Information on the processing of your personal data
Definition of terms
04109 Leipzig, Germany
Questions about data protection
If you have any questions about data protection regarding our company or our website, please contact our data protection officer:
Spirit Legal LLP Rechtsanwälte
Lawyer and data protection officer
c/o cognitix GmbH
04109 Leipzig, Germany
We took comprehensive technological and organizational precautions to protect your personal data from unauthorized access, misuse, loss and other external interference. To this end, we review our security measures on a regular basis and adapt them to the state of the art.
You have the following rights regarding your personal data that you can exercise against us:
Right of access (GDPR, article 15),
Right to rectification (GDPR, article 16) or erasure (GDPR, article 17),
Right to restriction of processing (DGDPR, article 18),
Right to object processing (GDPR, article 21),
Right to withdraw your consent (GDPR, article 7, section 3),
Right to receive your personal data in a structured, commonly used and machine-readable format ("Portability") and right to transmit those data to another controller if the requirements of article 20, section 1 letters a, b of the GDPR are met (GDPR, article 20).
You can exercise your rights by notifcation to the contact address stated under "Controller" or or by contacting the data protection officer appointed by us.
In addition, you have the right to lodge a complaint with a supervisory authority about the processing of your personal data carried out by us (GDPR, article 77).
Use of the website, access data
In general, you can use our website for purely informational purposes without disclosing your identity. When you call up the individual pages of the website for this purpose, we will only transmit access data to our web space provider so that the website can be displayed to you. This is the following data:
browser type and version,
used operating system,
language and version of the browser software,
date and time of the server request,
access status/HTTP status code,
referrer URL (the previously visited page),
transferred data volume.
The temporary processing of the IP address is necessary to technically enable the delivery of the website to your computer. This requires processing your IP address for the duration of the session. The legal basis for such processing is article 6, section 1, item 1, letter f) of the GDPR.
This access data will not be used to identify individual users and will not be consolidated with other data sources. The access data will be deleted when it is no longer needed for the purpose of its processing. In the case of the collection of data to deliver the website, this will be the case when you terminate your visit to the website.
IP addresses are stored in log files to ensure the functionality of the website. We also use the data to optimize the website and to ensure the security of our information technology systems. The data is not evaluated for marketing purposes in this context. On principle, the data is deleted after seven days at the latest. Further processing is possible in individual cases. In this case, the IP address will be deleted or alienated in such a way that it will no longer be possible to match it to the requesting client.
a) Technically necessary cookies
Some elements of our website require that the requesting browser can be identified even after changing the page. The following data is processed in the cookies:
The user data collected by technically necessary cookies will not be processed to create user profiles. We also use so-called "session cookies" that store a session ID that can be used to allocate multiple requests of your browser to the shared session. Session cookies are necessary to use the website. In particular, they allow us to to recognize the terminal device used when you return to the website. We use this cookie to recognize you when you return to the website if you have an account with us. Otherwise, you would have to log in at every visit. The legal basis for such processing is article 6, section 1, item 1, letter f) of the GDPR. We use session cookies to make the use of the website more attractive and effective. The session cookies will be deleted when you log out or close the browser.
b) Technically unnecessary cookies
frequency of page views.
We use these cookies to make the use of the website more effective and attractive. The legal basis for such processing is article 6, section 1, item 1, letter f) of the GDPR. Cookies that are not technically necessary are automatically deleted after a specified period of time that may vary depending on the cookie.
If we include cookies of third parties in our website, we will inform you of this separately below.
c) Banner notice on cookies
Contacting our company
When you contact our company, for example by email or using the contact form on the website, we will process the personal data you provided to answer your inquiry.
To processes inquiries made using the contact form on the website, it is necessary that you state a name or pseudonym, your company, and a valid email address. At the time you send the message to us, the following data is processed in addition:
The legal basis for such processing is article 6, section 1, item 1, letter f) of the GDPR or article 6, section 1, item 1, letter b) of the GDPR if you contact us with the purpose to conclude a contract. If it is necessary to enter your data in order to conclude a contract, it may be impossible to conclude or execute a contract or to process the inquiry if the data is not provided.
We solely process personal data collected via the contact form to process the inquiry. If you contact us by email, this also constitutes the necessary legitimate interest in the processing of the data. The other personal data we process during the sending process serves to prevent a misuse of the contact form and to ensure the security of our information technology systems.
The data will not be passed on to third parties in this context. The data is solely processed to process the conversation. We will delete the data arising in this context after processing is no longer necessary, or restrict processing to compliance with the existing legally mandatory storage obligations.
Processing and disclosure of personal data for contractual purposes
We will process your personal data if and insofar as this is necessary for the initiation, justification, execution and/or termination of a legal transaction with our company. The legal basis for this results from article 6, section 1, item 1, letter b) of the GDPR. If the data processing is necessary for the conclusion of a contract, the conclusion of the contract, the execution and/or the termination of a legal transaction with our company may be impossible if the data is not provided.
