Privacy Policy
Thank you for visiting our website alohaspirit.ch and for your interest in our company.
The protection of your personal data, such as date of birth, name, telephone number, address, etc., is important to us.
The purpose of this privacy policy is to inform you about the processing of your personal data that we collect from you when you visit our site. Our data protection practices are in accordance with the legal regulations of the Swiss Federal Data Protection Act (FADP) and the EU's General Data Protection Regulation (GDPR). The following data protection declaration serves to fulfil the information obligations arising from the FADP and the GDPR. These can be found, for example, in Art. 19 ff. FADP as well as Art. 13 ff. of the GDPR.
Owner or responsible person
The controller within the meaning of Art. 5 let. j FADP or Art. 4 no. 7 GDPR is the person who alone or jointly with others decides on the purposes and means of the processing of personal data. The controller pursuant to Art. 4 No. 7 GDPR is also the recipient of the personal data within the meaning of Art. 4 No. 9 GDPR. Any third party recipient shall be identified separately.
With regard to our website, the owner or responsible person is:
AlohaSpirit GmbH
Alderstrasse 28
8008 Zurich
Switzerland
E-mail: info@alohaspirit.ch
Tel: +41 76 393 20 60
Provision of the website and creation of log files
Each time our website is accessed, our system automatically collects data and information from the device (e.g. computer, mobile phone, tablet, etc.) used to access it.
What personal data is collected and to what extent is it processed?
(1) Information about the browser type and version used;
(2) The operating system of the retrieval device;
(3) Host name of the accessing computer;
(4) The IP address of the retrieval device;
(5) Date and time of access;
(6) Websites and resources (images, files, other page content) accessed on our website;
(7) Websites from which the user's system accessed our website (referrer tracking);
(8) Message whether the retrieval was successful;
(9) Amount of data transmitted
This data is stored in the log files of our system. This data is not stored together with the personal data of a specific user, so that individual site visitors cannot be identified.
Legal basis for the processing of personal data
Personal data is processed in accordance with the principle of legality (Art. 6 para. 1 FADP) and the principle of good faith (Art. 6 para. 2 FADP or Art. 2 CC) as well as Art. 6 para. 1 lit. f GDPR (legitimate interest).
Purpose of data processing
The temporary (automated) storage of data is necessary for the course of a website visit in order to enable delivery of the website. The storage and processing of personal data is also carried out to maintain the compatibility of our website for as many visitors as possible and to combat abuse and eliminate malfunctions. For this purpose, it is necessary to log the technical data of the accessing computer in order to be able to react as early as possible to display errors, attacks on our IT systems and/or errors in the functionality of our website. In addition, we use the data to optimise the website and to generally ensure the security of our information technology systems.
Duration of storage
The deletion of the aforementioned technical data takes place as soon as they are no longer required to ensure the compatibility of the website for all visitors, but no later than 3 months after accessing our website.
Possibility of restriction, objection, correction and deletion
You may at any time request the restriction of processing pursuant to Art. 18 GDPR or object to processing pursuant to Art. 21 GDPR as well as request the correction or deletion of data pursuant to Art. 16 or 17 GDPR. You can find out which rights you have and how to exercise them in the lower section of this privacy policy.
Special functions of the website
Our site offers you various functions, during the use of which personal data is collected, processed and stored by us. We explain below what happens to this data:
Order form
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What personal data is collected and to what extent is it processed?
The data you enter in the form fields, such as address, surname, first name, etc., will be processed by us to fulfil the purpose stated below.
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Legal basis for the processing of personal data
Personal data is processed in accordance with the principle of legality (Art. 6 para. 1 FADP) and the principle of good faith (Art. 6 para. 2 FADP or Art. 2 CC) as well as Art. 6 para. 1 let. b FADP (implementation of (pre)contractual measures).
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Purpose of data processing
The purpose of the data processing is to process your order so that we can fulfil or initiate the contract concluded with you.
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Duration of storage
The data is deleted as soon as it is no longer required for processing the order and there are no longer any legal storage obligations. As a rule, the legislator provides for a retention obligation of 10 years.
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Possibility of objection, processing, correction and deletion
You can restrict processing in accordance with Article 18 of the GDPR, object to processing in accordance with Article 21 of the GDPR and request correction or deletion of data in accordance with Article 16 or 17 of the GDPR at any time. You can find out which rights you have and how to exercise them in the lower section of this data protection declaration.
