Privacy policy

We hereby inform you in accordance with the legal requirements of data protection law (especially in accordance with the BDSG n.F. and the European General Data Protection Regulation ‘GDPR’) about the nature, scope, and purpose of the processing of personal data by our company. This privacy policy also applies to our websites and social media profiles. With regard to the definition of terms such as “personal data” or “processing,” we refer to Art. 4 GDPR.

Name and contact details of the data controller

Our data controller (hereinafter “controller”) within the meaning of Art. 4 para. 7 GDPR is:

Tobias Wintrich
Am Ginsterberg 48
52477, Alsdorf, Deutschland
E-Mail:

Types of data, purposes of processing, and categories of data subjects

Below, we inform you about the type, scope, and purpose of the collection, processing, and use of personal data.

1. Types of data we process

Contact details (phone number, email, fax, etc.), Content data (text inputs, videos, photos, etc.), Communication data (IP address, etc.),

2. Purposes of processing under Art. 13 para. 1 c) GDPR

Evidence purposes / securing evidence, Optimizing the website technically and economically, Facilitating easy access to the website, Contacting in case of legal objections by third parties, Optimizing and statistical evaluation of our services, Improving user experience, Making the website user-friendly, Economic operation of advertising and website, Marketing / Sales / Advertising, Creating statistics, Avoiding SPAM and abuse, Handling contact inquiries, Providing websites with functions and content, Security measures, Uninterrupted, secure operation of our website

3. Categories of data subjects under Art. 13 para. 1 e) GDPR

Visitors/Users of the website
The data subjects are collectively referred to as “users.”

Legal bases for the processing of personal data

Below we inform you about the legal bases for the processing of personal data:

  1. If we have obtained your consent for the processing of personal data, Art. 6 para. 1 sentence 1 lit. a) GDPR is the legal basis.
  2. If the processing is necessary for the performance of a contract or for the implementation of pre-contractual measures requested by you, Art. 6 para. 1 sentence 1 lit. b) GDPR is the legal basis.
  3. If the processing is necessary for compliance with a legal obligation to which we are subject (e.g., legal retention obligations), Art. 6 para. 1 sentence 1 lit. c) GDPR is the legal basis.
  4. If the processing is necessary to protect vital interests of the data subject or another natural person, Art. 6 para. 1 sentence 1 lit. d) GDPR is the legal basis.
  5. If the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, Art. 6 para. 1 sentence 1 lit. f) GDPR is the legal basis.

Disclosure of personal data to third parties and processors

Without your consent, we generally do not disclose data to third parties. If this should nevertheless occur, the disclosure is based on the legal bases mentioned above, e.g., when data is disclosed to online payment providers for contract fulfillment or based on a court order or due to a legal obligation to release data for the purpose of law enforcement, threat prevention, or enforcement of intellectual property rights.
We also use processors (external service providers e.g., for web hosting our websites and databases) to process your data. If data is passed on to processors as part of an agreement for order processing, this is done in accordance with Art. 28 GDPR. We carefully select our processors, regularly monitor them, and have granted them the right to issue instructions regarding data. In addition, the processors must have taken appropriate technical and organizational measures and comply with data protection regulations pursuant to the BDSG n.F. and GDPR.

Transfer of data to third countries

The European General Data Protection Regulation (GDPR) has created a uniform basis for data protection in Europe. Therefore, your data is primarily processed by companies to which the GDPR applies. If processing is carried out by third-party services outside the European Union or the European Economic Area, they must comply with the special requirements of Articles 44 et seq. GDPR. This means that processing is based on special guarantees, such as an EU Commission’s officially recognized determination of a level of data protection equivalent to that in the EU or compliance with officially recognized specific contractual obligations, the so-called “standard contractual clauses.”
To the extent that, due to the ineffectiveness of the so-called “Privacy Shield,” we obtain your explicit consent pursuant to Art. 49 para. 1 sentence 1 lit. a) GDPR for the transfer of data to the USA, we will inform you about the risk of secret access by US authorities and the use of data for monitoring purposes, possibly without legal recourse for EU citizens.

