Privacy

Introduction

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to briefly as “data”) we process, for what purposes, and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the context of providing 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 offering”).

The terms used are not gender-specific.

Status: January 8, 2023

Table of Contents

Controller

Mügge & Dr. Pitschel, Partnerschaft von Rechtsanwälten mbB
Arkaden am Gericht, Berliner Str. 10
37073 Göttingen

Authorized Representatives:

Dr. Anthea Pitschel, Karl-Heinz Mügge

Email Address:

[email protected]

Legal Notice:

www.muegge-pitschel.de/impressum

Overview of Processing

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

Types of Data Processed

  • Inventory data.
  • Location data.
  • Contact data.
  • Content data.
  • Usage data.
  • Meta/communication data.

Categories of Data Subjects

  • Users.

Purposes of Processing

  • Contact requests and communication.
  • Security measures.
  • Reach measurement.
  • Tracking.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.

Relevant Legal Bases

In the following, you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection requirements in your or our country of residence or domicile may apply. Should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) – The data subject has given their consent to the processing of their personal data for one or more specific purposes.
  • Legitimate Interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

In addition to the data protection regulations of the GDPR, national regulations on data protection in Germany apply. This includes, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). The BDSG contains, in particular, special regulations on the right to information, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes, and transmission as well as automated individual decision-making including profiling. Furthermore, it regulates data processing for purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, implementation, or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

Security Measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account 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 the risk to the rights and freedoms of natural persons, to ensure a level of protection appropriate to the risk.

The measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access, input, disclosure, ensuring availability, and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, the deletion of data, and reactions to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software, and procedures in accordance with the principle of data protection by design and by default.

Deletion of Data

The data processed by us will be deleted in accordance with the legal requirements as soon as the consents permitted for processing are revoked or other permissions lapse (e.g., if the purpose of processing this data has lapsed or it is not required for the purpose). If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted to these purposes. This means the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons or whose storage is necessary for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person.

Our privacy notices may also contain further information on the storage and deletion of data that takes precedence for the respective processing operations.

Use of Cookies

Cookies are small text files or other storage notices that store information on end devices and read information from end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed, or functions used in an online offering. Cookies can also be used for various purposes, e.g., for the functionality, security, and convenience of online offerings and for creating analyses of visitor flows.

Notes on consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, unless this is not required by law. Consent is particularly not necessary if the storage and reading of information, including cookies, are strictly necessary to provide the users with a telemedia service (i.e., our online offering) explicitly requested by them. The revocable consent is clearly communicated to the users and contains information on the respective cookie use.

Notes on legal bases under data protection law: The legal basis under data protection law on which we process the personal data of users with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g., in a commercial operation of our online offering and improvement of its usability) or, if this occurs within the framework of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which the cookies are processed by us in the course of this privacy policy or within the framework of our consent and processing procedures.

Storage duration: With regard to the storage duration, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their end device (e.g., browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be stored or preferred content can be displayed directly when the user visits a website again. Likewise, the data of users collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information on the type and storage duration of cookies (e.g., when obtaining consent), users should assume that cookies are permanent and the storage duration can be up to two years.

General notes on revocation and objection (opt-out): Users can revoke the consents they have given at any time and also object to the processing in accordance with the legal requirements in Art. 21 GDPR. Users can also declare their objection via the settings of their browser, e.g., by deactivating the use of cookies (although this may also restrict the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites  https://optout.aboutads.info and https://www.youronlinechoices.com/.

Further information on processing operations, procedures, and services:

  • Processing of cookie data based on consent: We use a cookie consent management procedure, within the framework of which the users’ consent to the use of cookies, or the processing and providers mentioned within the framework of the cookie consent management procedure, can be obtained and managed and revoked by the users. In this process, the declaration of consent is stored so as not to have to repeat the query and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following notes apply: The duration of the storage of the consent can be up to two years. In this process, a pseudonymous user identifier is formed and stored with the time of consent, information on the scope of the consent (e.g., which categories of cookies and/or service providers) as well as the browser, system, and end device used.
  • BorlabsCookie: Cookie consent management; Service provider: Hosted locally on our server, no data transfer to third parties; Website: https://de.borlabs.io/borlabs-cookie/; Further information: An individual user ID, language, and types of consent and the time of their submission are stored on the server side and in the cookie on the user’s device.