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Necessity of providing personal data
The information in the order form is necessary for the conclusion of a contract. If you do not fill in the mandatory fields or do not fill them in completely, the order you have requested cannot be carried out.
Booking request form
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Scope of the processing of personal data
We will process the data you enter in our booking request form (date, number of persons, etc.) to fulfil the following purpose.
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Legal basis for the processing of personal data
Personal data is processed in accordance with the principle of legality (Art. 6 para. 1 FADP) and the principle of good faith (para. 2 FADP or Art. 2 CC) as well as Art. 6 para. 1 lit. b GDPR (implementation of (pre)contractual measures).
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Purpose of data processing
A pre-contractual exchange of information is necessary in order to check your booking so that we can prepare for the possible conclusion of a contract at a later date.
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Duration of storage
The data is deleted as soon as it is no longer required for processing the booking and there are no longer any legal retention obligations.
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Possibility of objection, processing, correction and deletion
You can restrict processing in accordance with Article 18 of the GDPR, object to processing in accordance with Article 21 of the GDPR and request correction or deletion of data in accordance with Article 16 or 17 of the GDPR at any time. You can find out which rights you have and how to exercise them in the lower section of this data protection declaration.
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Necessity of providing personal data
The information in the booking request form is required in order to process your booking properly. If you do not fill in the required fields or do not fill them in completely, we will not be able to process your booking request.
Contact form(s)
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What personal data is collected and to what extent is it processed?
The data you have entered in our contact forms, which you have entered in the input mask of the contact form.
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Legal basis for the processing of personal data
Personal data is processed in accordance with the principle of legality (Art. 6 para. 1 FADP) and the principle of good faith (Art. 6 para. 2 FADP or Art. 2 CC) as well as Art. 6 para. 1 lit. a FADP (consent through unambiguous confirmatory action or behaviour).
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Purpose of data processing
We will only use the data collected via our contact form or contact forms for processing the specific contact request received through the contact form. Please note that in order to fulfil your contact request, we may also send you e-mails to the address you have provided. The purpose of this is so that you can receive confirmation from us that your enquiry has been correctly forwarded to us. However, the sending of this confirmation e-mail is not obligatory for us and is only for your information.
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Duration of storage
After processing your request, the collected data will be deleted immediately, unless there are legal retention periods.
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Possibility of restriction, objection, correction and deletion
You may at any time request the restriction of processing pursuant to Art. 18 GDPR or object to processing pursuant to Art. 21 GDPR as well as request the correction or deletion of data pursuant to Art. 16 or 17 GDPR. You can find out which rights you have and how to exercise them in the lower section of this privacy policy.
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Necessity of providing personal data
The use of the contact forms is on a voluntary basis. You are not obliged to contact us via the contact form, but can also use the other contact options provided on our website. If you wish to use our contact form, you must fill in the fields marked as mandatory. If you do not fill in the required information on the contact form, you will either not be able to send the enquiry or we will not be able to process your enquiry due to a lack of information.
Newsletter registration form
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What personal data is collected and to what extent is it processed?
By registering for the newsletter on our website, we receive the e-mail address entered by you in the registration field and, if applicable, further contact data, provided that you communicate this to us via the newsletter registration form.
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Legal basis for the processing of personal data
Personal data is processed in accordance with the principle of legality (Art. 6 para. 1 FADP) and the principle of good faith (Art. 6 para. 2 FADP or Art. 2 CC) as well as Art. 6 para. 1 lit. a FADP (consent through unambiguous confirmatory action or conduct).
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Purpose of data processing
The data recorded in the registration mask of our newsletter will be used by us exclusively for sending our newsletter, in which we inform you about all our services and our news. After registration, we will send you a confirmation e-mail containing a link that you must click to complete the registration for our newsletter (double opt-in). By doing so, you give your consent to data processing in accordance with Art. 6 para. 6 FADP.
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Duration of storage
You can unsubscribe from our newsletter at any time by clicking on the unsubscribe link, which is also included in every newsletter. Your data will be deleted by us immediately after unsubscribing, provided that there are no legal retention obligations. Likewise, your data will be deleted by us immediately in the event that your subscription is not completed. We reserve the right to delete without giving reasons and without prior or subsequent information.