Deletion of data and storage period

Unless expressly stated in this privacy policy, your personal data will be deleted or blocked as soon as the consent given for processing is revoked or the purpose of storage no longer applies or the data is no longer required for the purpose, unless further storage is required for evidentiary purposes or statutory retention obligations prevent deletion. This includes, for example, commercial retention obligations for business letters according to § 257 para. 1 HGB (6 years) as well as tax retention obligations for documents according to § 147 para. 1 AO (10 years). When the prescribed retention period expires, your data will be blocked or deleted unless storage is still necessary for contract conclusion or contract fulfillment.

Existence of automated decision-making

We do not use automated decision-making or profiling.

Provision of our website and creation of log files

  1. If you merely use our website for informational purposes (i.e., no registration and no other transmission of information), we only collect the personal data that your browser sends to our server. If you want to view our website, we collect the following data:
    • IP address;
    • User’s internet service provider;
    • Date and time of access;
    • Browser type;
    • Language and browser version;
    • Content of the request;
    • Time zone;
    • Access status/HTTP status code;
    • Data volume;
    • Websites from which the request comes;
    • Operating system.
      This data is not stored together with other personal data about you.
  2. This data serves the purpose of delivering our website to you in a user-friendly, functional, and secure manner with features and content, as well as its optimization and statistical evaluation.
  3. The legal basis for this is our legitimate interest in data processing for the above purposes pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR.
  4. For security reasons, we store this data in server log files for a storage period of 70 days. After this period, it will be automatically deleted unless we need to retain it for evidentiary purposes in the event of attacks on the server infrastructure or other infringements of the law.

Cookies

  1. We use so-called cookies when you visit our website. Cookies are small text files that your internet browser stores on your computer. When you revisit our website, these cookies provide information to automatically recognize you. Cookies also include so-called “user IDs,” where user information is stored using pseudonymized profiles. We inform you about the use of cookies for the purposes mentioned above and how you can object to them or prevent their storage (“opt-out”) when you visit our website by displaying a notice in our privacy policy.
    The following types of cookies are distinguished:
    • Necessary, essential cookies: Essential cookies are cookies that are absolutely necessary for the operation of the website, to store certain functions of the website such as logins, shopping carts, or user inputs regarding the language of the website.
    • Session cookies: Session cookies are required to recognize multiple uses of an offer by the same user (e.g., if you have logged in to determine your login status). When you revisit our site, these cookies provide information to automatically recognize you. The information obtained in this way serves to optimize our offers and to provide you with easier access to our site. When you close the browser or log out, the session cookies are deleted.
    • Persistent cookies: These cookies remain stored even after the browser is closed. They are used to store login information, measure reach, and for marketing purposes. These are automatically deleted after a specified duration, which may vary depending on the cookie. You can delete the cookies at any time in your browser’s security settings.
    • Third-party cookies (especially from advertisers): According to your preferences, you can configure your browser settings to, for example, reject third-party cookies or all cookies. However, we would like to point out at this point that you may then not be able to use all the functions of this website. For more information about these cookies, please refer to the respective privacy policies of the third-party providers.
  2. Data categories: User data, cookie, user ID (especially the visited pages, device information, access times, and IP addresses).
  3. Purposes of processing: The information obtained in this way is used to optimize our web offerings technically and economically and to provide you with easier and more secure access to our website.
  4. Legal basis: If we process your personal data using cookies based on your consent (“opt-in”), then Art. 6 para. 1 sentence 1 lit. a) GDPR is the legal basis. Otherwise, we have a legitimate interest in the effective functionality, improvement, and economic operation of the website, so in that case, the legal basis is Art. 6 para. 1 sentence 1 lit. f) GDPR. The legal basis is also Art. 6 para. 1 sentence 1 lit. b) GDPR if cookies are used for contract initiation, e.g., for orders.
  5. Storage duration / Deletion: The data will be deleted as soon as they are no longer required to achieve the purpose of their collection. In the case of data collection to provide the website, this is the case when the respective session is ended.

    Cookies are otherwise stored on your computer and transmitted from there to our site. Therefore, as a user, you also have full control over the use of cookies. By changing the settings in your internet browser, you can disable or restrict the transmission of cookies. Already stored cookies can be deleted at any time. This can also be done automatically. If cookies for our website are deactivated, it may no longer be possible to use all functions of the website to their full extent.

