Privacy Policy
1. Scope and overview
We respect your personality and privacy and want to ensure the protection and lawful processing of your personal data.
In this data protection declaration we therefore inform you how and for what purpose we collect, process and use your personal data.
Personal data is processed when you use our website http://www.appreci8.io/ (“Website”) and also offline in the context of customer relations and for the provision of services.
“Personal data” are all individual details about personal or factual circumstances of an identified or identifiable natural person. This means that it is information that is personally assigned to you and can say something about you. We process different categories of such personal data. The main categories are listed below (see para. 3). In individual cases, however, we may also process other personal data.
“Processing” in this context means any handling of your data, including in particular the collection, storage, administration, use, transmission, disclosure or deletion of personal data.
2. Responsible body
Responsible for the data processing on our website:
Silverbush AG
Rotfluhstrasse 91
8702 Zollikon
Switzerland
E-mail: dataprivacy@appreci8.net
3. Scope and purpose of personal data
3.1 General
We enable you to make use of the following functionalities via this website:
- Analysis and support of recruiting processes without performance evaluation
- Video / Audio – Recording function for job interviews and for training purposes
- Evaluation of soft skills based on gestures, facial expressions and language of the applicants
- Assignment / matching of previously defined criteria to jobs
The provision of corresponding functionalities corresponds to the purposes of the processing. In addition, personal data are processed for the purpose of matching applicants, facilitating the search for and contact by interested parties.
3.2 Technical data if visiting our website
When you visit our website, our servers store the access in a so-called log file. The following technical data is collected automatically and without your intervention, as is the case with every connection to a web server:
- the Internet Protocol (IP) address of the requesting computer
- the name of the owner of the IP address range (usually your Internet access provider)
- the date and time of access
- the website from which the access was made (referrer URL), if applicable with the search word used
- the name and URL of the retrieved file
- the status code (e.g. error message)
- the operating system of your computer
- the browser you are using (type, version and language)
- the transmission protocol used (e.g. HTTP/1.1)
- if applicable, your user name from a registration/authentication
This data is collected and processed for the purpose of enabling the use of our website (connection establishment), ensuring and increasing the system security and stability of our systems and offers, analyzing the use of our offers and services, collecting general demographic information and enabling the optimization of our Internet offer (in particular, but not exclusively, product improvements, marketing measures, target group-specific advertising, etc.), as well as for internal statistical purposes.
We do not identify you as a website user unless you have a user account and are registered.
In addition, we use cookies and analysis tools (e.g. Google Analytics) when you visit our website (cf. para. 3.6 and 10).
3.3 Opening a user account
In order to obtain services via our website, you must open a user account. Which data is collected when opening a user account can be seen from the input form provided for this purpose, whereby it is indicated which information is mandatory and which information can be provided voluntarily. For example, the following information can be requested and processed:
- First name and surname
- Complete postal address (home, delivery and/or billing address)
- Telephone number(s)
- E-mail address(es)
- Birthday
- Gender
- Credit card and account information (depending on the selected payment method)
- Language preferences
- Information about subscribed newsletters or other advertising
In order to use certain functionalities of this website, information is required from you so that we can offer and provide you with the services of this website. This includes in particular:
- Information about your personal and professional skills (e.g. professional and educational background, completed training and courses, language skills, etc.)
- Video / Audio – Recording function for job interviews
- Information about preferences, wishes and expectations for a job
We use this information for the processing and administration of our digital offers, in particular for the
- Analysis and support of recruiting processes without performance evaluation
- Evaluation of soft skills on the basis of gestures, facial expressions and language of the applicants in video recordings
- Assignments based on analysis results and defined criteria to jobs or with employers or recruiters
With the help of the user account, we would like to provide you with protected and direct access to your basic data stored with us. You can view data about your completed, open and recently sent submissions and created documents (e.g. CV, resume) and manage your address data, bank details and newsletter.
We use the personal data for the processing and administration of our digital offers, for checking the plausibility of the data entered, i.e. for the establishment, content, processing and amendment of the contractual relationships concluded with you via your user account and, in the case of chargeable services, for proper invoicing.
