Privacy Policy

This privacy policy explains the nature, scope and purpose of the processing of personal data (hereinafter referred to as ‘data’) in the context of the provision of our services and within our online offering and the associated websites, functions and content, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as ‘online offering’). With regard to the terms used, such as ‘processing’ or ‘controller’, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Types of data processed

– Inventory data (e.g., personal master data, names or addresses).
– Contact details (e.g., email, telephone numbers).
– Content data (e.g., text entries, photographs, videos).
– Usage data (e.g., websites visited, interest in content, access times).
– Meta/communication data (e.g., device information, IP addresses).

Categories of data subjects

Visitors and users of the online offering (hereinafter, we also refer to the persons concerned collectively as ‘users’).

Purpose of processing

– Provision of the online offering, its functions and content.
– Responding to contact requests and communicating with users.
– Security measures.
– Reach measurement/marketing.

Terms used

‘Personal data’ means any information relating to an identified or identifiable natural person (hereinafter referred to as ‘data subject’); A natural person is considered identifiable if they can be identified, directly or indirectly, in particular by association with an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or one or more special characteristics that express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

‘Processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers virtually any handling of data.

‘Pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

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

The ‘controller’ is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

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

Relevant legal bases

In accordance with Art. 13 GDPR, we hereby inform you of the legal basis for our data processing. For users within the scope of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, the following applies if the legal basis is not specified in the privacy policy:
The legal basis for obtaining consent is Art. 6 (1) (a) and Art. 7 GDPR;
The legal basis for processing for the fulfilment of our services and the implementation of contractual measures as well as responding to enquiries is Art. 6 (1) (b) GDPR;
The legal basis for processing to fulfil our legal obligations is Art. 6(1)(c) GDPR;
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6(1)(d) GDPR serves as the legal basis.
The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Art. 6 para. 1 lit. e GDPR.

The legal basis for processing to safeguard our legitimate interests is Article 6(1)(f) GDPR.
The processing of data for purposes other than those for which it was collected is determined by the provisions of Art. 6(4) GDPR.
The processing of special categories of data (in accordance with Art. 9(1) GDPR) is determined by the provisions of Art. 9(2) GDPR.

Safety measures

We are committed to the security of personal data. We take appropriate security measures to limit the misuse of and unauthorised access to personal data. This ensures that only the necessary persons have access to your data, that access to the data is protected and that our security measures are regularly reviewed.

The security measures we use include the following:

Vulnerability detection

HTTP Strict Transport Security and associated security headers

TLS / SSL

Recommended page reinforcement features

Cooperation with processors, joint controllers and third parties

If, in the course of our processing, we disclose data to other persons and companies (processors, joint controllers or third parties), transfer it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if the transfer of data to third parties, such as payment service providers, is necessary for the fulfilment of a contract), if users have given their consent, if a legal obligation requires it, or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we disclose data to other companies in our group, transfer it to them or otherwise grant them access to it, this is done in particular for administrative purposes as a legitimate interest and, beyond that, on a basis that complies with legal requirements.

Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this occurs in the context of using third-party services or disclosing or transferring data to other persons or companies, this will only take place if it is necessary for the fulfilment of our (pre)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or allow the data to be processed in a third country if the legal requirements are met. This means that processing is carried out, for example, on the basis of special guarantees, such as the officially recognised determination of a level of data protection equivalent to that of the EU (e.g. for the USA through the ‘Privacy Shield’) or the observance of officially recognised special contractual obligations.

Use of cookies

We use the consent tool ‘Real Cookie Banner’ to manage the cookies and similar technologies (tracking pixels, web beacons, etc.) we use and the related consents. Details on how ‘Real Cookie Banner’ works can be found at https://devowl.io/de/rcb/datenverarbeitung/.

The legal basis for the processing of personal data in this context is Art. 6(1)(c) GDPR and Art. 6(1)(f) GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.

The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide personal data. If you do not provide personal data, we cannot manage your consents.

Rights of data subjects

You have the right to request confirmation whether relevant data is being processed and to obtain information about this data, as well as further information and a copy of the data in accordance with legal requirements. In accordance with legal requirements, you have the right to request the completion of data concerning you or the correction of inaccurate data concerning you. In accordance with legal requirements, you have the right to request that the data in question be deleted immediately or, alternatively, in accordance with legal requirements, to request a restriction on the processing of the data. You have the right to request that the data concerning you that you have provided to us be retained in accordance with legal requirements and that its transfer to other controllers be requested. You also have the right, in accordance with legal requirements, to lodge a complaint with the competent supervisory authority.

Right of withdrawal

You have the right to revoke any consent you have given with effect for the future.

Right of objection

You may object to the future processing of data concerning you at any time in accordance with the statutory provisions. In particular, you may object to the processing of data for direct marketing purposes.