After the purpose has been achieved (e.g. contract processing), the personal data will be blocked for further processing or deleted unless we are entitled to further storage and processing as required in the respective context on the basis of a consent given by you (e.g. consent to the processing of the email address for sending electronic advertising mail), a contractual agreement, a legal authorization (e.g. authorization to send direct marketing) or on the basis of legitimate interests (e.g. storage for the assertion of claims).
Your personal data will be disclosed if:
this is necessary for the justification, execution and/or termination of a legal transaction with our company (e.g. disclosing data to a payment service provider/shipping company to perform a contract with you), (GDPR, article 6, section 1, item 1, letter b), or
a subcontractor or vicarious agent whom we employ exclusively to provide the offers or services requested by you needs this data (such auxiliary persons shall only be authorized to process the data to the extent that this is necessary for the provision of the offer or service, unless you are expressly informed otherwise), or
or if an enforceable administrative order exists (GDPR, article 6, section 1, item 1, letter c)), or
or if an enforceable judicial order exists (GDPR, article 6, section 1, item 1, letter c)), or
we are obliged by law to do so (GDPR, article 6, section 1, item 1, letter c)), or
processing is necessary in order to protect the vital interests of the data subject or of another natural person (GDPR, article 6, section 1, item 1, letter d)), or
processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority (GDPR, article 6, section 1, item 1, letter e)), or
we are authorized or obliged to disclose the data for the purposes of pursuing legitimate interests (GDPR, article 6, section 1, item 1, letter f)).
Beyond this, your personal data shall not be disclosed to other persons, companies or bodies, unless you have effectively consented to such disclosure. The legal basis for such processing is article 6, section 1, item 1, letter a) of the GDPR.
Registration for events
On the website, you can register as a guest or speaker for events of our company or for events where our company is represented. The basis for the processing of your data for the participation in events is article 6, section 1, item 1, letter b) of the GDPR. Processing is necessary for the justification, execution and/or termination of legal transactions with our company (e.g. disclosing data to a payment service provider/shipping company to perform a contract with you). If the data is not provided, it may be impossible to conclude a contract or to execute or terminate legal transactions with our company.
In the registration form, you have to state your name and your email address, amongst others. The data is processed for the purpose of maintaining contacts and improving our public image and public relations. If you have expressed interest in a personal appointment, we will also process the data to prepare and execute the appointment.
Your data will be disclosed to third parties (e.g. payment service providers, shipping companies and the organizer) for the purposes of handling payments, shipping event documentation and registration with the organizer. A targeted transfer of your personal data to a so-called third country is not planned.
We will delete the data arising in this context after storage is no longer necessary, or restrict processing if there are statutory storage obligations.
We reserve the right to use the email address provided by you as part of the registration in accordance with the statutory provisions to send you the following content by email during or after the registration, unless you have already objected to such processing of your email address:
Provided that the transmission of electronic information is not necessary for contract processing (e.g. email in informational form) and the legal basis from article 6, section 1, item 1, letter b) of the GDPR is relevant, processing is based on the legal basis according to article 6, section 1, item 1, letter f) of the GDPR. Our legitimate interests in the processing are the improvement and optimization of our services, sending direct marketing and ensuring customer satisfaction. We will delete your data when you terminate your license agreement, at the latest three years after termination of the agreement.
On the website, you can subscribe to our email newsletter that we use to regularly provide information about the following contents:
offers from our portfolio,
events of our company,
offers (including events) of third parties provided that you consented to this,
new products/product lines,
special offers/time-limited offers.
To receive the newsletter, the following personal data are required:
recipient (name or pseudonym),
valid email address.
Registration for our newsletter is a double opt-in process. After entering the data marked mandatory, we will send an email to the email address you provided. In this email we will ask you to explicitly confirm your subscription to our newsletter (by clicking the confirm link). This way we make sure that you really wish to receive our email newsletter. If you do not confirm the registration within 24 hours, we will block access to the information sent to us and delete it automatically after one month at the latest.
At the time of registration, the following data is processed in addition:
date/time of subscription to newsletter,
time of your confirmation of the confirm link
We process your IP address, the time you subscribed to the newsletter and confirmed your subscription to document your subscription to the newsletter and protect your personal data from misuse. The legal basis for processing is article 6, section 1, item 1, letter f) of the GDPR. We will process this data for a period of two years after termination of the contract. If subscription to the newsletter takes place without concluding a contract, we will process this data for a period of two years after termination of use. We will delete the data when the subscription to the newsletter ends.
