Privacy Policy
Privacy Policy
We are very pleased with your interest in our company. Data protection has a particularly high priority for the management of FpP Federnfabrik AG. It is generally possible to use the websites of FpP Federnfabrik AG without providing any personal data. However, if a data subject wishes to use special services of our company through our website, processing personal data may become necessary. If the processing of personal data is necessary and there is no legal basis for such processing, we generally obtain the consent of the data subject.
The processing of personal data, such as the name, address, email address, or telephone number of a data subject, is always in accordance with the General Data Protection Regulation and in compliance with the national data protection regulations applicable to FpP Federnfabrik AG. Through this privacy policy, our company aims to inform the public about the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, this privacy policy provides information to data subjects about their rights.
As the data controller, FpP Federnfabrik AG has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, internet-based data transmissions can generally have security gaps, so absolute protection cannot be guaranteed. For this reason, each data subject is free to transmit personal data to us via alternative means, such as by telephone.
1. Definitions
The privacy policy of FpP Federnfabrik AG is based on the terms used by the European legislator when enacting the General Data Protection Regulation (GDPR). Our privacy policy is intended to be easily readable and understandable for both the public and our customers and business partners. To achieve this, we would like to explain the terms used in advance. In this privacy policy, we use the following terms:
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a) Personal Data
Personal data is any information relating to an identified or identifiable natural person (hereinafter "data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier, or to one or more specific characteristics that express the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
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b) Data Subject
A data subject is any identified or identifiable natural person whose personal data is processed by the data controller.
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c) Processing
Processing is any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
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d) Restriction of Processing
Restriction of processing is the marking of stored personal data with the aim of limiting its processing in the future.
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e) Profiling
Profiling is any form of automated processing of personal data that involves using personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements of that natural person.
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f) Pseudonymization
Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without additional information, provided that such additional information is kept separately and subject to technical and organizational measures that ensure that the personal data is not attributed to an identified or identifiable natural person.
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g) Data Controller
The data controller is the natural or legal person, authority, agency, or other body which, alone or jointly with others, determines the purposes and means of processing personal data. Where the purposes and means of such processing are determined by Union law or the law of the Member States, the data controller or the specific criteria for their designation may be provided for by Union law or the law of the Member States.
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h) Processor
The processor is a natural or legal person, authority, agency, or other body that processes personal data on behalf of the data controller.
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i) Recipient
The recipient is a natural or legal person, authority, agency, or other body to which personal data is disclosed, whether or not it is a third party. Authorities that may receive personal data in the course of a particular inquiry in accordance with Union law or the law of the Member States are not considered recipients.
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j) Third Party
A third party is a natural or legal person, authority, agency, or other body other than the data subject, the data controller, the processor, and persons who, under the direct authority of the data controller or processor, are authorized to process personal data.
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k) Consent
Consent is any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.
2. Name and Address of the Data Controller
The data controller according to the General Data Protection Regulation, other applicable data protection laws in the Member States of the European Union, and other data protection regulations is:
FpP Federnfabrik AG
Sihlbruggstrasse 144
6340 Baar / ZG
Switzerland
Tel.: 041 761 28 23
Email: info@fpp.ch
Website: www.fpp.ch
3. Cookies
The websites of FpP Federnfabrik AG use cookies. Cookies are text files that are placed and stored on a computer system via an internet browser.
Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters through which websites and servers can be assigned to the specific internet browser in which the cookie was stored. This allows the visited websites and servers to distinguish the individual browser of the affected person from other internet browsers that contain other cookies. A specific internet browser can be recognized and identified by the unique cookie ID.
By using cookies, FpP Federnfabrik AG can provide users of this website with more user-friendly services that would not be possible without the setting of cookies.
With the help of a cookie, information and offers on our website can be optimized for the user. As already mentioned, cookies enable us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, a user of a website that uses cookies does not have to enter their login details again on each visit to the website, as this is taken over by the website and the cookie stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online shop remembers the items a customer has placed in the virtual shopping cart through a cookie.
The affected person can prevent the setting of cookies by our website at any time by making the appropriate setting in the internet browser used and thereby permanently object to the setting of cookies. Furthermore, already set cookies can be deleted at any time via an internet browser or other software programs. This is possible in all common internet browsers. If the affected person deactivates the setting of cookies in the internet browser used, not all functions of our website may be fully usable.