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Possibility of restriction, objection, correction and deletion
You may at any time request the restriction of processing pursuant to Art. 18 GDPR or object to processing pursuant to Art. 21 GDPR as well as request the correction or deletion of data pursuant to Art. 16 or 17 GDPR. You can find out which rights you have and how to exercise them in the lower section of this privacy policy.
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Necessity of providing personal data
If you would like to use our newsletter, you must fill in the fields marked as mandatory and confirm your e-mail address by clicking on the double opt-in link. The newsletter registration details are necessary in order to be able to make use of the newsletter offer. The information is used exclusively for sending our newsletter. If you do not fill in the mandatory fields, we will not be able to provide you with our newsletter service.
Appointment booking form
We offer the option of booking services online on our website. To carry out these bookings, we work together with an external booking system that is integrated into our website via a so-called iFrame. This involves the collection, processing and storage of your personal data. This may include the following data: IP addresses, name, e-mail address, telephone number, etc. The data collected is used exclusively to process your booking and for analysis purposes. The booking service provider sanasearch.ch, which we use, processes this data on our behalf. You accept the terms and conditions and data protection provisions of the service provider when you make a booking. Your data will be treated confidentially and will not be passed on to unauthorized third parties.
Disclosure of information to third parties
Personal data is processed in accordance with the principle of legality (Art. 6 para. 1 FADP) and the principle of good faith (Art. 6 para. 2 FADP and Art. 2 CC).
The disclosure of information to third parties depends on the scope of the activities or offers of our website or our business model described below.
As a matter of principle, we only keep your information for as long as necessary and treat it confidentially. Exceptions to this are the transfer of personal data to debt collection service providers, to public bodies and authorities and to private individuals, who have a right to it due to legal regulations, court decisions or official orders as well as the transfer to authorities for the purpose of initiating legal proceedings or for law enforcement purposes if our legally protected rights are attacked.
Statistical analysis of visits to this website - Webtracker
We collect, process and store the following data when this website or individual files on the website are accessed: IP address, website from which the file was accessed, name of the file, date and time of access, amount of data transferred and report on the success of the access (so-called web log). We use this access data exclusively in non-personalised form for the continuous improvement of our website and for statistical purposes.
Any personal data is processed in accordance with the principle of legality (Art. 6 para. 1 FADP) and the principle of good faith (Art. 6 para. 2 FADP and Art. 2 CC). We also use the following web trackers to evaluate visits to this website:
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Matomo (local)
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Scope of the processing of personal data
Our website contains a tracking code from Matomo (formerly Piwik), an open source web analysis tool (https://matomo.org). The web tracking is carried out solely by us without any personal reference. Matomo is hosted on our own server infrastructure for this purpose. A transfer to third parties therefore does not take place.
We collect, process and store usage data about the use of our site, such as referrer links, the time spent on certain URLs, the clickstream and also data about your browser settings, such as the manufacturer of the browser and also its version, the screen resolution and the operating system used.
We may also collect and store parts of your IP address and information about the loading speed of our website. From this data, we can only create anonymous usage profiles and extract statistical information. We also use cookies as part of Matomo web tracking to distinguish returning site visitors from first-time visitors. Cookies are small text files that are stored locally in the memory of your internet browser and contain a separate ID and possibly other technical information. The data collected in this context will not be merged with other personal data that may be available to us without your separate consent.
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Legal basis for the processing of personal data
In many cases, there is no personal reference. If there is a personal reference, the legal basis for the collection is Art. 6 para. 1 lit f GDPR (legitimate interest) or your consent according to Art. 13 para. 1 FADP.
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Purpose of data processing
The purpose of web tracking is to analyse user flows in order to enable us to anonymously monitor the functionality and user-friendliness of our website and to constantly improve our internet offering. It serves solely to collect statistical, non-personal data.
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Duration of storage
We store all web tracking data collected via Matomo for an indefinite period of time, insofar as this data is only available to us in anonymised form. If the data is not anonymised, we will delete it after 12 months at the latest.
