Privacy Policy

This data protection declaration informs you about the nature, scope, and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the websites, functions, and content associated with it, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”). With regard to the terms used, such as “processing” or “controller,” we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Responsible

Nick Strøger
79100 Freiburg im Breisgau
E-mail: info(at)nickstroeger.com
Imprint: nickstroeger.com/imprint/

Types of Data Processed

Inventory data (e.g., names, addresses)
Contact data (e.g., email, phone numbers)
Content data (e.g., text input, photographs, videos)
Usage data (e.g., web pages 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 offer (hereinafter, referred to collectively as “users”).

Purpose of Processing

Provision of the online offer, its functions, and content
Answering contact requests and communication with users
Security measures
Reach measurement/marketing

Terminology Used

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, online identifier (e.g., cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

“Processing” means any operation or set of operations performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data.

“Pseudonymization” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

“Profiling” means any automated processing of personal data used to evaluate certain personal aspects relating to a natural person, particularly to analyze or predict aspects concerning that person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

“Controller” means the natural or legal person, public authority, agency, or other body which alone or jointly with others determines the purposes and means of processing personal data.

“Processor” means a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller.

Relevant Legal Basis

In accordance with Article 13 of the GDPR, we inform you of the legal basis for the data processing activities on this website. If the legal basis is not explicitly mentioned in the privacy statement, the following applies: The legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 GDPR; the legal basis for processing to fulfill the website’s services and carry out contractual measures and respond to inquiries is Art. 6(1)(b) GDPR; the legal basis for processing to fulfill legal obligations is Art. 6(1)(c) GDPR; and the legal basis for processing to protect the legitimate interests of this website is Art. 6(1)(f) GDPR. In cases where vital interests of the data subject or another natural person require the processing of personal data, the legal basis is Art. 6(1)(d) GDPR.

Security Measures

This website takes appropriate technical and organizational measures in accordance with Art. 32 GDPR, considering the state of the art, the implementation costs, and the nature, scope, circumstances, and purposes of the processing, as well as the varying likelihood and severity of risk to the rights and freedoms of natural persons, to ensure a level of protection appropriate to the risk.

These measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as access to, entry into, disclosure of, ensuring the availability of, and separation of data. Furthermore, procedures have been established to ensure the exercise of data subjects’ rights, the deletion of data, and responses to data compromises. Additionally, this website considers the protection of personal data during the development or selection of hardware, software, and processes, in accordance with the principle of data protection through technology design and data protection-friendly default settings (Article 25 of the GDPR).

Cooperation with Processors and Third Parties

If, during the processing of data, this website discloses data to other persons and companies (order processors or third parties), transmits it to them, or otherwise grants them access to the data, this will only occur on the basis of a legal permission (e.g., if the transmission of the data to third parties, such as payment service providers, is necessary for the performance of a contract pursuant to Art. 6(1)(b) GDPR), if you have consented, if a legal obligation provides for this, or based on the legitimate interests of this website (e.g., when using agents, web hosts, etc.).

If third parties are commissioned to process data on the basis of a so-called “order processing agreement,” this is done on the basis of Art. 28 GDPR.

Transfers to Third Countries

If this website processes data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of using third-party services or disclosing or transferring data to third parties, this will only happen if it is done to fulfill (pre)contractual obligations, based on your consent, due to a legal obligation, or based on the legitimate interests of this website. Subject to legal or contractual permissions, data is processed or allowed to be processed in a third country only if the special requirements of Art. 44 et seq. GDPR are met. This means, for example, that the processing is carried out based on special guarantees, such as the officially recognized determination of a data protection level corresponding to that of the EU (e.g., for the USA by the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).

Rights of Data Subjects

You have the right to request confirmation as to whether data concerning you is being processed and to information about this data, as well as further information and a copy of the data in accordance with Art. 15 GDPR.

You have the right, in accordance with Art. 16 GDPR, to request the completion of data concerning you or the correction of inaccurate data concerning you.

In accordance with Art. 17 GDPR, you have the right to request the deletion of data concerning you without undue delay, or alternatively, in accordance with Art. 18 GDPR, to request the restriction of the processing of data.

You have the right to request that the data concerning you, which you have provided to this website, be received in accordance with Art. 20 GDPR and to request that it be transferred to other data controllers.

You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 GDPR.

Right of Withdrawal

You have the right to revoke any consent given in accordance with Art. 7(3) GDPR with effect for the future.

Right to Object

You may object to the future processing of data concerning you at any time in accordance with Art. 21 GDPR. The objection can be made, in particular, against processing for direct marketing purposes.