4. Collection of General Data and Information
The website of FpP Federnfabrik AG collects a range of general data and information with each access to the website by an affected person or an automated system. This general data and information is stored in the server's log files. The following data may be collected: (1) the types and versions of browsers used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (known as the referrer), (4) the sub-websites that are accessed through an accessing system on our website, (5) the date and time of access to the website, (6) an Internet Protocol (IP) address, (7) the Internet service provider of the accessing system, and (8) other similar data and information used to avert risks in the event of attacks on our information technology systems.
When using this general data and information, FpP Federnfabrik AG does not draw any conclusions about the affected person. Instead, this information is needed to (1) correctly deliver the content of our website, (2) optimize the content of our website and its advertising, (3) ensure the ongoing functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyber attack. Therefore, this anonymously collected data and information is evaluated by FpP Federnfabrik AG both statistically and with the aim of enhancing data protection and data security in our company, ultimately ensuring an optimal level of protection for the personal data we process. The anonymous data in the server log files is stored separately from any personal data provided by the affected person.
5. Contact Possibility via the Website
The website of FpP Federnfabrik AG contains information required by legal regulations that allows for quick electronic contact with our company and immediate communication with us, which also includes a general address for electronic mail (email address). If an affected person contacts the data controller via email or through a contact form, the personal data transmitted by the affected person is automatically stored. Such personal data voluntarily provided by the affected person to the data controller is stored for the purpose of processing or contacting the affected person. No transfer of this personal data to third parties takes place.
6. Routine Deletion and Blocking of Personal Data
The data controller processes and stores personal data of the data subject only for the period necessary to achieve the storage purpose or as required by the European legislator or another legislator in laws or regulations applicable to the data controller.
If the storage purpose ceases or a storage period required by the European legislator or another competent legislator expires, the personal data will be routinely and legally blocked or deleted.
7. Rights of the data subject
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a) Right to Confirmation
Every affected person has the right granted by the European legislator to request confirmation from the controller whether personal data concerning them is being processed. If an affected person wishes to exercise this right to confirmation, they can contact an employee of the controller at any time.
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b) Right to Access
Every person affected by the processing of personal data has the right granted by the European legislator to obtain free information from the controller about the personal data stored about them and a copy of this information at any time. Furthermore, the European legislator has granted the affected person access to the following information:
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- the purposes of the processing
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- the categories of personal data being processed
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- the recipients or categories of recipients to whom the personal data have been or will be disclosed, particularly in the case of recipients in third countries or international organizations
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- if possible, the planned duration for which the personal data will be stored, or, if that is not possible, the criteria used to determine that period
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- the existence of the right to rectification or erasure of personal data concerning them or to restriction of processing by the controller, or of the right to object to such processing
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- the existence of a right to lodge a complaint with a supervisory authority
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- if the personal data were not collected from the affected person: all available information about the source of the data
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- the existence of automated decision-making, including profiling, in accordance with Article 22(1) and (4) GDPR, and — at least in those cases — meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the affected person
Furthermore, the affected person has the right to information about whether personal data have been transferred to a third country or to an international organization. If that is the case, the affected person also has the right to be informed about the appropriate safeguards related to the transfer.
If an affected person wishes to exercise this right to information, they can contact an employee of the controller at any time.
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c) Right to Rectification
Every person affected by the processing of personal data has the right granted by the European legislator to request the immediate rectification of incorrect personal data concerning them. Furthermore, the affected person has the right, considering the purposes of the processing, to request the completion of incomplete personal data — also by means of a supplementary statement.
If an affected person wishes to exercise this right to rectification, they can contact an employee of the controller at any time.
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d) Right to Erasure (Right to be Forgotten)
Every person affected by the processing of personal data has the right granted by the European legislator to request the immediate erasure of personal data concerning them if one of the following reasons applies and processing is not necessary:
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- The personal data have been collected or otherwise processed for purposes no longer necessary.
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- The affected person withdraws their consent on which the processing was based according to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, and there is no other legal ground for the processing.
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- The affected person objects to the processing under Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the affected person objects to the processing under Article 21(2) GDPR.
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- The personal data have been processed unlawfully.
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- The erasure of personal data is required to fulfill a legal obligation under Union or Member State law to which the controller is subject.
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- The personal data were collected in relation to offered information society services according to Article 8(1) GDPR.
If one of the above reasons applies and an affected person wishes to request the erasure of personal data stored by FpP Federnfabrik AG, they can contact an employee of the controller at any time. The employee of FpP Federnfabrik AG will ensure that the erasure request is promptly complied with.