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Possibility of objection and deletion
You can prevent the collection of the aforementioned data as well as its processing by installing a JavaScript blocker to prevent the collection of other app analysis data. Insofar as a personal reference should arise, you can revoke your consent at any time according to the rules outlined in this privacy policy.
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Integration of external web services and processing of data outside the EU
On our website, we use active content from external providers, so-called web services. By calling up our website, these external providers may receive personal information about your visit to our website. This may involve the processing of data outside of Switzerland and the EU. You can prevent this by installing an appropriate browser plug-in or deactivating the execution of scripts in your browser. This may result in functional restrictions on Internet pages that you visit.
We use the following external web services:
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Amazon AWS
We use on our site the service Amazon AWS of the company Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, 1855 Luxembourg, Luxembourg, e-mail: privacyshield@amazon.com, website: http://aws.amazon.com/. According to the assessment of Swiss authorities, the processing takes place in safe third countries. You can find the list of countries in Switzerland and further information at the following link: https://www.edoeb.admin.ch/edoeb/de/home/datenschutz/handel-und-wirtschaft/uebermittlung-ins-ausland.html. Personal data is also transferred to the U.S. With regard to the transfer of personal data to the U.S., there is an adequacy decision on the EU-US Data Privacy Framework of the EU Commission within the meaning of Art. 45 of the GDPR (hereinafter: DPF - https://commission.europa.eu/document/fa09cbad-dd7d-4684-ae60-be03fcb0fddf_en ). The operator of the service is certified under the DPF, so that the usual level of protection of the GDPR applies to the transfer.
The legal basis for the transmission of personal data is our legitimate interest in processing pursuant to Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in achieving the purpose described below.
Amazon AWS is a cloud computing offering from Amazon through which our site or individual elements of our site are reloaded. The separate AWS cloud enables us to download our website and its services from faster servers.
You can access the provider's certification under the EU-US Data Privacy Framework at https://www.dataprivacyframework.gov/list.
With regard to the processing, you have the right of objection listed in Art. 21 GDPR. You can find more information at the end of this privacy policy.
For further information on the handling of transmitted data, please refer to the provider's privacy policy at https://aws.amazon.com/de/privacy/?nc1=f_pr.
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Legally ok Rechtstextsnippet und Module
We use on our site the service Legally ok Rechtstextsnippet und Module of the company Legally ok GmbH, Schochenmühlestrasse 6, 6340 Baar, Switzerland, e-mail: hello@legally-ok.com, website: https://www.legally-ok.com/. Processing is carried out exclusively in Switzerland in accordance with the data protection legislation applicable there. The processing also takes place in a third country outside the EU. For this third country, there is an adequacy decision of the Commission. On the page of the EU Commission (link: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_de) you will find an up-to-date list of all adequacy decisions.
The legal basis for the transmission and processing is Art. 31 para. 1 FADP and Art. 6 para. 1 lit. c GDPR. The use of the service helps us to comply with our legal obligations.
With the help of the service, the contents of our legal texts are reloaded on our website. The respective current legal texts are reloaded via the integration on our page. This integration may also be used to reload further technical modules with regard to the legal texts or legally required elements.
You can find out what rights you have with regard to processing at the end of this privacy statement.
For further information on the handling of transmitted data, please refer to the provider's privacy policy at https://www.legally-ok.com/datenschutz/.
Data security and data protection, communication by e-mail
Your personal data is protected by technical and organisational measures during collection, storage and processing so that it is not accessible to third parties. In the case of unencrypted communication by e-mail, we cannot guarantee complete data security on the transmission path to our IT systems, so we recommend encrypted communication or the postal service for information requiring a high level of confidentiality.
Duration of data storage and rights of the data subject
Duration of storage
We store personal data only to the extent and for as long as necessary to fulfil the purposes for which the personal data was collected, we have a legitimate overriding interest in retaining the data or are legally obliged to do so.
Right to information
You have the right to request confirmation as to whether we are processing personal data about you. If this is the case, you have the right to information on the data specified in 25 ff. FADP or Art. 15 para. 1 GDPR, insofar as the information cannot be refused, restricted or postponed by the owner of the data collection (cf. Art. 26 f. FADP or Art. 15 para. 4 GDPR). We will also be happy to provide you with a copy of the data.