Cookies and Right to Object in Direct Advertising

“Cookies” are small files stored on users’ computers. Various data can be stored within the cookies. The primary purpose of a cookie is to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies,” are cookies that are deleted after a user leaves an online offer and closes their browser. Such a cookie may store, for example, the contents of a shopping cart in an online store or a login status. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent.” For example, the login status can be stored if users revisit the website after several days. Likewise, the interests of users can be stored in such a cookie, which is used for range measurement or marketing purposes. “Third-party cookies” are cookies offered by providers other than the website operator. Otherwise, if they are only this website’s cookies, they are referred to as “first-party cookies.”

This website may use temporary and permanent cookies and provides information about this in the privacy policy.

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

A general objection to the use of cookies for online marketing purposes can be declared for a large number of the services, especially in the case of tracking, via the U.S. site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be prevented by disabling them in the browser settings. Please note that in this case, not all functions of this online offer can be used.

Deletion of Data

The data processed by this website will be deleted or restricted in its processing in accordance with Articles 17 and 18 GDPR. Unless expressly stated within the scope of this privacy policy, the data stored by this website will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.

According to legal requirements in Germany, data is stored for 10 years in accordance with §§ 147 para. 1 AO, 257 para. 1 nos. 1 and 4, para. 4 HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.) and for 6 years according to § 257 para. 1 nos. 2 and 3, para. 4 HGB (commercial letters).

According to legal requirements in Austria, storage is carried out, in particular, for 7 years in accordance with § 132 para. 1 BAO (accounting records, vouchers/invoices, accounts, receipts, business papers, statement of income and expenditure, etc.), for 22 years in connection with real estate, and for 10 years for documents in connection with electronically provided services, telecommunications, radio, and television services provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.

Business-Related Processing

Additionally, this website processes contract data (e.g., subject matter of contract, term, customer category) and payment data (e.g., bank details, payment history) from customers, prospective customers, and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising, and market research.

Agency Services

This website processes the data of customers within the scope of contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services, and training services.

In this context, this website processes inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., email, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of contract, term), payment data (e.g., bank details, payment history), usage data, and metadata (e.g., in the context of evaluating and measuring the success of marketing measures). Special categories of personal data are not processed unless these are components of commissioned processing. Data subjects include customers, prospective customers, as well as their customers, users, website visitors, or employees and third parties. The purpose of processing is the provision of contractual services, billing, and customer service. The legal basis for processing results from Art. 6 para. 1 lit. b GDPR (contractual services) and Art. 6 para. 1 lit. f GDPR (analysis, statistics, optimization, security measures). The necessity of providing this data is pointed out, and its disclosure to external parties only takes place if necessary for fulfilling the order. When processing data provided as part of an order, this website acts in accordance with the client’s instructions and legal requirements of contract processing pursuant to Art. 28 GDPR and does not process the data for any other purposes than those specified in the order.

Data is deleted after the expiration of legal warranty and comparable obligations. The necessity of keeping the data is reviewed every three years; in the case of legal archiving obligations, deletion takes place after their expiration (6 years, according to § 257 para. 1 HGB, 10 years, according to § 147 para. 1 AO). Data disclosed by the client as part of an order is deleted in accordance with the specifications of the order, generally after the end of the order.

Administration, Financial Accounting, Office Organization, Contact Management

This website processes data in the context of administrative tasks, business organization, financial accounting, and compliance with legal obligations, such as archiving. In this regard, the same data is processed as during the provision of contractual services. The processing bases are Art. 6 para. 1 lit. c GDPR and Art. 6 para. 1 lit. f GDPR. Customers, interested parties, business partners, and website visitors are affected by the processing. The purpose and interest in processing lies in the administration, financial accounting, office organization, archiving of data, i.e., tasks that serve the maintenance of business activities, performance of tasks, and provision of services. The deletion of data with regard to contractual services and contractual communication corresponds to the information mentioned in these processing activities.

In this context, data may be disclosed or transferred to tax authorities, consultants, such as tax advisors or auditors, as well as other fee offices and payment service providers.

Furthermore, based on business interests, information on suppliers, event organizers, and other business partners is stored, e.g., for future contact. This data, most of which is company-related, is generally stored permanently.

Business Analyses and Market Research

In order to operate this website economically and to be able to recognize market trends and the wishes of contractual partners and users, data on business transactions, contracts, inquiries, etc., is analyzed. This website processes inventory data, communication data, contract data, payment data, usage data, and metadata on the basis of Art. 6 para. 1 lit. f GDPR, whereby the data subjects include contractual partners, interested parties, customers, visitors, and users of this online offer.

