Privacy Policy


Privacy policy according to DSGVO

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).

The terms used are not gender-specific.

Status: May 2022

TABLE OF CONTENTS

  • Introduction
  • Responsible
  • Overview of the processing
  • Contact Data Protection Officer
  • Relevant legal bases
  • Transfer and disclosure of personal data
  • Data processing in third countries
  • Use of cookies
  • Provision of the online offer and web hosting
  • Newsletter and electronic notifications
  • Web analysis, monitoring and optimisation
  • Presence in social networks (social media)
  • Plugins and embedded functions and content
  • Data deletion
  • Amendment and update of the privacy policy
  • Rights of the data subjects

Responsible

iRights.Lab GmbH,
Managing Directors: Philipp Otto, Dr. Wiebke Glässer
Address: Oranienstraße 185, 10999 Berlin
Phone: +49 (0)30 40 36 77 230
Fax: +49 (0)30 40 36 77 260
E-mail: info@irights-lab.de

CONTACT DATA PROTECTION OFFICER

Lawyer Jan Mönikes

SCHALAST & PARTNER Attorneys at Law mbB
Marienstr. 30
10117 Berlin
E-Mail: datenschutz@irights-lab.de

OVERVIEW OF THE PROCESSING

The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

  • Inventory data (e.g. names).
  • Content data (e.g. entries in online forms, entries during registration for the internal user area).
  • Contact details (e.g. e-mail, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, retrievals, access times).

Categories of persons concerned

  • Communication partner.
  • Users (e.g. website visitors, users of online services, participants in the network as registered users).

Purposes of the processing

  • Provision of our online offer and user-friendliness.
  • Conversion measurement (measuring the effectiveness of marketing measures).
  • Direct marketing (e.g. by e-mail).
  • Profiling (creation of user profiles)
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Safety measures.
  • Tracking (e.g. interest/behavioural profiling, use of cookies) with separately granted consent.
  • Provision of contractual services and customer service for internal user area.
  • Managing and responding to enquiries.

 

RELEVANT LEGAL BASIS

In the following, we inform you about the legal basis of the Data Protection Regulation (DSGVO) on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, the national data protection provisions in your or our country of residence and domicile may apply. Should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO) – The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
  • Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures taken at the data subject’s request.
  • Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO) – Processing is necessary to protect the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Bundesdatenschutzgesetz – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision-making in individual cases. In addition, the regulations of the Telecommunications Telemedia Data Protection Act (TDDSG) apply, in particular regarding the process of storing and reading information on terminal devices (section 25, paragraph 1, sentence 1 TTDSG). This primarily covers the processes of data collection and storage. Furthermore, state data protection laws of the individual federal states may apply.

TRANSFER AND DISCLOSURE OF PERSONAL DATA

In the course of our processing of personal data, the data may be transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.

We use the WordPress CMS to manage the content of our website.

WordPress Foundation, 660 4th Street, Box 119, San Francisco, CA 94107, USA

WordPress uses cookies to store logged-in users (administrators) (Users Cookie) and for commenters on the blog (Commenters Cookie). The comment cookies expire after one year from the time they were set. You can find more information on data processing here: https://wordpress.org/support/article/cookies/

WordPress temporarily stores the visitor’s personal data (name and email) that they enter in the newsletter subscription form and transfers it to SendInBlue via the API. The name is not required, the email is required in the form. Purpose of use: https://www.sendinblue.com/legal/privacypolicy/

If you have any questions about the CMS, please send an e-mail to kontakt@irights-lab.de.

Furthermore, we use the service provider Converve for the submission of applications for the projects as well as suggestions of people.

Converve GmbH
Bahnhofstrasse 3
25355 Barmstedt
Fon: +49 (0) 4123-922 61-0
Fax: +49 (0) 4123-922 61-29
E-Mail: info@converve.com
www.converve.com

Converve stores and processes the personal data entered in the questionnaires (name, address, email address) according to the conditions assured by us below, in particular with regard to the storage period. The collection, processing and use of the data takes place exclusively on the territory of the Federal Republic of Germany, in a member state of the European Union (EU) or in another contracting state of the Agreement on the European Economic Area (EEA).