    Here you can find information on deleting cookies by browser:
  6. Objection and “Opt-Out”: You can prevent cookies from being stored on your hard drive regardless of consent or legal permission by generally selecting “do not accept cookies” in your browser settings. However, this may result in a functional limitation of our offers. You can object to the use of third-party cookies for advertising purposes via an “opt-out” on this American website (https://optout.aboutads.info) or this European website (http://www.youronlinechoices.com/de/praferenzmanagement/).

Use of blog functions / comments

  1. You can leave public comments in our blog, which contains posts on topics related to our website. You can use a pseudonym instead of your real name. Your contribution will then be published under the pseudonym. Providing an email address is mandatory, all other information is voluntary.
  2. We store your IP address with date and time when you submit a comment, which we delete after 70 days. The storage is for the legitimate interest of defending against third-party claims in case of the publication of unlawful or untrue content by you. We store your email address for the purpose of contacting you if third parties legally challenge your comments.
  3. Legal bases are Art. 6 para. 1 sentence 1 lit. b) and f) GDPR.
  4. We do not review your comments before publication. In case of complaints from third parties, we reserve the right to delete your comments. We do not disclose the data to third parties unless necessary to pursue our claims or there is a legal obligation (Art. 6 para. 1 sentence 1. lit. c) GDPR).
  5. The data will be deleted as soon as they are no longer required to achieve the purpose of their collection or to fulfill the contract because the contract has been terminated.

Contact via Contact Form / Email / Fax / Mail

  1. When you contact us via contact form, fax, mail, or email, your details are processed for the purpose of handling the contact request.
  2. The legal basis for processing the data, if you have given your consent, is Art. 6 para. 1 sentence 1 lit. a) GDPR. The legal basis for processing the data transmitted in the course of a contact request or email, letter, or fax is Art. 6 para. 1 sentence 1 lit. f) GDPR. The controller has a legitimate interest in processing and storing the data to be able to respond to user inquiries, to secure evidence for liability reasons, and to fulfill any legal retention obligations for business letters. If the contact aims at concluding a contract, an additional legal basis for the processing is Art. 6 para. 1 sentence 1 lit. b) GDPR.
  3. We may store your details and contact request in our Customer Relationship Management System (“CRM System”) or a comparable system.
  4. The data will be deleted as soon as they are no longer required to achieve the purpose of their collection. For the personal data from the contact form and those sent by email, this is the case when the respective conversation with you has ended. The conversation is deemed ended when it can be inferred from the circumstances that the matter in question has been finally clarified. We store inquiries from users who have an account or contract with us until two years after the contract has ended. In the case of legal archiving obligations, deletion takes place after their expiry: end of commercial (6 years) and tax (10 years) retention obligations.
  5. You have the option to revoke your consent to the processing of personal data at any time pursuant to Art. 6 para. 1 sentence 1 lit. a) GDPR. If you contact us by email, you can object to the storage of your personal data at any time.

Contact via Phone

  1. When you contact us by phone, your phone number is processed for the purpose of handling the contact request and its processing and temporarily stored or displayed in the RAM/cache of the phone/device/screen. Storage is for liability and security reasons, to provide evidence of the call, and for economic reasons to enable a return call. In the case of unauthorized marketing calls, we block the numbers.
  2. The legal basis for processing the phone number is Art. 6 para. 1 sentence 1 lit. f) GDPR. If the contact aims at concluding a contract, an additional legal basis for the processing is Art. 6 para. 1 lit. b) GDPR.
  3. The device cache stores calls for 70 days and progressively overwrites or deletes old data; when the device is disposed of, all data is deleted, and the memory may be destroyed. Blocked phone numbers are reviewed annually for the need for blocking.
  4. You can prevent the display of your phone number by calling with a suppressed phone number.

