1. General information

1.1 Objective and responsibility

1.2 Legal basis

1.3 Data subject rights

1.4 Data deletion and storage period

1.5 Processing security

1.6 Data transfer to third parties, subcontractors and third-party providers

2. Processing within the scope of our online offer

2.1 Collection of information on the use of the online offer

2.2 DoubleClick

2.3 Facebook Pixel (Facebook Custom Audience)

2.4 Google AdServices

2.5 Google AdWords Conversion

2.6 Google Analytics

2.7 Google Fonts

2.8 Google Tag Manager

2.9 Links to other websites

3. Processing for the purpose of carrying out our business processes

3.1 Contact form and contact by e-mail

3.2 Direct marketing

3.3 Canvassing existing customers

3.4 Responding to inquiries about projects

4. Cookie policy

4.1 General information

4.2 Cookie overview

4.3 Possibilities of objection

5 Changes to the privacy policy

1 General information

1.1 Objective and responsibility

1. this privacy policy informs you about the nature, scope and purpose of the processing of personal data in relation to our online offer and the associated websites, functions and content (hereinafter collectively referred to as “online offer” or “website”).

The provider of the online offer and responsible for data protection is Richard Tremmel (Schönbrunner Straße 36/55) – hereinafter referred to as “provider”, “we” or “us”.

The term “user” includes all customers and visitors of the online offer.

1.2 Legal basis

We collect and process personal data based on the following legal bases:

1. consent pursuant to Article 6(1)(a) of the General Data Protection Regulation (GDPR). Consent is any voluntary, specific, informed and unambiguous expression of will in the form of a statement or other unambiguous affirmative act by which the data subject indicates his or her agreement to the processing of personal data relating to him or her.

2. necessity for the fulfillment of the contract or the performance of preparatory measures pursuant to Article 6(1)(b) GDPR, i.e. the data is necessary for us to fulfill our contractual obligations towards you or we need the data to prepare for the conclusion of a contract with you.

3. processing for compliance with a legal obligation pursuant to Article 6(1)(c) GDPR, i.e. that, for example, processing of the data is required by law or other regulation.

4. processing for the purposes of legitimate interests pursuant to Article 6(1)(f) GDPR, i.e. that the processing is necessary to protect legitimate interests on our part or on the part of third parties, unless such interests are overridden by the interests or fundamental rights and freedoms of you which require the protection of personal data.

1.3 Data subject rights

You are entitled to the following rights regarding data processing by us:

1. right of appeal to a supervisory authority pursuant to Article 13(2)(d) of the GDPR and Article 14(2)(e) of the GDPR.
2. right to information pursuant to Article 15 GDPR
3. right of rectification pursuant to Article 16 GDPR
4. right to erasure (“right to be forgotten”) pursuant to Article 17 GDPR
5. right to restriction of processing pursuant to Article 18 GDPR
6. right to data portability pursuant to Article 20 GDPR
7. right to object pursuant to Article 21 GDPR

Note: Users may object to the processing of their personal data in accordance with the legal requirements at any time with effect for the future. The objection can be made in particular against the processing for purposes of direct advertising.

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, workplace or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.

1.4 Data deletion and storage period

The personal data of the data subject shall be deleted or blocked as soon as the purpose of the storage no longer applies. In addition, storage may take place if this has been provided for by the European or national legislator in Union regulations, laws or other provisions to which the controller is subject. Blocking or deletion of data also takes place when a storage period prescribed by the aforementioned standards expires, unless there is a need for further storage of the data for the conclusion or performance of a contract.

1.5 Processing security

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

1.6 Data transfer to third parties, subcontractors and third-party providers

1. personal data is only transferred to third parties within the framework of legal requirements. We only pass on users’ data to third parties if this is necessary, for example, for billing purposes or for other purposes if the transfer is necessary to fulfill contractual obligations to users.
2. If we use subcontractors for our online services, we have taken suitable contractual precautions and appropriate technical and organizational measures vis-à-vis these companies.
3. if we use content, tools or other means from other companies (hereinafter collectively referred to as “third party providers”) and their named registered office is located in a third country, it is to be assumed that a transfer of data to the third party providers’ countries of domicile will take place. The transfer of personal data to third countries by us will only take place if there is an adequate level of data protection, user consent or otherwise legal permission.

2 Processing within the scope of our online offer

2.1 Collection of information on the use of the online offer

1. our online offer is provided by Host Europe GmbH (Friesenplatz 4

50672 Cologne, Germany). The location of the AWS server is Frankfurt.

When using the online offer, information is automatically transmitted to us by the user’s browser; this includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

3. the processing of this information is based on legitimate interests pursuant to Article 6 paragraph (1) lit. f GDPR (e.g. optimization of the online offer) as well as to ensure the security of the processing pursuant to Article 5 paragraph (1) lit. f GDPR (e.g. for defense and reconnaissance of cyber attacks).