You can find out more about how Converve handles data here:

https://www.converve.com/de/ueber-uns/

DATA PROCESSING IN THIRD COUNTRIES

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we only process or have data processed in third countries with a recognised level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations
(Art. 44 to 49 DSGVO, information page of the EU Commission:
https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

USE OF COOKIES

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after their visit within an online offering. Stored information may include, for example, language settings on a website, login status, a shopping cart or where a video was watched. The term cookies also includes other technologies that perform the same functions as cookies (e.g. when user details are stored using pseudonymous online identifiers, also known as “user IDs”).

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his browser.
  • Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users used for reach measurement or marketing purposes can be stored in such a cookie.
  • First-party cookies: First-party cookies are set by us.
  • Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or absolutely necessary) cookies: Cookies may be absolutely necessary for the operation of a website (e.g. to save logins or other user entries or for security reasons).
  • Statistics, marketing and personalisation cookies: Furthermore, cookies are usually also used in the context of range measurement and when a user’s interests or behaviour (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This procedure is also referred to as “tracking”, i.e. tracking the potential interests of users. Insofar as we use cookies or “tracking” technologies, we will inform you separately in our data protection declaration or in the context of obtaining consent.

Processing of cookie data based on consent: On our website, we use GDPR Cookie Compliance (CCPA ready) plugin to obtain consent to store certain cookies and to document it in a data protection compliant manner. GDPR Cookie Compliance (CCPA ready) plugin separates strictly necessary cookies (WordPress and WPML), third-party cookies and additional cookies to give the visitor the option to disable them separately in the user interface or to continue with all of them at once. The strictly necessary cookies are cookies that are necessary for the proper functioning of the website, for example information about which cookies the user has agreed to. This does not store any sensitive or personal data. The consent log stores all data in the WordPress website database. The data stored includes: Date of consent, user IP address, accepted cookies and user email (for logged in users). GDPR Cookie Compliance (CCPA ready) plugin is open source software from the company Moove Agency, 35 Kingsland Rd, London E2.

More information: https://wordpress.org/plugins/gdpr-cookie-compliance/

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal basis: Consent (§ 25 para. 1 p. 1 TTDSG, Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

PROVISION OF THE ONLINE OFFER AND WEB HOSTING

In order to provide our online offer securely and efficiently, we use the services of a web hosting provider from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services as well as security services and technical maintenance services.

The data processed as part of the provision of the hosting offer may include all information relating to the users of our online offer that is generated as part of the use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

The provision of the web space is carried out on our behalf by the company

ALL-INKL.COM

New Media Münnich
Main Street 68
D-02742 Friedersdorf

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of the 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) and, as a rule, IP addresses and the requesting provider.

The server log files can be used on the one hand for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the utilisation of the servers and their stability.

  • Types of data processed: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

 NEWSLETTER AND ELECTRONIC NOTIFICATIONS

We send newsletters, e-mails and other electronic notifications (hereinafter referred to as “newsletter”) only with the consent of the recipients, on the basis of a contractual service relationship or a legal permission. Within the scope of the contractual service relationship, you will receive notifications in accordance with the concluded terms of use or conditions of participation.

If the contents of the newsletter are specifically described in the course of registration, they are decisive for the user’s consent. In addition, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name for the purpose of a personal address in the newsletter, or further details if these are required for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter is always carried out in a so-called double opt-in process. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can register with other people’s e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored with the dispatch service provider are also logged.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove consent formerly given. The processing of this data will be limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list (so-called “block list”) for this purpose alone.

The logging of the registration process is carried out on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Notes on legal basis: Newsletters or notifications are sent on the basis of the recipients’ consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of existing customer advertising. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests in order to prove that it was carried out in accordance with the law.

Contents: Information about us, our services, campaigns and offers.

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e-mail), meta/communication data (IP addresses), usage data (e.g. websites visited, interest in content, click behaviour, link click behaviour, access times).
  • Affected persons: Communication partner.
  • Purposes of processing: direct marketing (e.g. by e-mail).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
  • Possibility of objection (opt-out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can use one of the contact options given above, preferably e-mail, for this purpose.