With your confirmation at the conclusion of the opening or at the mutation of your details, you guarantee the correctness of the content of the details you have provided. You are obliged to treat the personal access data to the user account confidentially and not to make them accessible to any unauthorized third party. We cannot accept any liability for misused passwords unless we are responsible for the misuse.
3.4 Use of the website with a user account
Furthermore, we collect data for statistical reasons if you have a user account and are logged in to enable the smooth functioning of the website as well as for the analysis, optimization and personalization of the use of our offers and services. Thus, we collect data on whether and how you use our digital offers, in particular which functions and which content you perceive and how.
3.5 Contract data
Contract data is personal data that is generated in connection with the conclusion or execution of a contract, e.g. information on the conclusion of the contract or information on customer satisfaction. In this context, we process the personal data required for the conclusion, execution or termination of a contract. This includes in particular:
- Contact details (e.g. first name, last name, address, e-mail address, etc.) as well as billing and delivery address
- E-mail address
- Information on the initiation and conclusion of contracts, e.g. date of conclusion of the contract, information from the application process and information on the contract in question (e.g. type and duration);
- about the processing and administration of contracts (e.g. contact details, delivery addresses, deliveries made or failed and payment information);
- in connection with customer service and assistance with technical matters;
- about our interactions with you (if applicable, a history with corresponding entries);
Depending on the selected payment option, such as invoice, credit card or PayPal, the payment and thus also the processing of personal and payment data can take place via the corresponding payment system of the respective provider. In each case, the data protection provisions of the respective payment system provider also apply.
If you are registered and have a user account, we may store your personal data in the user account for the next purchase or contract conclusion. In particular, we store all information about your current and previous purchases and contract conclusions, i.e. the products, the services, the number of products and services per purchase, the payment amount. This data is used for analysis purposes (cf. para. 3.6).
3.6 Processing for marketing and analysis purposes; profiling
Our aim is to continuously improve the digital offers provided to you and to make them more needs-oriented and secure or to send you personalized advertising.
In some cases, your personal data is processed automatically in order to evaluate certain personal aspects (so-called profiling). Profiling is used by us in particular to be able to inform and advise you specifically about certain services or products from us.
For this purpose, user-specific historical and future data that we have at our disposal or will collect in the future can be linked with each other on an ongoing basis using various analysis tools, and user behaviour can be analyzed, aggregated, pseudonymized or anonymized across all offers. To improve our database, we may consult publicly available data or data from third-party providers. For example, the following customer activities may be processed:
- Contract data (including date of contract, type of contract, content of contract; contractual partner; term of contract; value of contract; claims asserted under contract)
- Usage information (including date, time, type, quantity and value of services requested or purchased; shopping cart; abandoned shopping cart; payment methods used; payment point; purchase history)
- Customer service information (including complaints, warranty claims, delivery information)
- Session data relating to visits to our Internet pages, apps for mobile devices or offers on Internet platforms, multimedia portals or social networks (including duration and frequency of visits, language and country preferences, information about browser and computer operating system, Internet protocol addresses, search terms and search results; ratings given)
- Location-based data when using mobile devices, if you have activated location sharing
- Communications via phone or e-mail
The knowledge gained from your use of our offer may be used and exploited by other participating companies as part of the analysis of user behaviour.
3.7 Contact and correspondence
We process personal data that you provide to us when you contact us via a contact form or by email, for example by submitting personal data to us. We ask you to use your discretion in determining what data you wish to disclose to us through these means of communication.
Your personal data is processed by us for the purpose of answering your request, for quality assurance or optimization of our service offer as well as for technical administration.
4. Origin of personal data
4.1 Transferred data
You usually provide us with personal data yourself, e.g. when you send us data, open a user account, order services or communicate with us.
The provision of personal data is usually voluntary, i.e. you are usually not obliged to disclose personal data to us. However, we must collect and process those personal data that are necessary for the processing of a contractual relationship and for the fulfilment of associated obligations or are required by law, e.g. mandatory contractual data. Otherwise, we will not be able to conclude or continue the contract in question.
