (e.g. by setting an opt-out cookie), the deactivation remains for all affected tracking tags that are integrated by the Google Tag Manager.
7. By integrating the Google Tag Manager, we pursue the purpose of being able to carry out a simplified and clear integration of various services. In addition, the integration of the Google Tag Manager optimizes the loading times of the various services.
8. The legal basis for the processing of personal data described here as part of the measurement process is consent expressly granted by you in accordance with Art. 6 Para. 1 lit. a GDPR.
9. The legal basis for the processing of those data that are processed in the context of obtaining consent is our legitimate interest pursuant to Art. 6 (1) lit. f GDPR. We have a legitimate interest in being able to prove that you have given your consent to the measurement procedure (Art. 7 (1) GDPR).

 

2.6 Matomo

1. This website uses the open source software Matomo (formerly Piwik) to statistically evaluate visitor access.
2. Matomo uses "cookies" for the evaluation of user access. With these text files, which are stored on the computer of the respective user, it is possible to analyse the use of the website. The information and data generated by cookies is stored on a server in Germany. The IP address is made anonymous before it is saved. You can deactivate the use of cookies in the settings of your browser. However, this may mean that our website can no longer be used to its full extent.
3. The data will not be passed on to third parties. Matomo uses user data in anonymous form so that we can optimize this website and our offer. IP addresses are stored by Matomo without the last digits. In this respect, we can determine from which network an inquiry comes. It is therefore not possible to assign the IP address to a computer.
4. You can disable Matomo's data collection here. If your browser supports the "Do-Not-Track" technology and you have activated it, your visit is automatically ignored.

5. By using this website, you consent to the processing of data about you by Matomo in the manner and for the purposes set out above.

 

2.7 Sojern
1. Our website uses so-called "pixel tags" (tiny image files), which provide information about which areas of our website customers have visited or measure how effective searches by customers on our website were.
2. Purpose is the secure and efficient provision and optimization of our online offer.
3. The specific storage period of the processed data cannot be influenced by us, but is determined by Sojern, Inc. Further information can be found in the Sojern, Inc. privacy policy; see https://www.sojern.com/privacy.
4. Sojern uses the cookies "apnid", "cid", "gid" and "ttdid". The legal basis is your consent pursuant to Art. 6 para. 1 lit. a GDPR.

 

2.8 TradeDesk
1. Our website uses TradeDesk, a service provided by The Trade Desk, Inc, Cremon 11, 20457 Hamburg, Germany.
2. TradeDesk uses cookies, among other things, which are stored on your computer and which enable an analysis of the use of the website. During use, data, in particular the IP address and user activities, may be transmitted to a server of The Trade Desk, Inc. and stored there. The Trade Desk, Inc. may transfer this information to third parties if this is required by law or if this data is processed by third parties.
3. You can prevent the collection and forwarding of personal data (in particular your IP address) and the processing of this data by deactivating the execution of JavaScript in your browser or installing a tool such as 'NoScript'.
4. Further information on data protection when using TradeDesk can be found at the following link: http://www.thetradedesk.com/privacy-policy/. An opt-out option is available at the following link: http://insight.adsrvr.org/track/stop?action=dooptout.
5. Tradedesk uses the cookies "TDCPM" and "TDID". The legal basis is your consent pursuant to Art. 6 para. 1 lit. a GDPR.

 

2.9 Links to other websites

1. While using some of our services (e.g. “BOOK A TABLE” and “menue card”) you will be automatically redirected to other websites.
2. Please note that this data protection declaration is not valid there. The privacy policy of the linked website may differ significantly from this one.

 

2.10 Hotelcareer / job offers

1. In order to offer the services of hotelcareer, a widget of hotelcareer is integrated on this page. The provider of this widget is StepStone Deutschland GmbH, Völklinger Straße 1, 40219 Düsseldorf.
2. In order to use the functions of the hotelcareer widget, it is necessary to save your IP address, browser information (name, version), website, user's operating system, user's screen resolution, language settings of the browser or the user's operating system. If you use hotelcareer, this data is usually transferred to a hotelcareer server and stored there. The provider of this site has no influence on this data transfer. The use of hotelcareer is in the interest of simple and convenient use.
3. The legal basis for the use of the hotelcareer widget is your consent according to Art. 6 para. 1 lit. a DSGVO. You can find more information on the handling of user data at hotelcareer in the data protection declaration at: https://www.hotelcareer.com/data-privacy-statement