The analyses are carried out for the purpose of business evaluations, marketing, and market research. In doing so, profiles of registered users with details, for example, of the services they have used, may be considered. The analyses serve to increase user-friendliness, optimize the online offer, and manage the business. The analyses are solely for internal use and are not disclosed externally unless they are anonymous analyses with aggregated values.

If these analyses or profiles are personal, they are deleted or anonymized upon termination of the user, or after two years from the conclusion of the contract. Otherwise, overall business analyses and general trend analyses are created anonymously wherever possible.

Google Tag Manager

Google Tag Manager is a solution that allows the management of so-called website tags via an interface (and thus, for example, the integration of Google Analytics and other Google marketing services into this online offer). The Tag Manager itself (which implements the tags) does not process any personal data of users. Regarding the processing of users’ personal data, please refer to the following information on Google services. Usage Policy: https://www.google.com/intl/de/tagmanager/use-policy.html.

Google Analytics

Based on the legitimate interests of this website (i.e., interest in the analysis, optimization, and economic operation of this online offer within the meaning of Art. 6 para. 1 lit. f GDPR), Google Analytics, a web analytics service provided by Google LLC (“Google”) is used. Google uses cookies. The information generated by the cookie about the use of the online offer by users is usually transmitted to a Google server in the USA and stored there.

Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google will use this information on behalf of the website operator to evaluate your use of the website, compile reports on website activity for the website operator, and provide other services related to website activity and internet usage. Pseudonymous usage profiles of the users may be created from the processed data.

This website only uses Google Analytics with IP anonymization activated. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.

The IP address transmitted by the user’s browser is not merged with other data from Google. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of the 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: http://tools.google.com/dlpage/gaoptout?hl=de.

For more information on data usage by Google, setting, and objection options, please refer to Google’s privacy policy (https://policies.google.com/technologies/ads) as well as the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

The users’ personal data is deleted or anonymized after 14 months.

Target Group Formation with Google Analytics

This website uses Google Analytics to display ads placed by Google and its partners only to those users who have also shown an interest in this online offer or who have certain characteristics (e.g., interests in certain topics or products determined on the basis of the websites visited), which are transmitted to Google (so-called “Remarketing Audiences,” or “Google Analytics Audiences”). With the help of Remarketing Audiences, this website also aims to ensure that ads correspond to the potential interest of users.

Google AdWords and Conversion Measurement

Based on the legitimate interests of this website (i.e., interest in the analysis, optimization, and economic operation of this online offering within the meaning of Art. 6(1)(f) GDPR), the services of Google AdWords are used. Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”) provides these services.

This website uses the online marketing method Google “AdWords” to place ads in the Google advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. This allows ads to be displayed more accurately to users who have shown an interest in the website’s offerings. If a user is shown ads for products they have shown interest in on other online offers, this is referred to as “remarketing.” When visiting the website and other websites on which the Google advertising network is active, a code is executed directly by Google and (re)marketing tags (invisible graphics or code, also referred to as “web beacons”) are integrated into the website. With their help, a unique cookie, i.e., a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). This file records the websites visited by the user, the content they are interested in, and the offers clicked on, as well as technical information about the browser and operating system, referring web pages, time of visit, and other information about the use of the online offer.

Furthermore, an individual “conversion cookie” is stored. The information obtained with the help of the cookie is used by Google to create conversion statistics for the website operator. However, only the anonymous total number of users who clicked on an ad and were redirected to a page tagged with a conversion tracking tag is revealed. No personal information identifying users is provided.

The users’ data is processed pseudonymously within the Google advertising network. Google does not store and process names or email addresses, but rather processes the relevant data cookie-related within pseudonymous user profiles. From Google’s perspective, ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has explicitly allowed Google to process the data without this pseudonymization. The information collected about users is transmitted to Google and stored on Google’s servers in the USA.

For more information about Google’s use of data, settings, and opt-out options, please refer to Google’s privacy policy (https://policies.google.com/technologies/ads) and the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

Integration of Third-Party Services and Content

Within this online offer, content or service providers are used based on the legitimate interests of the website operator (i.e., interest in the analysis, optimization, and economic operation of this online offer within the meaning of Art. 6 para. 1 lit. f GDPR) to integrate content or services offered by third-party providers, such as videos or fonts (hereinafter uniformly referred to as “content”).

This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they could not send the content to the user’s browser. The IP address is thus necessary for the display of this content. The website operator endeavors to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit, and other information about the use of this online offer, as well as be combined with such information from other sources.

Google Fonts

This website integrates fonts (“Google Fonts”) from the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.