If you provide us with information about other people (e.g. family members), we will assume that you are authorized to do so and that this information is accurate. Please also ensure that these other persons have been informed about this privacy policy.
4.2 Data collected
We may also collect personal data about you ourselves or by automated means, e.g. when you use our offers or make use of our services. This often involves behavioural and transactional data as well as technical data.
We may also derive personal data from existing personal data, for example, by evaluating behavioral and transactional data. Such derived personal data is often preference data.
We may, for example, analyze the behavioural and transactional data generated when you access the services via this website and make assumptions about your personal interests, preferences, affinities and habits based on this data. This enables us, for example, to tailor our offers and information to your individual needs and interests.
4.3 Received data
We may also receive personal information about you from other third parties, such as companies we work with, people who communicate with us, or public sources.
For example, we may receive information about you from the following third parties:
- from third parties when correspondence and meetings concern you;
- from credit agencies, e.g. when we obtain credit information;
- from the Swiss Post and address dealers, e.g. for address updates;
- of banks, insurance companies, distributors and other contractual partners for purchases and payments;
- from providers of online services, e.g. providers of Internet analysis services;
- of information services for compliance with legal requirements such as anti-money laundering and export restrictions;
- of authorities, parties and other third parties in connection with official and judicial proceedings;
- from public registers such as the debt enforcement register or the commercial register, from public bodies such as the Federal Statistical Office, from the media or from the Internet.
5. Legal basis of the processing
Depending on the purpose of the data processing, our processing of personal data is based on different legal bases. We may process personal data in particular if the processing:
- is necessary for the performance of a contract with the data subject or for pre-contractual measures (e.g. the examination of a contract request);
- is necessary for the exercise of legitimate interests;
- is based on consent;
- is necessary to comply with domestic or foreign law.
We have a legitimate interest in particular in the processing for the purposes described and in the disclosure of data to third parties and the objectives associated with this in each case. The legitimate interests in each case include our own interests and the interests of third parties. These legitimate interests include, for example, the interest of
- in good customer service, maintaining contacts and communicating with people even outside of a contract;
- in advertising and marketing activities;
- to get to know you and other people better;
- to improve products and services and to develop new ones;
- in the fight against fraud, e.g. in online shops, and the prevention and investigation of offences;
- in ensuring IT security, especially in connection with the use of websites, apps and other IT infrastructure;
- to ensure and organize business operations, including the operation and further development of websites and other systems;
- in corporate management and development;
- in the sale or purchase of companies, parts of companies and other assets;
- in the enforcement or defence of legal claims;
- in compliance with Swiss and foreign law as well as internal rules.
If and to the extent that the European General Data Protection Regulation (GDPR) applies, the following provisions regarding the legal basis shall apply.
Article 6(1)(a) of the GDPR serves as the legal basis for processing operations where we obtain consent for a specific processing purpose. Where the processing of personal data is necessary for the performance of a contract to which the data subject is a party, such as 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) of the GDPR. The same applies to such processing operations that are necessary for the implementation of pre-contractual measures, for example in cases of inquiries about our products or services.
If our company is subject to a legal obligation by which the processing of personal data becomes necessary, such as for compliance with tax obligations, the processing is based on Art. 6 para. 1 lit. c) DSGVO.
In rare cases, the processing of personal data might be necessary to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured on our premises and as a result his or her name, age, health insurance details or other vital information had to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6 (1) (d) DSGVO.
Ultimately, processing operations could be based on Article 6(1)(f) of the GDPR. Processing operations which are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to protect a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject are not overridden. Such processing operations are permitted to us in particular because they were specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest could be assumed if the data subject is a customer of the controller (recital 47, sentence 2 of the GDPR).
Where the processing of personal data is based on Art. 6(1)(f) DSGVO, our legitimate interest is to carry out the safe and efficient provision and optimization of our online offer and our business in general for the benefit of the well-being of all our employees and our shareholders.
6. Newsletter, print magazine and direct marketing
You have the option of subscribing to our e-mail newsletter by providing your e-mail address in order to receive regular information about our promotions, offers and innovations. The provision of further information, e.g. first name and surname, is voluntary and will be used to address you personally.