Services used and service providers:

 

WEB ANALYSIS, MONITORING AND OPTIMISATION

Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can, for example, recognise at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas need optimisation.

In addition to web analysis, we may also use testing procedures, e.g. to test and optimise different versions of our online offer or its components.

For these purposes, so-called user profiles may be created and stored in a file (so-called “cookie”) or similar procedures may be used with the same purpose. This information may include, for example, content viewed, websites visited and elements used there and technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed, depending on the provider.

The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored in the context of web analysis, A/B testing and optimisation, but pseudonyms. This means that we as well as the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purpose of the respective procedures.

Notes on legal bases: Where we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behaviour-related profiling, use of cookies), conversion measurement (measurement of the effectiveness of marketing measures), profiling (creation of user profiles).
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

Matomo: The information generated by the cookie about your use of this website is only stored on our server and is not passed on to third parties; Service provider: Self-hosted web analytics/reach measurement; Website: https://matomo.org/; Deletion of data: The cookies have a maximum storage period of 13 months.

PRESENCES IN SOCIAL NETWORKS (SOCIAL MEDIA)

We maintain online presences within social networks and process user data in this context in order to communicate with users active there or to offer information about us.

We would like to point out that user data may be processed outside the European Union. This may result in risks for the users because, for example, it could make it more difficult to enforce the rights of the users.

Furthermore, user data within social networks is usually processed for market research and advertising purposes. For example, usage profiles can be created based on the usage behaviour and resulting interests of the users. The usage profiles can in turn be used, for example, to place 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 behaviour and the interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).

For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, click behaviour, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

  • Twitter: social network; service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, parent company: Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Privacy policy: https://twitter.com/de/privacy, (settings) https://twitter.com/personalization

PLUGINS AND EMBEDDED FUNCTIONS AND CONTENT

We integrate functional and content elements into our online offer that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These can be, for example, graphics, videos or social media buttons and posts (hereinafter uniformly referred to as “content”).

The integration always requires that the third-party providers of this content process the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is thus required for the display of this content or function. We endeavour to only use content whose respective providers only use the IP address to deliver 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 analyse 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 our online offering, as well as being linked to such information from other sources.

Notes on legal bases: Where we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms).
  • Data subjects: Users (e.g. website visitors, users of online services), communication partners.
  • Purposes of processing: provision of our online offer and user experience, provision of contractual services and customer service, security measures, management and response to enquiries, contact requests and communication, direct marketing (e.g. by email), tracking (e.g. interest/behavioural profiling, use of cookies), interest-based and behavioural marketing, profiling (creation of user profiles).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Contract performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

 

DELETION OF DATA

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked, contractual relationships are terminated or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose).

If the data are not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. I.e. 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 or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

Further information on the deletion of personal data can also be found in the individual data protection notices of this data protection declaration.

AMENDMENT AND UPDATE OF THE DATA PROTECTION DECLARATION

We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

Where we provide addresses and contact details of companies and organisations in this privacy statement, please note that the addresses may change over time and please check the details before contacting us.

RIGHTS OF THE PERSONS CONCERNED

As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right of revocation for consents: You have the right to revoke any consent you have given at any time.
  • Right of access: You have the right to request confirmation as to whether data in question is being processed and to be informed about this data and to receive further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: In accordance with the law, you have the right to request that data concerning you be completed or that inaccurate data concerning you be rectified.
  • Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data relating to you be erased immediately or, alternatively, to request restriction of the processing of the data in accordance with the law.
  • Right to data portability: You have the right to receive data relating to you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transferred to another controller.
  • Complaint to the supervisory authority: You also have the right, in accordance with the law, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you believe that the processing of personal data relating to you infringes the GDPR. The address of the competent supervisory authority at the registered office of the controller is:

Berlin Commissioner for Data Protection and Freedom of Information
Friedrichstr. 219
10969 Berlin
mailbox@datenschutz-berlin.de

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