If the personal data have been made public by FpP Federnfabrik AG and our company is required to erase the personal data under Article 17(1) GDPR, FpP Federnfabrik AG will take reasonable measures, including technical measures, to inform other controllers processing the published personal data that the affected person has requested the erasure of all links to such personal data or copies or replications of such personal data, as far as processing is not necessary. The employee of FpP Federnfabrik AG will take the necessary steps in each case.
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e) Right to Restriction of Processing
Every person affected by the processing of personal data has the right granted by the European legislator to request the restriction of processing from the controller if one of the following conditions is met:
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- The accuracy of the personal data is contested by the affected person, for a period that allows the controller to verify the accuracy of the personal data.
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- The processing is unlawful, the affected person objects to the erasure of the personal data and requests instead the restriction of the use of the personal data.
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- The controller no longer needs the personal data for processing purposes, but the affected person needs them to assert, exercise or defend legal claims.
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- The affected person has objected to the processing under Article 21(1) GDPR and it is not yet clear whether the legitimate grounds of the controller override those of the affected person.
If one of the above conditions applies and an affected person wishes to request the restriction of personal data stored by FpP Federnfabrik AG, they can contact an employee of the controller at any time. The employee of FpP Federnfabrik AG will arrange for the restriction of processing.
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f) Right to Data Portability
Every person affected by the processing of personal data has the right granted by the European legislator to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used and machine-readable format. They also have the right to transmit those data to another controller without hindrance from the controller to whom the personal data were provided, provided that the processing is based on consent according to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR or on a contract according to Article 6(1)(b) GDPR and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, the affected person has the right to have the personal data transmitted directly from one controller to another, where technically feasible, and provided that this does not adversely affect the rights and freedoms of others.
To exercise the right to data portability, the affected person can contact an employee of FpP Federnfabrik AG at any time.
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g) Right to Object
Every person affected by the processing of personal data has the right granted by the European legislator to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them which is based on Article 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.
If FpP Federnfabrik AG processes personal data based on the objection, it will cease processing unless we can demonstrate compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the affected person, or the processing is necessary for the assertion, exercise, or defense of legal claims.
If FpP Federnfabrik AG processes personal data for direct marketing purposes, the affected person has the right to object at any time to the processing of their personal data for such marketing purposes. This also applies to profiling to the extent that it is related to such direct marketing. If the affected person objects to FpP Federnfabrik AG's processing for direct marketing purposes, F pP Federnfabrik AG will cease processing the personal data for these purposes.
In addition, the affected person has the right to object to the processing of their personal data by FpP Federnfabrik AG for scientific or historical research purposes, or for statistical purposes under Article 89(1) GDPR, on grounds relating to their particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
To exercise the right to object, the affected person can contact an employee of FpP Federnfabrik AG directly. They are free to use the right to object in connection with the use of information society services and notwithstanding Directive 2002/58/EC, by automated means, and shall be entitled to do so regardless of the requirement of a written form.
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h) Automated Individual Decision-Making, Including Profiling
Every person affected by the processing of personal data has the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, provided that the decision (1) is not necessary for entering into, or performance of, a contract between the affected person and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the affected person’s rights and freedoms and legitimate interests, or (3) is not based on the affected person’s explicit consent.
If the decision (1) is necessary for entering into, or performance of, a contract between the affected person and a data controller, or (2) is based on the affected person’s explicit consent, FpP Federnfabrik AG shall implement suitable measures to safeguard the affected person’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view, and to contest the decision.
If an affected person wishes to exercise rights related to automated individual decision-making, they can contact an employee of the controller at any time.
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i) Right to Withdraw Data Protection Consent
Every person affected by the processing of personal data has the right granted by the European legislator to withdraw their consent to the processing of personal data at any time.
If an affected person wishes to exercise their right to withdraw consent, they can contact an employee of FpP Federnfabrik AG at any time.
8. Data Protection Regulations for the Use of Google Analytics (with Anonymization Function)
The data controller has integrated the Google Analytics component (with anonymization function) on this website. Google Analytics is a web analysis service. Web analysis involves collecting, gathering, and evaluating data on the behavior of visitors to websites. A web analysis service collects data such as the website from which a visitor came (known as the referrer), which subpages of the website were accessed, and how often and for how long a subpage was viewed. Web analysis is primarily used to optimize a website and conduct a cost-benefit analysis of online advertising.
The operator of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
The data controller uses the "_gat._anonymizeIp" add-on for web analysis via Google Analytics. This add-on shortens and anonymizes the IP address of the affected person's internet connection by Google when accessing our website from a Member State of the European Union or another contracting state of the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyze the flow of visitors on our website. Google uses the data and information obtained to evaluate the use of our website, compile online reports that illustrate activities on our website, and provide additional services related to the use of our website.