The newsletter will only be sent to you after you have entered your e-mail address and clicked on the link in the confirmation e-mail that is sent to you (so-called double opt-in procedure). By activating the confirmation link, you give us your consent for the use of your personal data. For the purpose of tracking your consent, we store your IP address and the date and time of your consent.
As a customer, you will receive regular postal advertising and/or e-mails with products and services of interest to you, in the case of e-mails based on your purchases, within the framework of the legal requirements and independently of the registration for our newsletter, unless you have already objected to this in the past. In doing so, we use your postal address or, in the case of addressing you by e-mail, the e-mail address you have provided. For the purpose of targeting advertising more closely to your interests, we may assign your data collected from business transactions such as purchases or returns to different customer or interest groups (profiling).
You can unsubscribe from the newsletter or from our magazine at any time and without giving a reason either in your user account or by e-mail or telephone. You can also unsubscribe from the e-mail newsletter yourself via the unsubscribe link that is attached to each newsletter. By unsubscribing, you object to the use of your e-mail address for sending the newsletter.
7. Disclosure of data to third parties
We work together with other companies or persons or commission other companies or persons with the processing and storage of data. They may have access to your personal data or usage data, but only to the extent necessary to perform their tasks. If external processors are used, they are contractually bound and technical and organisational measures are applied to ensure that they comply with the same data protection requirements and other obligations imposed by applicable data protection law to which we are subject.
Except as described below, we will only disclose your personal information when
- Your consent has been obtained;
- there is a legal obligation;
- this is necessary for the enforcement of our rights, in particular the enforcement of claims arising from the contractual relationship;
- this is necessary for the fulfilment of the contract or the implementation of pre-contractual measures;
- we have a legitimate interest in doing so and your contrary interests are not overridden; or
- another legal permission exists.
7.1 Order processing
We share your data with third parties to the extent necessary in the context of the use of the website and its services and the execution of contracts. For example, we pass on the necessary data to a service provider entrusted with the evaluation of soft skills based on video recordings, to banks or other payment service providers.
7.2 Partner for credit checks and payment processing
Insofar as we make advance payments, e.g. in the case of a purchase on account, we may, if necessary, obtain creditworthiness information from a credit agency on the basis of mathematical-statistical procedures in order to protect our legitimate interests. We work with the credit agency: Creditreform Egeli Zürich AG
For this purpose, we transmit the address data required for a credit check to the credit agency and use the information received about the statistical probability of a payment default for a weighed decision on the establishment, implementation or termination of the contractual relationship. The creditworthiness information may contain probability values (score values) which have been calculated on the basis of scientifically recognised mathematical-statistical procedures and in the calculation of which, among other things, address data are included. Your interests worthy of protection are taken into account in accordance with the statutory provisions.
Finally, when you make a credit card payment on the website, we forward your credit card information to your credit card issuer and to the credit card provider. If you choose to pay by credit card, you will be asked to provide all mandatory information. Regarding the processing of your credit card information by third parties, we ask you to also read the terms and conditions as well as the privacy policy of your credit card issuer.
7.3 Entrepreneurial reorganizations
In the event of a sale, merger or other reorganization of some or all of our company’s assets, personal information may be transferred, sold or otherwise shared with third parties as part of that transaction or reorganization.
7.4 Partner for newsletter dispatch by e-mail
For the dispatch of e-mail newsletters, we work together with “MailChimp” of the company The Rocket Science Group, LLC d/b/a MailChimp, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA (https://mailchimp.com/), to whom we pass on your data provided during the newsletter registration. Your data is usually transferred to a MailChimp server in the USA and stored there.
MailChimp uses this information to send and statistically evaluate the newsletter on our behalf. For the evaluation, the sent e-mails contain so-called web beacons or tracking pixels, which are single-pixel image files that are stored on our website. This makes it possible to determine whether a newsletter message has been opened and which links, if any, have been clicked on. In addition, technical information is recorded (e.g. time of retrieval, IP address, browser type and operating system). The data is collected exclusively pseudonymously and is not linked to your other personal data, a direct personal reference is excluded. This data is used exclusively for the statistical analysis of newsletter campaigns. The results of these analyses can be used to better adapt future newsletters to the interests of the recipients.