 

2.11 Triptease

1. On this website we use a service provided by Triptease Ltd, 15 Bishopsgate, London, EC2N 3AR, United Kingdom (hereinafter referred to as Triptease). We use the Triptease service to analyse user behaviour. We may share a limited amount of your information (such as room search, email address and name, if you provide it) with the Triptease group and use Triptease to collect data for analysis purposes when you visit our website to book a stay with us. Triptease analyzes your use of our Web site and tracks your use of cookies and similar technologies so that we can improve our service to you.
2. The legal basis for the use of Triptease is your consent according to art. 6 Para. 1 lit. a GDPR.
3. The data will be deleted as soon as the purpose of their collection has been fulfilled. You can find further information about the data protection regulations of Triptease under: https://www.triptease.com/privacy-policy
4. For more information about how Triptease uses cookies, see the following: https://www.triptease.com/cookie-policy

 

2.12 Microsoft Bing Ads
1. This website uses tracking technologies of the Bing Ads service, which is provided and operated by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA ("Microsoft"). Microsoft places a cookie on your device if you have reached our website via a Microsoft Bing ad. In this way, Microsoft Bing and we can recognize that someone has clicked on an ad, has been redirected to our website and has reached a previously determined target website (conversion website). We only learn the total number of users who clicked on a Bing ad and were then redirected to the conversion website. Microsoft collects and processes information via the cookie, from which pseudonymous user profiles are created. These user profiles are used to analyze visitor behavior on our website and are used to display advertisements. No personal information about the identity of the user is processed. If you do not want Microsoft to collect and process this information, you can prevent the setting of cookies in your browser settings. You can also disable targeted and interest-based advertising from Microsoft (http://choice.microsoft.com/de-DE/opt-out).
2. For more information about Bing Ads and Microsoft's use of personal data for advertising purposes, see https://secure.bingads.microsoft.com/ und https://privacy.microsoft.com/en-US/privacystatement.

 

2.13 Unpkg

1. A web service from the company Npm, Inc., 1999 Harrison Street # 1150, CA 94612 Oakland, USA (hereinafter referred to as “Unpkg”) is loaded onto our website. We use Unpkg as a content delivery network. The files integrated via Unpkg are open source, so they can be viewed and checked at any time.
2. The integration takes place on the basis of Art. 6 Para. 1 lit. f GDPR from the legitimate interest in upgrading our website as well as a technically safe, maintenance-free and efficient option to integrate external libraries and frameworks. Since Unpkg uses the hosting provider Cloudflare to provide the data, it is possible that the requests that are sent to these servers are stored for statistical or other purposes of use.
3. If you have activated JavaScript in your browser and have not installed a JavaScript blocker, your browser may transmit personal data to Unpkg.
4. You can prevent Unpkg from collecting and processing your data by deactivating the execution of script code in your browser or by installing a script blocker in your browser.
5. Further information on the handling of the transferred data can be found in Unpkg's data protection statement at https://www.npmjs.com/policies/privacy and at https://www.unpkg.com/ and https://www.cloudflare.com/de-de/privacypolicy/

 
2.14 Consent management
1. Our website uses the cookie consent technology "Contao" to obtain your consent for cookies and cookie-based applications that require your consent and to document this consent in a data protection-compliant manner.
2. When you enter our website, you will be shown a banner through the integration of a corresponding JavaScript code, via which you can give consent for certain cookies and cookie-based applications. As long as you do not give your consent, the aforementioned cookie consent tool blocks the setting of cookies that require your consent. The aforementioned cookie consent tool collects certain user information, including the IP address, when our website is called up so that page calls can be assigned to individual users and, on the other hand, the consent settings made by the user can be individually recorded, logged and stored for a session duration. This data is not passed on to third parties.
3. The collected data will be stored until you request us to delete it or until you delete the Contao cookie yourself or until the purpose for storing the data no longer applies. Mandatory legal retention periods remain unaffected.
4. The Contao cookie consent technology is used to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6 para. 1 p. 1 lit. c GDPR.