Google Analytics sets a cookie on the affected person's IT system. Cookies are explained above. The setting of the cookie enables Google to analyze the use of our website. Each time a page of this website operated by the data controller is accessed, and on which a Google Analytics component has been integrated, the affected person's browser is automatically prompted by the respective Google Analytics component to transmit data for online analysis to Google. As part of this technical procedure, Google gains knowledge of personal data such as the IP address of the affected person, which Google uses, among other things, to track the origin of visitors and clicks and to enable commission calculations.
The cookie stores personal information such as the access time, the location from which the access originated, and the frequency of visits to our website by the affected person. Each time our website is visited, this personal data, including the IP address of the internet connection used by the affected person, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may share this personal data collected through the technical process with third parties.
The affected person can prevent the setting of cookies by our website, as described above, at any time by adjusting their browser settings and thus permanently object to the setting of cookies. Such an adjustment of the browser settings would also prevent Google from setting a cookie on the affected person's IT system. Additionally, any cookies already set by Google Analytics can be deleted at any time via the internet browser or other software programs.
Furthermore, the affected person has the option to object to and prevent the collection of data generated by Google Analytics related to the use of this website, as well as the processing of this data by Google. To do this, the affected person must download and install a browser add-on from the link https://tools.google.com/dlpage/gaoptout. This browser add-on informs Google Analytics via JavaScript that no data and information about website visits may be transmitted to Google Analytics. Google regards the installation of the browser add-on as an objection. If the affected person's IT system is deleted, formatted, or reinstalled at a later date, the affected person must reinstall the browser add-on to deactivate Google Analytics. If the browser add-on is uninstalled or deactivated by the affected person or by someone within their sphere of control, there is an option to reinstall or reactivate the browser add-on.
Further information and Google's current privacy policy can be accessed at https://www.google.de/intl/de/policies/privacy/ and http://www.google.com/analytics/terms/de.html. Google Analytics is explained in more detail at https://www.google.com/intl/de_de/analytics/.
9. Privacy Policy Regarding the Use and Application of Google Remarketing
The data controller has integrated Google Remarketing services on this website. Google Remarketing is a feature of Google AdWords that allows a company to show ads to internet users who have previously visited the company's website. Integrating Google Remarketing allows a company to create user-specific ads and display interest-relevant advertisements to internet users.
The operator of the Google Remarketing services is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
The purpose of Google Remarketing is to display interest-relevant advertising. Google Remarketing allows us to show ads through the Google advertising network or on other websites that are tailored to the individual needs and interests of internet users.
Google Remarketing sets a cookie on the affected person's IT system. Cookies are explained above. The setting of the cookie allows Google to recognize the visitor of our website when they subsequently visit websites that are also part of the Google advertising network. Each time a website with the Google Remarketing service integrated is accessed, the affected person's browser automatically identifies itself to Google. As part of this technical process, Google gains knowledge of personal data such as the IP address or browsing behavior of the user, which Google uses, among other things, to display interest-relevant advertising.
The cookie stores personal information, such as the websites visited by the affected person. Each time our website is visited, personal data, including the IP address of the internet connection used by the affected person, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may share this personal data collected through the technical process with third parties.
The affected person can prevent the setting of cookies by our website, as described above, at any time by adjusting their browser settings and thus permanently object to the setting of cookies. Such an adjustment of the browser settings would also prevent Google from setting a cookie on the affected person's IT system. Additionally, any cookies already set by Google Remarketing can be deleted at any time via the internet browser or other software programs.
Furthermore, the affected person has the option to object to interest-based advertising by Google. To do this, the affected person must visit the link www.google.de/settings/ads from each of their browsers and make the desired settings there.
Further information and Google's current privacy policy can be accessed at https://www.google.de/intl/de/policies/privacy/.
10. Privacy Policy Regarding the Use and Application of Google AdWords
The data controller has integrated Google AdWords on this website. Google AdWords is an internet advertising service that allows advertisers to display ads both in Google’s search engine results and within the Google advertising network. Google AdWords enables advertisers to pre-select specific keywords so that an ad is shown in Google’s search results only when a user queries a keyword-relevant search term. Within the Google advertising network, ads are distributed to topic-relevant websites using an automatic algorithm and based on the previously defined keywords.