Furthermore, MailChimp may use this data itself on the basis of its own legitimate interest in the needs-based design and optimization of the service as well as for market research purposes, for example, to determine from which countries the recipients come. However, MailChimp does not use the data of our newsletter recipients to write to them itself or to pass them on to third parties.
If you wish to object to the data analysis for statistical evaluation purposes, you must unsubscribe from the newsletter.
To protect your data in the USA, we have concluded an order data processing agreement (“Data Processing Agreement”) with MailChimp on the basis of the standard contractual clauses of the European Commission to enable the transfer of your personal data to MailChimp. This data processing agreement can be viewed at the following internet address: https://mailchimp.com/legal/data-processing-addendum/.
You can view MailChimp’s privacy policy here: https://mailchimp.com/legal/privacy/
7.5 Hosting Partner
For the purpose of hosting and distributing website content, we use the products of hosting partners based in Switzerland and abroad, who process our data on our behalf.
Hosting partners outside Switzerland are:
- Heroku. The hosting of the provider takes place exclusively in the data centers in EU
We have concluded a Data Processing Agreement (DPA) with the provider based on EU standard contractual clauses. The provider guarantees to process personal data in accordance with Swiss and European data protection laws even outside the EU or the European Economic Area. You can view the provider’s privacy policy here: https://devcenter.heroku.com/articles/gdpr
8. Transfer of personal data abroad
We are also entitled to transfer your personal data to commissioned third-party companies abroad. These are obliged to the same extent as we are to data protection. If the level of data protection in a country does not correspond to that in Switzerland or the EU, we contractually ensure that the protection of your personal data corresponds to that in Switzerland or the EU at all times. We ensure this in each case through one or more of the following measures:
- by concluding standard contractual clauses of the European Commission with the commissioned service providers, cf. https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_de
- by the existence of Binding Corporate Rules (BCR) recognized by a European data protection authority at the service providers commissioned, cf. https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/binding-corporate-rules_de
9. Cookies
We use cookies on various pages to make visiting our website more attractive, to enable the use of certain functions and to improve offers on our website accordingly. These are small text files that are stored on your computer. Most of the cookies we use are deleted from your hard drive at the end of the browser session (so-called session cookies). Other cookies remain on your computer and allow us to recognize you on your next visit (so-called permanent cookies).
Most Internet browsers (“browsers”) automatically accept cookies. However, you can configure your browser so that no cookies are stored on your computer or a message always appears when you receive a new cookie.
Deactivating cookies may mean that you are no longer able to use all the functions of our website to their full extent.
10. Tracking and Analysis Tools
10.1 General
For the purpose of demand-oriented design and continuous optimization of our website, we use the following tracking and web analysis services from third-party providers, such as Google Analytics from Google Inc. In addition to the data listed under point 3 we may receive the following information:
- navigation path followed by a visitor to our website
- Dwell time on the website or subpage
- Subpage on which the website is left
- Country, region or city from where access is made
- End device (type, version, color depth, resolution, width and height of the browser window)
- Information whether visitor is recurring or new.
This information is used to evaluate the use of the website, to compile reports on website activity and to provide other services associated with the use of the website and the Internet for the purposes of market research and the design of the website in line with requirements. A transfer of data from our service partners to third parties only takes place due to legal regulations or within the framework of order data processing.
10.2 Analysis tools from Google
Due to the tools used by Google, your browser automatically establishes a direct connection with the Google server. We have no influence on the scope and further use of the data collected by Google through the use of this tool and therefore inform you according to our state of knowledge: Through the integration of Google Analytics, Google receives the information that you have called up the corresponding part of our website or clicked on an advertisement from us. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, there is the possibility that Google learns your IP address and stores it.
Statistical evaluations are provided by Google. Based on these evaluations, we can see which of the advertising measures used is particularly effective. We do not receive any further data from the use of the advertising media; in particular, we have no way of combining the data with your personal data and identifying you.