Following your confirmation, we will process the email address and name/pseudonym of the recipient for the purpose of sending our email newsletter. The legal basis for processing is article 6, section 1, item 1, letter a) of the GDPR. We will delete the data when you terminate the subscription to the newsletter.
Note that we evaluate your user behavior when sending the newsletter. For this evaluation, the sent emails contain so-called web beacons or tracking pixels, one-pixel image files that are integrated on our website. For the evaluation, we correlate the data listed under "Use of the website, access data" and the web beacons with your email address and an individual ID. Links in the newsletter also contain this ID.
Using the collected data, we create a user profile to tailor the newsletter to your individual interests. In this process, we record when you read our newsletters and what links you click in them. From this we draw conclusions to your personal interests. We relate this data to actions you take on our website. This information will be processed for as long as you subscribe to the newsletter. After you unsubscribe we process the data purely statistically and anonymously.
The purpose of this is to evaluate the use and optimization of the email marketing that we send to you. The legal basis for such processing is article 6, section 1, item 1, letter f) of the GDPR.
"MailChimp" email marketing service
We use the "MailChimp" email marketing service by Rocket Science Group, LLC (675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA, web: https://mailchimp.com/; hereinafter: MailChimp).
If you have subscribed to the newsletter, the data provided during registration will be stored and processed on the servers of MailChimp in the USA. MailChimp submitted to EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. You can view the certification of Rocket Science Group at https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG. MailChimp processes this information to send and evaluate the newsletters on our behalf. The newsletters contain so-called web beacons, one-pixel files that are retrieved from the MailChimp server when the newsletter is opened. Technical data such as the browser used, time of the page call and IP address, is collected as part of the retrieval process. This data is processed to evaluate and improve our services. Furthermore, it is evaluated whether and when newsletters are opened and which links are clicked by the reader. In theory, this data can be assigned to individual newsletter recipients. However, neither we nor MailChimp intend to monitor individual recipients. Instead, the evaluation of the mentioned data serves to detect the reading habits of the recipients in order to be able to adapt, optimize and spread our newsletter contents better. The legal basis for such processing is article 6, section 1, item 1, letter f) of the GDPR. We have no knowledge of the storage time at MailChimp and have no influence on it.
Furthermore, according to their own policy, MailChimp can use the transmitted data for the optimization and improvement of their own services, e.g. to optimize the sending and display of the newsletters. According their own account, MailChimp does neither process the data to send you their own advertising nor disclose it to third parties.
As a newsletter recipient you may be redirected to the MailChimp website. For example, in case of representation problems with your email program when you follow the link to read the newsletter online. Note in this context that MailChimp may be using additional analysis services and cookies on their website to process your personal data on behalf of MailChimp. We have no influence on such processing.
We use external hosting services to provide the following services: infrastructure and platform services, computing capacity, storage resources, database services and technical maintenance services. All data required for the operation and use of our website is processed in this context.
We use external hosting services for the operation of the website. By using external hosting services, we aim at an efficient and secure provision of our website. The legal basis for the processing is article 6, section 1, item 1, letter f) of the GDPR.
Integration of third-party content
The website integrates third-party content such as videos, maps, RSS feeds or graphics from other websites. This integration always assumes that the providers of this content (hereinafter: third-party providers) perceive the IP addresses of the users. Without the IP addresses they would be unable to send the content to the users' browsers. The IP address is therefore required for the presentation of this content.
We endeavor to only use content by third-party providers who process the IP address only to deliver the content. However, we have no influence on whether the third-party providers process the IP addresses for statistical purposes, for example. Insofar as this is known to us, we will inform you about it below.
It is possible that some third-party providers process data outside the European Union.
Google Tag Manager
On our website we use Google Tag Manager. Google Tag Manager is a solution that allows marketers to manage website tags using one interface. The Tag Manager tool (that implements the tags) itself is a cookie-free domain and does not collect any personal data. The tool triggers other tags that may themselves collect data. Google Tag Manager does not access this data. If tags were deactivated at the domain or cookie level, this will persist for all tracking tags implemented with Google Tag Manager.
On the website, we use plugins of the video portal YouTube.de and YouTube.com, a service provided by YouTube LLC (headquartered in 901 Cherry Avenue, San Bruno, CA 94066, USA; hereinafter: YouTube) – represented by Google. Using plugins, we can integrate visual content (videos) that we published on Youtube.de and Youtube.com in this website.
The videos are all integrated in "extended privacy mode", meaning that no user data about you is transmitted to YouTube if you do not play the videos. The data is only transmitted when you play the videos. We have no influence on this data transmission.