 

3 Processing for the purpose of carrying out our business processes

 

3.1 Processing of personal data according to § 30 of the Federal Registration Act
1. We have the legal obligation to collect the following data from you according to the German Federal Registration Act (Bundesmeldegesetz / BMG):
a.) date of arrival and expected departure,
b.) surname,
c.) first name,
d.) date of birth,
e.) nationality,
f.)  address,
g.) the number of fellow travellers and their nationality in the cases of § 29 para. 2 sentences 2 and 3 BMG,
h.) serial number of the passport or the passport substitute paper (only for foreign guests),
i.) If necessary, further data for the collection of tourism and spa contributions
2. We are obliged to collect, process and pass on this data within the framework of the BMG. The legal basis for the processing results from Article 6 paragraph (1) letter c) GDPR (legal requirement).
3. We delete this data or restrict processing as soon as it is permissible under the provisions of the BMG and if there is no consent on your part pursuant to Article 6 paragraph (1) letter a) GDPR and no other legitimate interest on our part pursuant to Article 6 paragraph (1) letter f) GDPR in continued processing.

 

3.2 Table reservations
1. We use the "Opentable" service of the provider OpenTable GmbH (Zeil 109, 60313 Frankfurt am Main, Germany). This service allows you to make table reservations for our restaurant.
2. The use of Opentable contributes to the facilitation of reservations and optimization of our economic operation. This represents a legitimate interest for us in accordance with Art. 6 para. 1 sentence 1 lit. f GDPR.
3. The service is not directly embedded on our website, but is a link to the website of Opentable. User information is only transferred to Opentable after the link is activated. Please note that separate data protection regulations apply on the OpenTable site.
4. For more information about how we treat user information and the information you provide, please see Opentable's Privacy Policy at https://www.opentable.de/legal/privacy-policy.

 

3.3 Hotel stays
1.    When you stay with us, we try to make your stay as pleasant as possible This requires the processing of your personal data to provide specific services during your hotel stay.
These services include
a.) housekeeping and maintenance;
b.) the return of lost or forgotten items to you; and
c.) managing your preferences and those of your companions, such as dietary requirements and pillow preferences
to offer you a better service during your stay with us.
2. For these purposes we process in particular the following data: name and surname, postal address, consumption habits, arrival and departure dates, nutritional needs, e-mail address, first and last name of adult roommates, other personal preferences, payment information (for the return of lost or forgotten items), telephone number
3. These data are usually collected directly from you, during your stay in the hotel, or reach us via your travel agency or, for example, through the booking system you use.
4. Legal basis for the processing of this data is the balancing of interests in accordance with Art. 6 Para. 1 Sentence 1 lit. f GDPR. Our legitimate interest is to organise our hotel maintenance activities, to personalise the services offered and to be able to identify the owner of a lost or forgotten item.
5. Possible recipients of the data are hotel personnel (including housekeeping, maintenance, reception and other hotel personnel), IT service providers and delivery or courier service providers (for the return of lost or forgotten items).
6. You can object to the use of the data at any time with effect for the future. An objection can lead to a noticeable restriction of our services.

 

3.4 Gift vouchers
1. In our voucher shop you have the opportunity to purchase vouchers for different occasions. If a user realizes this option, the data entered in the input mask will be transmitted to us and processed by us. The processing includes the following data: salutation / title, first name, name, telephone number, e-mail address, date of birth, address, voucher value, wishes, payment data.
2. The voucher shop is based on the voucher system of INCERT eTourism GmbH & Co KG, Lederfabrik Linz, Leonfeldnerstrasse 328, A-4040 Linz (www.incert.at). We have concluded an order processing agreement with INCERT.
3. A transfer of personal data to third parties, if this is necessary in the context of the contract, for example, to the commissioned with the payment transaction bank. Further transmission of data only takes place if you have expressly consented to the transmission.
4. The legal basis for the processing of the data is the conclusion of a purchase contract with the user in accordance with article 6 paragraph 1 lit. b GDPR.
5. The processing of the personal data provided by the user takes place solely for the processing of the voucher purchase and for the handling of payment transactions.

 

3.5 Surveys
1. We use the software "ReviewPro" to process your ratings and comments in the context of surveys such as the restaurant survey.
2. ReviewPro is provided by Review Rank, S.A. (Aribau 240, 6-M Barcelona, 08006 Spain). For details, please refer to the Privacy Policy of Review Rank S.A. at https://www.reviewpro.com/privacy-policy/
3. By participating in a survey you agree to the processing of your data for the purpose of conducting and evaluating the survey.
4. The participation in a survey can always be carried out without providing personal data. If you provide us with your contact details, these may be used to clarify any queries relating to the respective survey.
5. 6 months after the completion of the survey, the data will be deleted.