Right of rectification
Pursuant to Art. 32 (1) FADP or Art. 16 GDPR, you have the right to demand that incorrect personal data (e.g. address, name, etc.) be corrected, provided that there is no legal obligation to the contrary. You can also request that the data stored by us be completed at any time. A corresponding adjustment will be made immediately.
Right to erasure
Pursuant to Article 17 (1) of the GDPR, you have the right to have us delete the personal data we have collected about you if
- the data is either no longer required;
- the legal basis for processing has ceased to exist without replacement due to the revocation of your consent;
- there are no longer any legitimate reasons for processing the data;
- Your data is being processed unlawfully;
- a legal obligation requires this.
Pursuant to Article 17 (3) of the GDPR, this right does not exist if
- the processing is necessary for the exercise of the right to freedom of expression and information;
- Your data has been collected on the basis of a legal obligation;
- processing is necessary for reasons of public interest;
- the data is necessary for the assertion, exercise or defence of legal claims.
Right to restrict processing
According to Art. 18 (1) GDPR, you have the right to request the restriction of the processing of your personal data in individual cases.
This is the case when
- the accuracy of the personal data is disputed by you;
- the processing is unlawful and you do not consent to its deletion;
- the data is no longer required for the purpose of processing, but the collected data is used for the assertion, exercise or defence of legal claims;
- an objection to the processing has been lodged pursuant to Art. 21 (1) GDPR and it is still unclear which interests prevail.
Right of withdrawal
If you have given us express consent to process your personal data (Art. 6 para. 6 FADP and Art. 31 para. 1 FADP; Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR), you may revoke this consent at any time. Please note that the lawfulness of the processing carried out on the basis of the consent up to the revocation is not affected by this. Information for which we are legally obliged to retain data will be deleted after expiry of the deadline.
Right to object
In accordance with Art. 21 of the GDPR, you have the right to object at any time to the processing of personal data relating to you that has been collected on the basis of Art. 6 (1) f of the GDPR (in the context of a legitimate interest). If you have given us express consent to process your personal data (Art. 6 para. 6 FADP and Art. 31 para. 1 FADP), you may revoke this consent at any time. Please note that the lawfulness of the processing carried out on the basis of the consent up to the revocation is not affected by this. You only have this right if there are special circumstances that speak against the storage and processing. Information for which we are legally obliged to store data will be deleted after expiry of the deadline.
How do you exercise your rights?
You can exercise your rights at any time by contacting us using the contact details below:
AlohaSpirit GmbH
Alderstrasse 28
8008 Zurich
Switzerland
E-mail: info@alohaspirit.ch
Tel: +41 76 393 20 60
Right to data portability
Pursuant to Article 20 of the GDPR, you have a right to the transfer of personal data relating to you. We will provide the data in a structured, common and machine-readable format. The data can be sent either to you or to a person responsible named by you.
We will provide you with the following data upon request:
- Data collected on the basis of consent (Art. 31 para. 1 FADP as well as Art. 6 para. 1 let. a GDPR);
- Data that we have received from you in the context of existing contracts (Art. 31 para. 2 let. a FADP as well as Art. 6 para. 1 let. b GDPR and Art. 9 para. 2 let. a GDPR);
- Data that has been processed as part of an automated procedure.
We will transfer the personal data directly to a responsible person of your choice as far as this is technically feasible. Please note that we are not permitted to transfer data that interferes with the overriding interests of third parties, or only to a limited extent, pursuant to Art. 26 (1) b FADP or Art. 20 (4) GDPR.
Notifications to the FDPIC and possibility to file a complaint
Pursuant to Art. 49 FADP, data subjects may file a report with the supervisory authority if there are sufficient indications that a data processing operation could violate data protection regulations. The supervisory authority for data protection in Switzerland is the Federal Data Protection and Information Commissioner (FDPIC).
For further information, please consult the contact form of the FDPIC: https://www.edoeb.admin.ch/edoeb/de/home/deredoeb/kontakt.html
If you suspect that your data is being processed illegally on our website, you can seek clarification of the issue in court in accordance with Art. 32 FADP. As a rule, a lawsuit in accordance with Art. 28 ff. CC should be sought. If you are affected by the processing of data by federal bodies, the procedure is in accordance with Art. 41 FADP. In this case, you can also contact the FDPIC (see the reference to the contact form above).