By visiting the website YouTube is notified that you called the respective sub-page of our website. In addition, the data listed under "Use of the website, access data" is transmitted. This occurs regardless of whether YouTube provides a user account that you are logged in to, or whether no user account exists. If you are logged in to Google, your data will be directly assigned to your account. If you do not wish this assignment with your YouTube profile, you need to log out before activating the button. YouTube stores your data as usage profiles and processes them for the purposes of marketing, market research and/or design of its website according to demand. This evaluation takes place (even for users who are not logged in) to deliver tailored marketing and to notify other users of the social network about your activities on our website. Google also processes your personal data in the USA and has submitted to EU-US Privacy Shield (https://www.privacyshield.gov/EU-US-Framework). You can view the certification of Google at https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
The legal basis for the processing is article 6, section 1, item 1, letter f) of the GDPR. The processing serves to make our website more attractive and to offer additional services to you. We have no knowledge of the storage time at YouTube and have no influence on it.
Services for statistical, analytical and marketing purposes
Some of the third-party providers offer the possibility to directly object the use of the respective service, e.g. by setting an opt-out cookie.
In the following, we provide information on the services by third-party providers currently used on our website as well as the purpose and scope of data processing in individual cases and your possibilities to object.
If IP address anonymization is enabled on this website, Google will previously truncate your IP address within member states of the European Union or other signatory states to the Agreement on the European Economic Area. The full IP address is only in exceptional cases transmitted to a Google server in the USA and truncated there. On our behalf, Google will use this information to evaluate your use of this website, to compile reports on website activity for us and to provide us with other services relating to website and Internet usage.
The IP address transmitted by your browser via Google Analytics will not be consolidated with other Google data.
This website uses Google Analytics with the "_anonymizeIp()" extension. This means that IP address are processed in a truncated form, thus excluding the possibility of personal references. Therefore, any reference to you in the collected data is immediately eliminated, meaning that any personal data is immediately deleted.
We use Google Analytics to analyze and continuously improve the use of our website. Using these statistics, we can improve our website and make it more interesting to you as a user. Regarding the exceptional cases when personal data is transmitted to the USA, Google submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. You can view the certification of Google at https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active .
For further information on Google as a third-party provider refer to:
Usage-based online marketing
Google AdWords conversion
We use Google AdWords to attract attention to our attractive offers with the help of advertising material (so-called Google AdWords) on external websites. In relation to the data of the advertising campaigns we can determine the success of individual advertising efforts.
This advertising material is delivered via so-called Google ad servers. For this purpose, we use ad server cookies that serve to measure certain success parameters, such as the display of ads and clicks by users. If you access our website via a Google ad, Google AdWords will store a cookie on your terminal device. Normally, these cookies expire after 30 days and do not serve to identify you. For this cookie the following analysis values are usually stored: the unique cookie ID, the number of ad impressions per placement (frequency), the latest impression (relevant for post-view conversions), and opt-out information (flag that the user does not wish to be addressed again).
These cookies allow Google to recognize your Internet browser. If a user visits certain website pages of a Google AdWords customer and the cookie stored on the computer has not expired yet, Google and the customer can see that the user clicked the ad and was referred to the website. Every Google AdWords customer is assigned a unique cookie. Google only provides us with statistical evaluations to determine the success of our advertising material.
Due to the marketing tools used, your browser automatically establishes a direct connection to the Google server. We have no influence on the scope and further processing of the data Google collects using this tool. We therefore provide the following information to the best of our knowledge: Due to the integration of AdWords conversion, Google is informed that you visited the respective part of our website or clicked one of our ads. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or are not logged in, it is possible that the provider learns and stores your IP address.
Google processes the data in the USA and has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. You can view the certification of Google at https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active .
The legal basis for such processing of your data is article 6, section 1, item 1, letter f) of the GDPR. We aim at displaying interesting advertising material to you, making our website more interesting for you and achieving a fair calculation of advertising costs. The maximum storage time at Google is eighteen months. For further information on privacy at Google refer to: http://www.google.com/intl/de/policies/privacy and https://services.google.com/sitestats/de.html.
Google transmits the information generated by the DoubleClick cookies to a server in the USA and stores it there. Google complies with the privacy terms of the EU-US Privacy Shield agreement and is certified according to Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. You can view the certification of Google at https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active. Data will only be forwarded to third parties as required by law or for order processing. According to Google, DoubleClick cookies do not contain any personal data.
Due to the marketing tools used, your browser automatically establishes a direct connection to the Google server. We have no influence on the scope and further processing of the data Google collects using this tool. We therefore provide the following information to the best of our knowledge: Due to the integration of DoubleClick, Google is informed that you visited the respective part of our website or clicked one of our ads. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or are not logged in, it is possible that the provider learns and stores your IP address.
The legal basis for such processing is article 6, section 1, item 1, letter f) of the GDPR. The DoubleClick cookies are deleted after six months at the latest. We use DoubleClick to display advertisements that may be of interest to you and to make our website more interesting for you.