Newsletter

  1. You can subscribe to our newsletter with your voluntary consent by entering your email address. Only this is mandatory. Providing additional data is voluntary and serves the purpose of personal address. We use the so-called “Double Opt-in” procedure for registration. After you have registered with your email address, you will receive an email from us to confirm your registration. If you click on this confirmation link, your email will be added to the newsletter distribution list and stored for the purpose of sending emails. If you do not click on the confirmation link within 24 hours, your registration data will be blocked and automatically deleted after 30 days.
  2. In addition, we log your IP address used during registration as well as the date and time of the double opt-in (registration and confirmation). The purpose of this storage is to meet legal requirements regarding the proof of your registration and to prevent abuse of your email.
  3. As part of your consent declaration, the contents (e.g., advertised products/services, offers, advertising, and topics) of the newsletter are described concretely.
  4. When sending the newsletter, we analyze your user behavior. The newsletters contain so-called “web beacons” or “tracking pixels” that are called up when the newsletter is opened. For the evaluations, we link the web beacons with your email address and an individual ID. Links received in the newsletter also contain this ID. The data is collected exclusively in pseudonymized form, so the IDs are not linked to your other personal data, and direct personal identification is excluded. With this data, we can determine whether and when you have opened the newsletter and which links in the newsletter have been clicked. This serves the purpose of optimizing and statistically evaluating our newsletter.
  5. The legal basis for newsletter distribution, performance measurement, and email storage is your consent according to Art. 6 para. 1 sentence 1 lit. a) GDPR in conjunction with § 7 para. 2 no. 3 UWG, and for logging the consent, Art. 6 para. 1 sentence 1 lit. f) GDPR, as this serves our legitimate interest in legal verifiability.
  6. You can object to tracking at any time by clicking the unsubscribe link at the end of the newsletter. However, in that case, newsletter reception would also be terminated. If you disable the display of images in your email software, tracking is also not possible. However, this may have limitations regarding newsletter functionality, and contained images will not be displayed.
  7. You can revoke your consent to receive the newsletter at any time. You can exercise your revocation by clicking the unsubscribe link at the end of the newsletter, sending an email, or a message to our contact details above. We will store your data as long as you have subscribed to the newsletter. After unsubscribing, your data will only be stored anonymously for statistical purposes.

Google Adsense

  1. We have integrated advertisements from the Google service “Adsense” (service provider: Google Ireland Limited, registration number: 368047, Gordon House, Barrow Street, Dublin 4, Ireland) on our website. The advertisements are marked with the (i) note “Google Ads” in each ad.
  2. Data categories and description of data processing: Usage data / communication data; Google receives information when you visit our website. Google places a web beacon or cookie on your computer for this purpose. The data is also transferred to the USA and analyzed there. If you are logged in with a Google account, Adsense can associate the data with your account. If you do not wish this, you must log out before visiting our website. However, Google may also use other information for this purpose:
    • The type of websites you visit and the mobile apps installed on your device;
    • Cookies in your browser and settings in your Google account;
    • Websites and apps you have visited; • Your activities on other devices;
    • Previous interactions with Google ads or advertising services;
    • Your Google account activities and information.

      When you click on an Adsense ad, Google processes the IP of the users (usage data), with the processing being pseudonymized (so-called “advertising ID”) by truncating the IP to the last two digits. Google does not link identifiers from cookies or similar technologies to special categories of personal data under Art. 9 GDPR, such as ethnic origin, religion, sexual orientation, or health, in personalized advertising.
  3. Purpose of processing: We have activated personalized ads to display more interesting advertising that supports the commercial use of our website, increases value for us, and improves the user experience for you. With the help of personalized advertising, we can reach users via Adsense based on their interests and demographic characteristics (e.g., “sports enthusiasts”). In addition, the processing serves tracking, remarketing, and conversion measurement, as well as financing our website offering.
  4. Legal basis: If you have consented to the processing of your personal data by “Google Adsense with personalized ads” (“opt-in”), Art. 6 para. 1 p. 1 lit. a) GDPR is the legal basis. Otherwise, the legal basis for the processing of your data is Art. 6 para. 1 p. 1 lit. f) GDPR due to our legitimate interests in analyzing, optimizing, and efficiently operating our advertising and website.
  5. Data transmission / recipient category: Google Ireland, USA; This website also has Google AdSense ads from third-party providers enabled. The aforementioned data may also be transferred to these third-party providers named “Certified External Vendors” at https://support.google.com/dfp_sb/answer/94149.
  6. Storage duration: The data is stored for up to 24 months after the last visit.
  7. Objection and elimination options (“opt-out”): You can object to or prevent the installation of cookies by Google Adsense in various ways:
  8. In the Google Advertising Privacy Policy at https://policies.google.com/technologies/ads, you can find further information on the use of Google cookies in ads and their advertising technologies, storage duration, anonymization, location data, operation, and your rights.