10.2.1 Google Analytics
The provider of Google Analytics is Google Inc, a company of the holding company Alphabet Inc, based in the USA. Before the data is transmitted to the provider, the IP address is shortened by activating IP anonymization (“anonymizeIP”) on this website. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. The anonymized IP address transmitted by your browser within the scope of Google Analytics is not returned to us. According to its own information, Google Inc. will not associate the IP address with any other data relating to the user. You can find more information about the web analysis service used on the Google Analytics website. A browser add-on to deactivate Google Analytics can be found at http://tools.google.com/dlpage/gaoptout?hl=de.
10.2.2 Google Adwords
We use the offer of Google Adwords to draw attention to our attractive offers with the help of advertising tools (so-called Google Adwords) on external websites. We use this tool to display advertisements that may be of interest to you, to make our website more interesting for you and to achieve a fair calculation of advertising costs.
These advertisements are delivered by Google via so-called “ad servers”. For this purpose, we use ad server cookies, through which certain parameters for measuring success, such as the display of ads or clicks by users, can be measured. If you access our website via a Google ad, Google Adwords will store a cookie on your PC. These cookies usually lose their validity after 90 days. The unique cookie ID, number of ad impressions per placement (frequency), internet browser, last impression (relevant for post-view conversions) and opt-out information (marking that the user no longer wishes to be addressed) are usually stored as analysis values for this cookie. If a user visits certain pages of the website and the cookie stored on his computer has not yet expired, Google can recognize that the user clicked on the ad at an earlier time and was redirected to this page.
10.3 Use of social plugins from Facebook
So-called social plugins (“plugins”) of the social network Facebook are used on our website. Facebook is operated by Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”).
You can find an overview of the plugins here: https://developers.facebook.com/docs/plugins. If you call up a page of our website that contains such a plugin, your browser establishes a direct connection to the Facebook servers. The content of the plugin is transmitted directly to your browser by the respective provider and integrated into the page. By integrating the plugins, the providers receive the information that your browser has accessed the corresponding page of our website, even if you do not have a profile with the corresponding social network or are not currently logged in. This information (including your IP address) is transmitted from your browser directly to a server of the respective provider in the USA and stored there.
If you are logged into one of the social networks, the providers can directly assign the visit to our website to your profile on Facebook. If you interact with the plugins, for example by clicking the “Like” button, the corresponding information is also transmitted directly to a server of the provider and stored there. The information will also be published on the social network and possibly displayed to your contacts there.
The purpose and scope of the data collection and the further processing and use of the data by the providers as well as your rights in this respect and setting options for protecting your privacy can be found in the data protection information of the providers.
Facebook privacy notice: http://www.facebook.com/policy.php
If you do not want Facebook to directly assign the data collected via our website to your profile in the respective social network, you must log out of Facebook before visiting our website.
You can also completely prevent the loading of the plugins with add-ons for your browser, e.g. the Facebook plugins with the “Facebook Blocker” (http://webgraph.com/resources/facebookblocker/).
10.4 Instagram links
Our website contains links to the Instagram service, which is operated by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA. We do not use so-called “social plugins” from Instagram for this purpose. By clicking on these icons, you will be redirected directly to the internet pages of Instagram.
In order to protect your privacy, please refer to Instagram’s privacy policy at: https://help.instagram.com/155833707900388 for further details on the collection, processing and use of your data, as well as your legal options and settings.
10.5 Use of LinkedIn Analytics
We use the analysis service LinkedIn Analytics of LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. Through the use of LinkedIn Analytics, pseudonymous usage profiles are created of the users. The profiles are used to analyse user behaviour and are used to optimise our offer. The following data is processed
- Information about the operating system
- Device identifier
- Internet Service Provider
- IP address
- referrer URL
- Browser information
You can obtain further information on the processing of data by LinkedIn here: https://www.linkedin.com/legal/privacy-policy
10.6 Use of Twitter Analytics
We use the analytics tool Twitter Analytics from Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA (hereinafter referred to as: Twitter). With Twitter Analytics, we can measure interaction with Twitter users, learn the interests, locations and origins of our followers and track how our Twitter Cards achieve clicks, app installs and retweets. The following data is processed in the process:
- IP address (anonymized)
- Browser type
- Referrer/Exit pages
- Operating system
- Time and date of access
- Clickstream data
- Views
- Clicks
- Twitter account details
You can obtain further information on the processing of data by Twitter Analytics here: https://twitter.com/de/privacy
11. Data security
We use appropriate technical and organizational security measures to protect your personal data stored with us against manipulation, partial or complete loss and against unauthorized access by third parties. Our security measures are continuously adapted and improved in line with technological developments.