 

3.6 Video surveillance
Below you will find our privacy policy in the sense of article 13 GDPR regarding the processing of personal data in the context of our video surveillance.
1. Video recordings are processed on the basis of article 6 paragraph 1 lit. f GDPR; the so-called legitimate interest.
2. Our legitimate interests are:
•    Preservation of the house right
•    Protection against theft, protection of property
•    Clarification of burglary and theft
•    Protection of guests and employees
3. The processing of the video recordings is exclusively done in accordance with the stated purpose.
4. Any further use or transfer of video recordings shall only be made to the extent that this is necessary in the context of a possible prosecution. Recipients in this case are the competent law enforcement agencies.
5. We use external service providers for the maintenance of the video surveillance system, whereby access to the video surveillance system or stored video recordings can not be ruled out.
6. The deletion of the video recordings takes place 10 days after recording, provided that no special occurrences have occurred which justify or require further storage.

3.7 Newsletter
1. Description and scope of data processing
If you would like to receive the newsletter offered on the website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter. No further data is collected, or only on a voluntary basis.
We use the "Brevo" service to send newsletters. The provider is Sendinblue GmbH (Köpenicker Straße 126, 10179 Berlin, Germany) - hereinafter referred to as the service provider. Your data is stored on Sendinblue GmbH servers in Germany.
You can find detailed information about the service and the service provider here:
https://www.brevo.com/de/datenschutz-uebersicht/sowie
https://www.brevo.com/de/legal/privacypolicy/.
2. Usage analysis
With the help of Brevo, we are able to analyze our newsletter campaigns. For example, we can see whether a newsletter message has been opened and which links have been clicked on. In this way, we can determine, among other things, which links were clicked on particularly often.
We can also recognize whether certain previously defined actions were carried out by the newsletter recipient after opening/clicking (conversion rate). For example, we can recognize whether a room was booked or a table reserved after clicking on the newsletter.
If you do not wish to be analyzed by Brevo, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every e-mail/newsletter.
You can find detailed information on the functions of Brevo here:
https://www.brevo.com/de/newsletter-software/.
3. Legal basis
Data processing is based on your consent (Art. 6 para. 1 lit. a GDPR). You can revoke this consent at any time. The legality of the data processing operations that have already taken place remains unaffected by the revocation.
The legal basis for the usage analysis is the balancing of interests pursuant to Art. 6 para. 1 lit. f GDPR.
We have concluded a data processing agreement (DPA) with the service provider in accordance with Art. 28 GDPR for the use of Brevo. This ensures that the service provider processes the personal data of our newsletter recipients only in accordance with our instructions and in compliance with the GDPR.
4. Storage period
Your data processed in Brevo will be stored by us or the service provider until you unsubscribe from the newsletter and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored by us for other purposes remains unaffected by this.
After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the service provider in a blacklist if this is necessary to prevent future mailings. The data from the blacklist will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). Storage in the blacklist is not limited in time. You can object to storage in the blacklist if your interests outweigh our legitimate interest.

4 Cookies

 

4.1 General Information

1. Cookies are information transmitted by our web server or third-party web servers to the users' devices where they are stored for later retrieval. Cookies can be in the form of small files or any other types of information storage.
2. In the case that users do not want that cookies are stored on their device, they will be asked to disable the corresponding option in their browser's system settings. Saved cookies may be deleted in the system settings of the browser. The exclusion of cookies can lead to functional impairments of this online service.

 

4.2 Cookie overview, objection
1. You can find an up-to-date overview of the cookies and services used on this website in the "Contao" consent management platform (see section 2.15 „Consent management“).
2. You can also manage your individual consents and preferences there.

 

 

5 Changes to the Data Privacy Policy

 

1. We reserve the right to change this Data Privacy Policy with regards to the data processing, in order to adapt it to changed legal situations, to changes of the online service or of the data processing.
2. If users' consents are required or if elements of the Data Privacy Policy contain provisions in regards to the contractual relationship with the users, the changes will only be made with the consent of the users.
3. Users are requested to keep themselves informed about the content of this Data Privacy Policy on a regular basis.

 

Version: January 2024