4. the information is automatically deleted 7 days after the end of the connection – i.e. use of the online offer – provided that no other retention periods conflict with this.

The collection of the data and the storage of the data in log files is absolutely necessary for the provision of the online offer. Therefore, there is no deletion, objection or correction option on the part of the user.

2.2 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 ads that are relevant to you. In the process, a pseudonymous identification number (ID) is assigned to your browser in order to check which ads were displayed in your browser and which ads were called up. The cookies do not contain any personal information. The use of DoubleClick cookies only enables Google and its partner websites to serve ads based on previous visits to our website or other websites on the Internet. The information generated by the cookies is transferred by Google to a server in the USA for evaluation and stored there. Under no circumstances will Google combine their 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

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 and for the purposes set out above.

2.3 Facebook Pixel (Facebook Custom Audience)

1. we use Facebook Website Custom Audiences on our website and have integrated the so-called Facebook Pixel.

2. this pixel is used to collect pseudonymous information about the use of this website (e.g. information about viewed content). The transmitted data of the pixel can be used to address you with individualized advertising on Facebook, provided you have a Facebook account.
   
   
3. For more information on the scope and purpose of data collection, please refer to Facebook’s privacy policy at https://de-de.facebook.com/privacy/explanation. You can deactivate the data collection at any time under the following link: https://de-de.facebook.com/help/769828729705201/.

4. the legal basis for the processing is your consent pursuant to Article 6 (1) (a) GDPR.

2.4 Google AdServices

1. this website uses the remarketing or “like audience” feature of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”).

2. you can be targeted with advertising by placing personalized and interest-based ads when you visit other websites in the so-called “Google Display Network”. “Google Remarketing” or the “Similar Target Groups” function uses so-called “cookies”, text files that are stored on your computer and enable an analysis of your use of the website. These text files are used to record your visits and anonymous data about the use of the website. Personal data is not stored. If you visit another website in the so-called “Google Display Network”, you may be shown ads that relate to the product and information areas previously accessed on our website.

3. Google’s privacy policy on remarketing with further information can be found here: http://www.google.com/privacy/ads/.

4. the legal basis for the processing is your consent pursuant to Article 6 (1) (a) GDPR.

2.5 Google AdWords Conversion

1. this website uses the “Google AdWords Conversion Tracking” function of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”).

2. Google AdWords Conversion Tracking uses so-called “cookies”, text files that are stored on your computer and allow an analysis of your use of the website when you click on a Google ad. Personal data is not stored in the process. As long as the cookie is valid, Google and we as the website operator can recognize that you have clicked on an ad and reached a certain target page (e.g. order confirmation page, newsletter registration). These cookies cannot be tracked across multiple websites by different AdWords participants. The cookie creates conversion statistics in “Google AdWords”. These statistics record the number of users who clicked on one of our ads. They also count how many users reached a landing page that was tagged with a “conversion tag”. However, the statistics do not contain any data with which you can be identified.

3. for more information about how Google uses conversion data and about Google’s privacy policy, click here: https://support.google.com/adwords/answer/93148?ctx=tltp http://www.google.de/policies/privacy/

4. the legal basis for the processing is your consent pursuant to Article 6 (1) (a) GDPR.

2.6 Google Analytics

1. we use Google Analytics, a web analytics service provided by Google Ireland Limited (Gordon House Barclays Dublin Ireland – hereinafter “Google”), on the basis of your consent for the analysis, optimization and economic operation of our online offer pursuant to Article 6 (1) (a) GDPR. Google uses cookies and other technologies. The information generated by the service about the use of the online offer by users is transmitted to a Google server in the USA and processed there.

2. Google acts on our behalf within the scope of commissioned processing pursuant to Article 28 GDPR. We have concluded a data protection agreement with Google that includes the EU standard data protection clauses.

3. we use Google Analytics with IP anonymization enabled.

4. Google Analytics stores cookies in your web browser for a period of two years since your last visit. These cookies contain a randomly generated user ID that can be used to recognize you on future visits to the website. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of data generated by the cookie and related to their use of the online offer to Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/¬dlpage/gaoptout?hl=en.

5. the collected data is stored together with the randomly generated user ID, which enables the evaluation of pseudonymous user profiles. This user-related data is automatically deleted after 26 months. Other data remains stored in aggregated form indefinitely.

6. For more information about Google’s data use, settings and revocation options, please visit Google’s websites: https://policies.google.com/technologies/partner-sites?hl=de (“Data use by Google when you use our partners’ websites or apps”). https://policies.google.com/technologies/ads (“Data use for advertising purposes”) https://adssettings.google.com/¬authenticated (“Managing information Google uses to serve ads to you”).