Amazon Partner Program

  1. I participate in the Amazon Partner Program (service provider: Amazon EU S.à.r.l, Amazon Services Europe S.à.r.l, and Amazon Media EU S.à.r.l., all three located at 5 Rue Plaetis, L–2338 Luxembourg, Parent company: Amazon.com Inc., 2021 Seventh Ave, Seattle, Washington 98121, USA), through which we receive advertising fees by placing advertisements or partner links when third parties purchase something on Amazon through them.
  2. Data categories and description of data processing: Usage data. Amazon creates statistics and records when a partner link is clicked and what was purchased through it. For this purpose, the data is transferred to the USA and analyzed there. To track orders, a specific attribute called the partner ID is added to the partner link URL. If you are logged into your Amazon account, Amazon may potentially associate this data with your account. If you do not wish this to happen, you must log out of your account. Amazon may potentially disclose your data to authorities or contractual partners.
  3. Purpose of processing: Analysis, optimization, and economical operation of our website through the partner program.
  4. Legal bases: If you have given your consent (“opt-in”) for the processing of your personal data through the “partner program” from the third-party provider, then Article 6(1) sentence 1 lit. a) GDPR is the legal basis. The legal basis for the processing of your data is also our legitimate interest in the analysis, optimization, and economical operation of our website according to Article 6(1) sentence 1 lit. f) GDPR.
  5. Storage duration: The storage duration of the information through the partner link is up to 24 hours since clicking on the partner link or up to 89 days if items are added to the shopping cart on Amazon.
  6. Data transmission/Recipient category: Amazon EU.
  7. You can object to the installation of cookies by Amazon in various ways or prevent them:
    • You can block cookies in your browser by setting it to “do not accept cookies,” which also includes third-party cookies.
    • You can disable interest-based ads on Amazon through this link: https://www.amazon.de/adprefs.
    • You can deactivate personalized ads from third parties participating in the advertising self-regulation initiative “About Ads” via the link https://optout.aboutads.info for US sites or for EU sites at http://www.youronlinechoices.com/de/praferenzmanagement/. However, this setting will only persist until you delete all your cookies.
  8. For more information, please refer to Amazon’s privacy policy at https://www.amazon.de/gp/help/customer/display.html?nodeId=201909010 and for interest-based advertising here: https://www.amazon.de/gp/help/customer/display.html?nodeId=201151440.

Google reCAPTCHA

  1. We have integrated the anti-spam function “reCAPTCHA” from “Google” (Provider: Google Ireland Limited, Registration No.: 368047, Gordon House, Barrow Street, Dublin 4, Ireland) on our website.
  2. Data categories and description of data processing: Usage data (e.g., accessed webpage, IP). By using “reCAPTCHA” in our forms, we can determine whether the input was made by a machine (robot) or a human. When using the service, your IP address and, if necessary, other data required for this purpose may be transmitted to Google servers in the USA.
  3. Purpose of processing: Prevention of spam and abuse as well as our economic interest in optimizing our website.
  4. Legal bases: If you have given your consent (“opt-in”) for the processing of your personal data via “reCAPTCHA” from the third-party provider, then Article 6(1) sentence 1 lit. a) GDPR is the legal basis. The legal basis is also our legitimate interest in data processing according to Article 6(1) sentence 1 lit. f) GDPR, which lies in the purposes mentioned above.
  5. Data transmission/Recipient category: Third-party provider in the USA.
  6. Storage duration: Until the cookies are deleted by you as a user.
  7. For more information about Google reCAPTCHA, visit https://www.google.com/recaptcha/ and consult Google’s privacy policy at https://policies.google.com/privacy.