Deletion of data

The data we process will be deleted or restricted in its processing in accordance with legal requirements. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and there are no legal retention obligations preventing its deletion.

If the data is not deleted because it is required for other, legally permissible purposes, its processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

Provision of our statutory and business services

We process the data of our members, supporters, interested parties, customers or other persons in accordance with Art. 6 (1) lit. b. GDPR, insofar as we offer them contractual services or act within the framework of existing business relationships, e.g. towards members, or are ourselves recipients of services and benefits. In all other cases, we process the data of data subjects in accordance with Art. 6(1)(f) GDPR on the basis of our legitimate interests, e.g. in the case of administrative tasks or public relations work.

The data processed in this context, the type, scope and purpose of the processing and the necessity of the processing are determined by the underlying contractual relationship. This generally includes inventory and master data of individuals (e.g. name, address, etc.), as well as contact details (e.g. email address, telephone number, etc.), contract data (e.g. services used, content and information communicated, names of contact persons) and, if we offer services or products that are subject to payment, payment data (e.g. bank details, payment history, etc.).

We delete data that is no longer required for the fulfilment of our statutory and business purposes. This is determined in accordance with the respective tasks and contractual relationships. In the case of business processing, we store the data for as long as it may be relevant for business transactions and with regard to any warranty or liability obligations. The necessity of storing the data is reviewed every three years; otherwise, the statutory retention obligations apply.

Posts remain visible after the account has been deleted and are marked as ‘guest’. A separate notification is required to delete the posts.

IP addresses are stored to protect the forum from misuse.

Users suspected of spam are initially blocked. They can be reactivated by notifying the administrator.

Online presence on social media

We maintain online presences within social networks and platforms in order to communicate with customers, interested parties and users who are active there and to inform them about our services.

We would like to point out that user data may be processed outside the European Union. This may pose risks for users, as it could make it more difficult for them to enforce their rights, for example. With regard to US providers certified under the Privacy Shield, we would like to point out that they are committed to complying with EU data protection standards.

Furthermore, user data is generally processed for market research and advertising purposes. For example, usage profiles can be created based on user behaviour and the resulting interests. The usage profiles can in turn be used, for example, to place advertisements within and outside the platforms that are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on users’ computers, in which the usage behaviour and interests of users are stored. Furthermore, data independent of the devices used by users can also be stored in the usage profiles (especially if users are members of the respective platforms and are logged in to them).

The processing of users’ personal data is based on our legitimate interests in effectively informing users and communicating with them in accordance with Art. 6(1)(f) GDPR. If users are asked by the respective providers to consent to data processing (i.e. to declare their consent, e.g. by ticking a checkbox or confirming a button), the legal basis for processing is Art. 6 para. 1 lit. a, Art. 7 GDPR.

For a detailed description of the respective processing operations and the options for objection (opt-out), we refer to the information provided by the providers linked below.

In the case of requests for information and the assertion of user rights, we would also like to point out that these can be most effectively asserted with the providers. Only the providers have access to the user data and can take appropriate measures and provide information directly. However, if you still require assistance, please contact us.

– Google/YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – Privacy policy:

https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.

– Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) – Privacy policy: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.

Twitter

Our online offering may incorporate functions and content from the Twitter service, provided by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. This may include content such as images, videos or text and buttons that allow users to share content from this online offering on Twitter.
If users are members of the Twitter platform, Twitter can assign the access to the above-mentioned content and functions to the users’ profiles there. Twitter is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law. (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active). Privacy policy: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization.

Contact

When contacting us (e.g. by email or via social media), the user’s details are processed for the purpose of handling the contact request and its processing in accordance with Art. 6(1)(b) (within the framework of contractual/pre-contractual relationships) and Art. 6(1)(f) (other enquiries) of the GDPR. The user’s details may be stored in a customer relationship management system (‘CRM system’) or comparable enquiry organisation system.

We delete the enquiries if they are no longer required. We review the necessity every two years; furthermore, the statutory archiving obligations apply.

Hosting and email delivery

The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, email delivery, security services and technical maintenance services, which we use for the purpose of operating this online offering.

In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online service on the basis of our legitimate interests in the efficient and secure provision of this online service in accordance with Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of a data processing agreement).

Collection of access data and log files

We, or our hosting provider, collect data about every access to the server on which this service is located (so-called server log files) on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR. The access data includes the name of the website accessed, the file, the date and time of access, the 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.

Log file information is stored for security reasons (e.g. to investigate misuse or fraud) for a maximum of 35 days and then deleted. Data that needs to be retained for evidence purposes is excluded from deletion until the respective incident has been finally clarified.

Changes and updates to the privacy policy

We ask that you regularly review the content of our privacy policy. We will amend the privacy policy as soon as changes to our data processing practices make this necessary. You will be informed as soon as the changes require action on your part (e.g. consent) or other individual notification.