The operator of Google AdWords services is Google Ireland Limited, Gordon House, Barrow Street, Dublin, D04 E5W5, Ireland.
The purpose of Google AdWords is to promote our website by displaying interest-relevant advertising on third-party websites and in Google search engine results, as well as displaying external ads on our website.
If an affected person arrives at our website via a Google ad, a so-called conversion cookie is placed on the affected person's IT system by Google. Cookies are explained above. A conversion cookie expires after thirty days and does not serve to identify the affected person. If the cookie has not expired, it tracks whether certain subpages, such as a shopping cart from an online store system, were accessed on our website. Using the conversion cookie, both we and Google can track whether an affected person who arrived at our website via an AdWords ad generated a sale, i.e., completed or abandoned a purchase.
The data and information collected through the use of the conversion cookie are used by Google to create visit statistics for our website. We use these visit statistics to determine the total number of users who were referred to us through AdWords ads, to assess the success or failure of each AdWords ad, and to optimize our future AdWords ads. Neither our company nor other Google AdWords advertisers receive information from Google that could identify the affected person.
The conversion cookie stores personal information, such as the websites visited by the affected person. Each time our website is visited, personal data, including the IP address of the internet connection used by the affected person, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may share this personal data collected through the technical process with third parties.
The affected person can prevent the setting of cookies by our website, as described above, at any time by adjusting their browser settings and thus permanently object to the setting of cookies. Such an adjustment of the browser settings would also prevent Google from setting a conversion cookie on the affected person's IT system. Additionally, any cookies already set by Google AdWords can be deleted at any time via the internet browser or other software programs.
Furthermore, the affected person has the option to object to interest-based advertising by Google. To do this, the affected person must visit the link www.google.de/settings/ads from each of their browsers and make the desired settings there.
Further information and Google's current privacy policy can be accessed at https://www.google.de/intl/de/policies/privacy/.
11. Legal Basis for Processing
Article 6(1)(a) GDPR serves as the legal basis for processing operations where we obtain consent for a specific processing purpose. If the processing of personal data is necessary to fulfill a contract with the data subject, such as in processing operations required for the delivery of goods or the provision of another service or consideration, the processing is based on Article 6(1)(b) GDPR. The same applies to processing operations necessary for the performance of pre-contractual measures, such as in cases of inquiries about our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as fulfilling tax obligations, the processing is based on Article 6(1)(c) GDPR. In rare cases, the processing of personal data may be necessary to protect vital interests of the data subject or another natural person. For example, if a visitor to our company were to be injured and their name, age, health insurance details, or other vital information needed to be passed on to a doctor, hospital, or other third parties, the processing would be based on Article 6(1)(d) GDPR. Finally, processing operations may be based on Article 6(1)(f) GDPR. This legal basis applies to processing operations not covered by any of the above legal bases if the processing is necessary for the purposes of legitimate interests pursued by our company or a third party, provided that the interests, fundamental rights, and freedoms of the data subject do not override those interests. Such processing operations are specifically permitted as they are explicitly mentioned by the European legislator. He considered that a legitimate interest might be assumed if the data subject is a customer of the controller (Recital 47, sentence 2 GDPR).
12. Legitimate interests in the processing pursued by the controller or a third party
If the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is the conduct of our business for the benefit of all our employees and stakeholders.
13. Duration for which personal data is stored
The criterion for the duration of the storage of personal data is the respective statutory retention period. After the expiry of this period, the corresponding data is routinely deleted, provided it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
14. Legal or contractual requirements for providing personal data; Necessity for contract conclusion; Obligation of the data subject to provide the personal data
We inform you that providing personal data is sometimes legally required (e.g., tax regulations) or may arise from contractual agreements (e.g., information about the contracting party). In some cases, it may be necessary for a contract to be concluded that a data subject provides us with personal data, which must then be processed by us. For example, the data subject is required to provide us with personal data if our company enters into a contract with them. Failure to provide the personal data would result in the contract with the data subject not being concluded. Before providing personal data, the data subject must contact one of our employees. Our employee will inform the data subject on a case-by-case basis whether providing the personal data is legally or contractually required or necessary for the contract conclusion, whether there is an obligation to provide the personal data, and what the consequences of not providing the personal data would be.
15. Existence of Automated Decision-Making
As a responsible company, we refrain from automatic decision-making or profiling.
This privacy policy was created using the privacy policy generator of DGD Deutsche Gesellschaft für Datenschutz GmbH, which operates as an External Data Protection Officer Ingolstadt, in cooperation with IT and data protection lawyer Christian Solmecke.