2.7 Google Fonts

1. to make the visit to our website attractive, we use fonts from Google, the so-called Google Fonts.

2. we have embedded the Google fonts locally, i.e. on our web server. This means that there is no connection to Google servers and thus no transmission of your data to Google.

2.8 Google Tag Manager

1. this website uses Google Tag Manager. This service enables the management of website tags via an interface. Google Tool Manager only implements tags, does not set cookies and does not collect personal data. The Google Tag Manager triggers other tags that may collect personal data. However, Google Tag Manager does not access this data.

2. if the deactivation is done at domain or cookie level, it remains valid for all tracking tags implemented with Google Tag Manager.

3. the use of Google Tag Manager is based on our legitimate interests pursuant to Article 6 (1) (f) GDPR. We are interested in an efficient and simple provision of our services.

2.9 Links to other websites

1. while using some of our services (e.g. in the “projects” section) you will also be automatically redirected to other websites.

2. please note that this privacy policy is not valid there. The privacy policy of the linked website may differ significantly from this one.

3 Processing for the purpose of carrying out our business processes

3.1 Contact form and contact by e-mail

1. when contacting us (via online form or e-mail), the data provided by the user will be processed exclusively for the purpose of handling the request and its processing.

2. any other use of the data shall only take place on the basis of the user’s consent.

3. user data is stored in our customer relationship management system (“CRM system”). The statutory retention periods for business letters apply.

3.2 Direct marketing

1. if you have given us your consent, we will inform you regularly by e-mail, phone or SMS about us, new offers. We use your name, email address and telephone number for this purpose. The legal basis for data processing is Art. 6 para. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future.

2. the dispatch of our newsletter by e-mail is only carried out with your prior express consent according to the double opt-in principle: after registering for the newsletter on our website, you will receive an e-mail asking you to confirm your newsletter registration. This ensures that no third party has misused your data. If no confirmation is received within 48 hours of receipt of the confirmation email, we will delete your contact details. If you withdraw your consent, your email address will be deleted from our newsletter distribution list.

By subscribing to the newsletter, you also consent to newsletter tracking for the purpose of personalized advertising and market research by us. With the help of so-called tracking pixels or web beacons and links, each of which is linked to an individual ID, we collect the following personal tracking information in connection with the use of our newsletter:

– Opening the newsletter, clicking on the links contained therein, submitting a form on our website after clicking on a link contained in the newsletter (along with the time of these actions).

– Type of terminal device used when you access images in the newsletter or click on links

– Behavior on our website when you access it via a link from our newsletter (along with the time of these actions)

– Location of retrieval, if you retrieve images in the newsletter or click on links (by means of assignment of your IP address, which we do not store, however)

We save this data to your user profile, which is assigned to the data you entered when you registered for the newsletter. We use this data to evaluate and optimize our e-mail marketing and for purposes of personalized advertising and market research. This enables us to send you personalized product, service and offer information that is of particular interest to you as part of our newsletter. You can revoke your consent to this data processing at any time with future effect by unsubscribing from the newsletter. We delete the tracking data when you unsubscribe from our newsletter. Data that has been stored by us for other purposes remains unaffected by this.

For the sending and evaluation of the emails, we use MailChimp, a service of the provider Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA (“MailChimp”). The data processed when sending and evaluating the emails is stored on MailChimp’s servers in the USA. MailChimp acts as a processor for us within the meaning of Art. 4 No. 8 GDPR.

If you unsubscribe from our newsletter, your data (including tracking data) will be deleted from MailChimp’s servers.

For more information, please refer to the privacy policy of MailChimp (https://mailchimp.com/legal/privacy/).

3.3 Canvassing existing customers

1. insofar as you have already used services from us against payment, we may inform you from time to time by e-mail or letter about similar services from us, if you have not objected to this.

The legal basis for the data processing is Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in direct advertising (recital 47 GDPR). You can object to the use of your e-mail address and postal address for advertising purposes at any time without additional costs with effect for the future.

4 Cookie policy

4.1 General information

1. cookies are information that is transmitted from our web server or third-party web servers to users’ web browsers and stored there for later retrieval. Cookies may be small files or other types of information storage.

2. if users do not want cookies to be stored on their computer, they are asked to disable the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies may lead to functional restrictions of this online offer.

4.2 Cookie overview

An overview of the cookies used can be found in our Cookie Policy.

4.3 Possibilities of objection

You can manage your cookie settings via our Cookie Policy.

5 Changes to the privacy policy

1. we reserve the right to change this data protection declaration with regard to data processing in order to adapt it to changed legal situations, to changes in the online offer or to data processing.

2. insofar as user consent is required or components of the data protection declaration contain provisions of the contractual relationship with the users, the changes shall only be made with the consent of the users.

3. users are requested to inform themselves regularly about the content of this privacy policy.
   
   

Status: June 2023