Provision of the Online Offering and Web Hosting

We process the data of users in order to be able to provide them with our online services. For this purpose, we process the user’s IP address, which is necessary to transmit the content and functions of our online services to the user’s browser or end device.

  • Processed data types: 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: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); security measures.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures, and services:

  • Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files”. The server log files may include the address and name of the websites and files accessed, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), and usually 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 utilization of the servers and their stability;  Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is required for evidentiary purposes is excluded from deletion until the final clarification of the respective incident.
  • STRATO: Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacities); Service provider: STRATO AG, Pascalstraße 10, 10587 Berlin, Germany; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.strato.de; Privacy Policy: https://www.strato.de/datenschutz; Data processing agreement: Provided by the service provider.

Web Analysis, Monitoring, and Optimization

Web analysis (also referred to as “reach measurement”) serves to evaluate the visitor flows of our online offering and can include behavior, interests, or demographic information about the visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognize at what time our online offering or its functions or content are used most frequently or invite reuse. Likewise, we can understand which areas require optimization.

In addition to web analysis, we can also use testing procedures to, for example, test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles, i.e., data summarized for a usage process, can be created for these purposes and information can be stored in a browser or in an end device and read from it. The information collected includes, in particular, websites visited and elements used there as well as 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 to us or to the providers of the services we use, location data can also be processed.

The IP addresses of the users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear data of the users (such as email addresses or names) are stored within the framework of web analysis, A/B testing, and optimization, but pseudonyms. This means that both we and 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 purposes of the respective procedures.

  • Processed data types: 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); profiles with user-related information (creation of user profiles); tracking (e.g., interest/behavior-related profiling, use of cookies); provision of our online offering and user-friendliness.
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing operations, procedures, and services:

Social Media Presence

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

We point out that user data may be processed outside the European Union. This may result in risks for users, because, for example, the enforcement of user rights could be made more difficult.

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

For a detailed description of the respective forms of processing and the opt-out options, we refer to the privacy policies and information of 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 asserted most effectively with the providers. Only the providers have access to the users’ data and can directly take appropriate measures and provide information. Should you nevertheless need help, you can contact us.

  • Processed data types: Contact data (e.g., email, phone numbers); 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).
  • Purposes of processing: Contact requests and communication; feedback (e.g., collecting feedback via online form); marketing.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures, and services:

  • Facebook Pages: Profiles within the social network Facebook – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content users view or interact with, or the actions they take (see under “Things you and others do and provide” in the Facebook Data Policy:  https://www.facebook.com/policy), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see under “Device Information” in the Facebook Data Policy:  https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analysis services, so-called “Page Insights”, for page operators so that they receive insights into how people interact with their pages and with the content associated with them. We have concluded a special agreement with Facebook (“Page Insights Controller Addendum”,  https://www.facebook.com/legal/terms/page_controller_addendum), which in particular regulates which security measures Facebook must observe and in which Facebook has agreed to fulfill data subject rights (i.e., users can, for example, direct information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information about Page Insights data” (https://www.facebook.com/legal/terms/information_about_page_insights_data);  Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Standard contractual clauses (guaranteeing data protection level for processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further information: Joint controllership agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. The joint controllership is limited to the collection by and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transmission of the data to the parent company Meta Platforms, Inc. in the USA (on the basis of the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
  • LinkedIn: Social network; Service provider: LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy Policy: https://www.linkedin.com/legal/privacy-policy; Data processing agreement: https://legal.linkedin.com/dpa; Standard contractual clauses (guaranteeing data protection level for processing in third countries): https://legal.linkedin.com/dpa; Opt-out option: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

Plugins and Embedded Functions and Content

We integrate functional and content elements into our online offering 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 city maps (hereinafter uniformly referred to as “content”).