Presence on Social Media

  1. We maintain profiles or fan pages on social media. When you use and access our profile on the respective network, the respective privacy policies and terms of use of the respective network apply.
  2. Data categories and description of data processing: Usage data, contact details, content data, inventory data. Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage behavior and resulting user interests can be used to create user profiles. These user profiles can then be used to display advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behavior and interests of the users are stored. Furthermore, data can also be stored in the user profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in). For a detailed presentation of the respective processing methods and the possibilities for objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks. Also, in the case of requests for information and the assertion of data subject rights, we point out that these can be most effectively asserted with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information directly. If you still need assistance, you can contact us.
  3. Purpose of processing: Communication with users connected to and registered on social networks; information and advertising for our products, offers, and services; external presentation and image maintenance; evaluation and analysis of users and content of our presence on social media.
  4. Legal bases: The legal basis for the processing of personal data is our legitimate interest in the purposes mentioned above according to Article 6(1) sentence 1 lit. f) GDPR. If you have given us or the responsible party of the social network consent to the processing of your personal data, the legal basis is Article 6(1) sentence 1 lit. a) in conjunction with Article 7 GDPR.
  5. Data transmission/Recipient category: Social network.
  6. You can find the privacy policies, information on access, and options for objection (opt-out) of the respective networks/service providers here:

Rights of the Data Subject

  1. Objection or Revocation of Consent for Data Processing

    If the processing is based on your consent according to Art. 6 para. 1 sentence 1 lit. a), Art. 7 GDPR, you have the right to revoke your consent at any time. The lawfulness of the processing carried out on the basis of the consent until the revocation is not affected by this.

    If we base the processing of your personal data on the balancing of interests according to Art. 6 para. 1 sentence 1 lit. f) GDPR, you can object to the processing. This is the case if the processing is not necessary, in particular, to fulfill a contract with you, as described by us in the following description of the functions. When exercising such objection, we ask you to explain the reasons why we should not process your personal data as we have done. In the event of your justified objection, we will examine the situation and either stop or adjust the data processing, or show you our compelling legitimate reasons for continuing the processing.

    You can object to the processing of your personal data for advertising and data analysis purposes at any time. You can exercise the right to object free of charge. You can inform us of your objection to advertising using the following contact details:

    Tobias Wintrich
    Am Ginsterberg 48
    52477, Alsdorf, Germany
    Email:
  2. Right to Information
    You have the right to request confirmation from us as to whether personal data concerning you is being processed. If this is the case, you have the right to information about your personal data stored by us according to Art. 15 GDPR. This includes, in particular, information about the purposes of processing, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned duration of storage, the origin of your data, unless it was collected directly from you.
  3. Right to Rectification
    You have the right to request the correction of incorrect or completion of correct data according to Art. 16 GDPR.
  4. Right to Erasure
    You have the right to request the deletion of your personal data stored by us according to Art. 17 GDPR, unless legal or contractual retention periods or other legal obligations or rights to further storage contradict this.
  5. Right to Restriction
    You have the right to request a restriction on the processing of your personal data if one of the conditions in Art. 18 para. 1 lit. a) to d) GDPR is met:
    • if you dispute the accuracy of the personal data concerning you for a period that allows the data controller to verify the accuracy of the personal data;
    • the processing is unlawful and you oppose the erasure of the personal data and request instead the restriction of its use;
    • the data controller no longer needs the personal data for the purposes of processing, but you need it for the establishment, exercise, or defense of legal claims, or
    • if you have objected to the processing pursuant to Art. 21 para. 1 GDPR and it has not yet been determined whether the legitimate grounds of the data controller override your grounds.
  6. Right to Data Portability
  7. You have the right to data portability according to Art. 20 GDPR, which means that you can receive the personal data concerning you that you have provided to us in a structured, commonly used, and machine-readable format, or you can request the transmission to another controller.
  8. Right to Lodge a Complaint
  9. You have the right to lodge a complaint with a supervisory authority. As a rule, you can contact the supervisory authority, in particular in the Member State of your habitual residence, your place of work, or the place of the alleged infringement.

Data Security

To protect all personal data transmitted to us and to ensure that data protection regulations are complied with by both us and our external service providers, we have implemented appropriate technical and organizational security measures. Therefore, among other things, all data between your browser and our server is transmitted encrypted via a secure SSL connection.

As of: 18.02.2024