Privacy Policy

Privacy policy

Introduction

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as "data" for short) that we process, for what purposes and to what extent in the context of providing our application.

The terms used are not gender-specific.

Status: November 6, 2022

Responsible person

Marco Klein
Grünwalderstr. 41
81547 Munich

E-mail address:

impromat@marcoklein.dev

Overview of processing operations

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

Types of data processed

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

Categories of data subjects

  • Customers.
  • Interested parties.
  • Communication partners.
  • Users.

Purposes of processing

  • Provision of contractual services and customer service.
  • Contact requests and communication.
  • Security measures.
  • Direct marketing.
  • Management and response to requests.
  • Feedback.
  • Registration procedures.
  • Provision of our online offer and user-friendliness.
  • Information technology infrastructure.

Applicable legal bases

The following is an overview of the legal basis of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.

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

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

Security measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input of, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data, and responses to data compromise. Furthermore, we already consider the protection of personal data during the development or selection of hardware, software as well as procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Shortening of IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not necessary, the IP address is shortened (also referred to as "IP masking"). In this process, the last two digits or the last part of the IP address after a period are removed or replaced by wildcards. The shortening of the IP address is intended to prevent or make it significantly more difficult to identify a person by their IP address.

TLS encryption (https): To protect your data transmitted via our online offer, we use TLS encryption. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.

Transmission of personal data

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

Data transfer within the organization: We may transfer personal data to other entities within our organization or grant them access to such data. Where this transfer is for administrative purposes, the transfer of data is based on our legitimate business and operational interests or is made where it is necessary to fulfill our contract-related obligations or where we have the consent of the data subjects or legal permission.

Data processing in third countries

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

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

Deletion of data

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

Our data protection notices may also contain further details on the retention and deletion of data, which have priority for the respective processing operations.

Use of cookies

Cookies are small text files, or other memory notes that store information on end devices and read information from the end devices. E.g. to store the login status in a user account, a shopping cart content in an e-shop, the accessed content or used functions of an online offer. Cookies can further be used for various purposes, e.g. for purposes of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows.

Notes on consent: We use cookies in accordance with legal requirements. Therefore, we obtain prior consent from users, except where it is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary to provide the user with a telemedia service (i.e. our online offering) that they have expressly requested. The revocable consent will be clearly communicated to the users and will contain the information about the respective cookie use.

Notes on legal bases under data protection law: The legal basis under data protection law on which we process users' personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and improvement of its usability) or, if this is done in the context of the performance of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. For what purposes the cookies are processed by us, we clarify in the course of this privacy policy or in the context of our consent and processing processes.

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

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

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

Further notes on processing operations, procedures and services:

  • Processing of cookie data on the basis of consent: We use a cookie consent management procedure in the context of which the consent of users to the use of cookies, or the processing and providers named in the cookie consent management procedure, can be obtained and managed and revoked by users. Here, the declaration of consent is stored in order not to have to repeat its query and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or with the help of comparable technologies), in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g., which categories of cookies and/or service providers), as well as the browser, system and end device used.

Provision of the online services and web hosting

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

  • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.).); security measures.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further notes on processing processes, procedures and services:.

  • Provision of online offer on own/ dedicated server hardware: For the provision of our online offer, we use server hardware operated by us as well as the associated storage space, computing capacity and software; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

  • Collection of access data and log files: Access to our online offer is logged in the form of so-called "server log files". The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used, on the one hand, for security purposes, e.g., to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.

  • contabo: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: Contabo GmbH, Aschauer Straße 32a, D-81549 Munich, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.contabo.com/; Data protection statement: https://contabo.com/de/legal/privacy/.

Registration, login and user account

Users can create a user account. In the course of registration, users are provided with the required mandatory data and processed for the purpose of providing the user account on the basis of contractual obligation fulfillment. The processed data includes in particular the login information (username, password and an e-mail address).

In the context of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorized use. As a matter of principle, this data is not passed on to third parties unless it is necessary for the pursuit of our claims or there is a legal obligation to do so.

Users may be informed by e-mail about processes relevant to their user account, such as technical changes.

  • Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Providing contractual services and customer service; security measures; managing and responding to requests; providing our online services and user experience.
  • Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further notes on processing operations, procedures and services:.

  • Registration with pseudonyms: Users are allowed to use pseudonyms as usernames instead of plain names; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
  • Profiles of users are public: Users' profiles are publicly visible and accessible; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
  • Setting the visibility of profiles:** Users can use settings to determine the extent to which their profiles are visible to the public or accessible only to certain groups of people; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
  • Deletion of data after termination: If users have terminated their user account, their data with regard to the user account will be deleted, subject to any legal permission, obligation or consent of the users; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
  • No obligation to retain data: It is incumbent on users to back up their data in the event of termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Community functions

The community functions provided by us allow users to enter into conversations or other exchanges with each other. Please note that the use of the community functions is only permitted in compliance with the applicable legal situation, our terms and guidelines and the rights of other users and third parties.

  • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and customer service; security measures.
  • Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Further notes on processing operations, procedures and services:.

  • Posts by users are public: Posts and content created by users are publicly visible and accessible; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
  • Users can use settings to determine the extent to which the posts and content they create are visible or accessible to the public or only to certain persons or groups; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
  • Storage of data for security purposes: The contributions and other input of users are processed for the purposes of the community and conversation functions and, subject to legal obligations or legal permission, are not released to third parties. An obligation to surrender may arise in particular in the case of illegal contributions for the purposes of legal prosecution. We point out that in addition to the content of the contributions, their time and the IP address of the user are stored. This is done in order to be able to take appropriate measures to protect other users and the community; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
  • Right to delete content and information: The deletion of posts, content or information of users is permissible after proper consideration to the extent necessary insofar as there are concrete indications that they represent a violation of legal rules, our specifications or rights of third parties; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
  • Restricted deletion of conversation posts: Out of consideration for other users, conversation posts of the user remain stored even after termination and account deletion, so that conversations, comments, advice, or the like. Communication between and among users do not lose their meaning or reverse. User names are deleted or pseudonymized if they were not already pseudonyms. Users can assert the complete deletion of the conversation contributions at any time with us; Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).
  • Protection of own data: Users themselves decide what data they disclose about themselves within our online offering. For example, when users provide information about themselves or participate in conversations. We ask users to protect their data and to disclose personal data only with caution and only to the extent necessary. In particular, we ask users to note that they must protect access data very particularly and use secure passwords (i.e., above all, character combinations that are as long and random as possible); Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Single sign-on logon

Single sign-on" or "single sign-on logon or authentication" refers to procedures that allow users to log on to a provider of single sign-on procedures (e.g., a social network), including our online offering, using a user account. The prerequisite for single sign-on authentication is that users are registered with the respective single sign-on provider and enter the required access data in the online form provided for this purpose, or are already registered with the single sign-on provider and confirm the single sign-on registration via button.

Authentication takes place directly with the respective single sign-on provider. In the course of such authentication, we receive a user ID with the information that the user is logged in under this user ID at the respective single sign-on provider and an ID that cannot be used by us for other purposes (so-called "user handle"). Whether additional data is transmitted to us depends solely on the single sign-on procedure used, on the data releases selected as part of the authentication process and also on which data users have released in the privacy or other settings of the user account with the single sign-on provider. Depending on the single sign-on provider and the user's choice, this can be different data, usually the e-mail address and the user name. The password entered as part of the single sign-on procedure with the single sign-on provider is neither visible to us nor is it stored by us.

Users are asked to note that their details stored with us may be automatically compared with their user account with the single sign-on provider, but that this is not always possible or actually occurs. If, for example, users' e-mail addresses change, they must change them manually in their user account with us.

We may use the single sign-on login, if agreed with users, as part of or prior to the performance of the contract, if users have been asked to do so, process it as part of consent, and otherwise use it based on the legitimate interests of us and the interests of users in an effective and secure login system.

Should users ever decide that they no longer wish to use the link of their user account with the single sign-on provider for the single sign-on procedure, they must remove this link within their user account with the single sign-on provider. If users wish to delete their data from us, they must cancel their registration with us.

  • Types of data processed: Inventory data (e.g., names, addresses); contact data (e.g., e-mail, phone numbers); usage data (e.g., web pages visited, interest in content, access times); meta/communication data (e.g., device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and customer service; security measures; login procedures.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further notes on processing operations, procedures and services:.

Contact and inquiry management

When contacting us (e.g. via contact form, email, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested actions.

  • Types of data processed: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partners.
  • Purposes of processing: Contact requests and communication; managing and responding to requests; feedback (e.g., collecting feedback via online form); providing our online service and user experience.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Further notes on processing operations, procedures and services:

  • Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context to process the communicated request; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Change and update of the privacy policy

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

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

Rights of the data subjects

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

  • Right of objection: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Art. 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing..
  • Right to revoke consent: You have the right to revoke any consent given at any time.
  • Right of access: You have the right to request confirmation as to whether data in question is being processed and to obtain information about such data, as well as further information and a copy of the data in accordance with the law.
  • Right to rectification: You have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified.
  • Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data concerning you be erased without delay, or alternatively, in accordance with the law, to request restriction of the processing of the data.
  • Right to data portability: You have the right to receive data relating to you that you have provided to us in a structured, common and machine-readable format, or to request that it be transferred to another controller, in accordance with the law.
  • Complaint to supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the requirements of the GDPR.

Definitions of terms

This section provides you with an overview of the terms used in this Privacy Policy. Many of the terms are taken from the law and defined primarily in Article 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding. The terms are sorted alphabetically.

  • Personal data: "Personal data" means 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, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Controller: "Controller" means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
  • Processing: "Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data, whether collecting, evaluating, storing, transmitting or erasing.

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