Right of appeal to the supervisory authority pursuant to Art. 77 para. 1 GDPR
If you suspect that your data is being processed illegally on our site, you can of course have the issue clarified by the courts at any time. In addition, any other legal option is open to you. Irrespective of this, you have the option of contacting a supervisory authority in accordance with Article 77 (1) of the GDPR. The right of appeal pursuant to Art. 77 GDPR is available to you in the EU Member State of your place of residence, your place of work and/or the place of the alleged infringement, i.e. you can choose the supervisory authority to which you turn from the above-mentioned places. The supervisory authority to which the complaint has been submitted will then inform you of the status and outcome of your submission, including the possibility of a judicial remedy pursuant to Art. 78 GDPR.
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Our social media appearances
Data processing through social networks
We maintain publicly available profiles in social networks. The individual social networks we use can be found below.
Social networks such as Facebook, Twitter etc. can generally analyze your user behavior comprehensively if you visit their website or a website with integrated social media content (e.g. like buttons or banner ads). When you visit our social media pages, numerous data protection-relevant processing operations are triggered. In detail:
If you are logged in to your social media account and visit our social media page, the operator of the social media portal can assign this visit to your user account. Under certain circumstances, your personal data may also be recorded if you are not logged in or do not have an account with the respective social media portal. In this case, this data is collected, for example, via cookies stored on your device or by recording your IP address.
Using the data collected in this way, the operators of the social media portals can create user profiles in which their preferences and interests are stored. This way you can see interest-based advertising inside and outside of your social media presence. If you have an account with the social network, interest-based advertising can be displayed on any device you are logged in to or have logged in to.
Please also note that we cannot retrace all processing operations on the social media portals. Depending on the provider, additional processing operations may therefore be carried out by the operators of the social media portals. Details can be found in the terms of use and privacy policy of the respective social media portals.
Legal basis
Our social media appearances should ensure the widest possible presence on the Internet. This is a legitimate interest within the meaning of Art. 6 (1) lit. f GDPR. The analysis processes initiated by the social networks may be based on divergent legal bases to be specified by the operators of the social networks (e.g. consent within the meaning of Art. 6 (1) (a) GDPR).
Responsibility and assertion of rights
If you visit one of our social media sites (e.g., Facebook), we, together with the operator of the social media platform, are responsible for the data processing operations triggered during this visit. You can in principle protect your rights (information, correction, deletion, limitation of processing, data portability and complaint) vis-à-vis us as well as vis-à-vis the operator of the respective social media portal (e.g. Facebook).
Please note that despite the shared responsibility with the social media portal operators, we do not have full influence on the data processing operations of the social media portals. Our options are determined by the company policy of the respective provider.
Storage time
The data collected directly from us via the social media presence will be deleted from our systems as soon as you ask us to delete it, you revoke your consent to the storage or the purpose for the data storage lapses. Stored cookies remain on your device until you delete them. Mandatory statutory provisions - in particular, retention periods - remain unaffected.
We have no control over the storage duration of your data that are stored by the social network operators for their own purposes. For details, please contact the social network operators directly (e.g. in their privacy policy, see below).
Individual social networks
We have a profile on Facebook. The provider of this service is Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. According to Facebook’s statement the collected data will also be transferred to the USA and to other third-party countries.
We have signed an agreement with Facebook on shared responsibility for the processing of data (Controller Addendum). This agreement determines which data processing operations we or Facebook are responsible for when you visit our Facebook Fanpage. This agreement can be viewed at the following link: https://www.facebook.com/legal/terms/page_controller_addendum.
You can customize your advertising settings independently in your user account. Click on the following link and log in: https://www.facebook.com/settings?tab=ads.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum and https://de-de.facebook.com/help/566994660333381.
Details can be found in the Facebook privacy policy: https://www.facebook.com/about/privacy/.
We use the short message service Twitter. The provider is Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland.
You can customize your Twitter privacy settings in your user account. Click on the following link and log in: https://twitter.com/personalization.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://gdpr.twitter.com/en/controller-to-controller-transfers.html.
For details, see the Twitter Privacy Policy: https://twitter.com/privacy.
YouTube
We have a profile on YouTube. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Details on how they handle your personal data can be found in the YouTube privacy policy: https://policies.google.com/privacy?hl=en.