Integration always requires that the third-party providers of this content process the users’ IP address, as they could not send the content to their browser without the IP address. The IP address is therefore required for the display of this content or functions. We strive to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers can also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. Through the “pixel tags”, information such as visitor traffic on the pages of this website can be evaluated. The pseudonymous information can also be stored in cookies on the user’s device and contain, among other things, technical information about the browser and operating system, referring websites, visit time, and other information about the use of our online offering, as well as be combined with such information from other sources.

  • Processed data types: 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., email, phone numbers); content data (e.g., entries in online forms); location data (information on the geographical position of a device or a person).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness; marketing; profiles with user-related information (creation of user profiles).
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).

Further information on processing operations, procedures, and services:

  • Google Fonts (obtaining from Google server): Obtaining fonts (and symbols) for the purpose of a technically secure, maintenance-free, and efficient use of fonts and symbols with regard to timeliness and loading times, their uniform display, and consideration of possible licensing restrictions. The provider of the fonts is informed of the user’s IP address so that the fonts can be made available in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted, which are necessary for the provision of the fonts depending on the devices used and the technical environment. This data can be processed on a server of the font provider in the USA – When visiting our online offering, the users’ browsers send their browser HTTP requests to the Google Fonts Web API (i.e., a software interface for retrieving the fonts). The Google Fonts Web API provides users with the Cascading Style Sheets (CSS) from Google Fonts and then the fonts specified in the CSS. These HTTP requests include (1) the IP address used by the respective user to access the internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent describing the browser and operating system versions of the website visitors, as well as the referrer URL (i.e., the website on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and they are not analyzed. The Google Fonts Web API logs details of the HTTP requests (requested URL, user agent, and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must adapt the font generated for the respective browser type. The user agent is primarily logged and used for debugging to generate aggregated usage statistics that measure the popularity of font families. These summarized usage statistics are published on the “Analytics” page of Google Fonts. Finally, the referrer URL is logged so that the data can be used for production maintenance and an aggregated report on the top integrations based on the number of font requests can be generated. According to its own information, Google does not use any of the information collected by Google Fonts to create profiles of end users or to place targeted advertisements;  Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR); Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy; Further information: https://developers.google.com/fonts/faq/privacy?hl=de.
  • Google Maps: We embed maps from the “Google Maps” service provided by Google. The data processed may include, in particular, users’ IP addresses and location data;  Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson’s Quay, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR); Website: https://mapsplatform.google.com/; Privacy policy: https://policies.google.com/privacy.
  • LinkedIn plugins and content: This may include, for example, content such as images, videos or text, and buttons that allow users to share content from this online offering within LinkedIn; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Data processing agreement: https://legal.linkedin.com/dpa; Standard Contractual Clauses (ensuring an adequate level of data protection when processing in third countries): https://legal.linkedin.com/dpa; Right to object (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6(1) sentence 1 lit. f GDPR); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Right to object (opt-out): Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertising: https://adssettings.google.com/authenticated.

Amendment and update of the privacy policy

We kindly ask you to regularly review the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require an action on your part (e.g. consent) or other individual notification.

If we provide addresses and contact details of companies and organisations in this privacy policy, please note that addresses may change over time and we ask you to verify the details before contacting them.

Rights of data subjects

As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

  • Right to object: You have the right, on grounds relating to your particular situation, to object at any time to the processing of personal data concerning you which is based on Article 6(1) lit. e or f GDPR; this also applies to profiling based on these provisions. Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw any consent you have given at any time.
  • Right of access: You have the right to request confirmation as to whether data concerning you are being processed and to obtain information about such data, as well as further information and a copy of the data in accordance with the statutory provisions.
  • Right to rectification: In accordance with the statutory provisions, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to request that data concerning you be erased without undue delay or, alternatively, to request restriction of the processing of the data in accordance with the statutory provisions.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us, in a structured, commonly used and machine-readable format, in accordance with the statutory provisions, or to request that it be transmitted to another controller.
  • Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the provisions of the GDPR.

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