You should always keep your account access data confidential and close the browser window when you have finished communicating with us, especially if you share the computer with others.
Internally, we have taken a variety of measures to protect your data and handle it with care. In doing so, our employees and the service companies commissioned by us have been obligated to maintain confidentiality and comply with the provisions of data protection law.
12. Retention period of personal data
We retain personal data only for as long as is deemed necessary to comply with applicable laws and to protect our rights (legal retention period, e.g. commercial and tax retention periods) or as long as it is necessary for the purposes for which it was collected.
In particular, we store the personal data collected from customers in compliance with the following periods and subsequently delete them, provided that there are no legal or operational storage obligations/reasons to the contrary, or we have informed you in advance of deviating storage periods:
- Data collected during a purchase in the online shop is generally kept for 10 years after the last processing operation for accounting reasons;
- Personal data collected for marketing measures or web analyses are stored until the analysis is completed. The data is deleted at the latest two years after it is no longer used for advertising purposes or after expiry of the maximum retention period prescribed by law.
- Data that is collected for the purpose of providing the website is deleted when the respective session has ended. In the case of storage of data in log files, this is the case after three months at the latest.
13. Right of access, rectification, erasure or complaint
You can request information at any time about all data available in our data collection that concerns you. In particular, you can request information about:
- the processing purposes
- the category of personal data
- the categories of recipients to whom your data have been or will be disclosed
- the planned storage period
The exercise of your rights requires that you prove your identity (e.g. by means of a copy of your identity card if your identity cannot be established in any other way). In addition, we reserve the right, in the event of a disproportionately large expense, to demand that you bear the actual costs in advance.
Further, you are entitled,
- obtain information about the legal basis of the processing;
- immediately request the correction of incorrect or incomplete personal data stored by us;
- request the erasure of your personal data, unless the processing is necessary for the exercise of the right to freedom of expression and information, to comply with a legal obligation, for reasons of public interest or to assert or defend legal claims;
- request the restriction of the processing of your personal data if (i) the accuracy of the data is contested by you, (ii) the processing is unlawful but you object to its erasure, (iii) we no longer require the data but you need it for the assertion, exercise or defence of legal claims or (iv) you have objected to the processing;
- Receive the personal data you have provided to us in a structured, commonly used and machine-readable format or request that it be transferred to another controller.
You can revoke your consent at any time. This has the consequence that we may no longer continue the data processing based on this consent for the future.
We would like to point out that the exercise of your rights may be subject to legal restrictions. We reserve the right to assert these, e.g. if we are obliged to retain or process certain data, have an overriding interest in doing so (insofar as we are entitled to rely on this) or require them for the assertion of claims. Please note that the exercise of your rights may, under certain circumstances, conflict with contractual agreements and may have corresponding effects on the performance of the contract (e.g. premature termination of the contract or cost consequences). Where this is not already contractually regulated, we will inform you in advance.
You can complain to our data protection advisor or to a supervisory authority at any time. If your personal data is processed on the basis of legitimate interests, you have the right to object to the processing of your personal data if there are grounds for doing so that arise from your particular situation or if the objection is directed against direct advertising. In the latter case, you have a general right of objection, which is implemented by us without specifying a particular situation.
14. Amendment of the privacy policy
Due to the further development of our website or the implementation of new technologies, it may become necessary to change this privacy policy. If we decide to make material changes to our privacy policy, we will post those changes on our website and notify registered users by e-mail to the e-mail address they provided when they opened an account.
