Privacy policy
Preamble
With this privacy policy we would like to inform you about the types of your personal data (hereinafter also referred to simply as "data") that we process, for what purposes and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the course of providing our services and, in particular, on our websites, in mobile applications and within external online presences. The terms used are not gender-specific.
Last updated: 11 October 2023
Legal text by Dr. Schwenke
Last updated: 11 October 2023
Legal text by Dr. Schwenke
Table of contents
- Preamble
- Controller
- Overview of processing operations
- Relevant legal bases
- Security measures
- Disclosure of personal data
- International data transfers
- Rights of data subjects
- Use of cookies
- Business services
- Providers and services used in the course of business
- Payment methods
- Provision of the online offering and web hosting
- Registration, login and user account
- Blogs and publication media
- Contact and enquiry management
- Communication via messenger
- Video conferences, online meetings, webinars and screen sharing
- Audio content
- Application process
- Cloud services
- Newsletters and electronic notifications
- Promotional communication via email, post, fax or telephone
- Prize draws and competitions
- Web analytics, monitoring and optimisation
- Online marketing
- Customer reviews and rating procedures
- Plugins and embedded functions and content
- Management, organisation and auxiliary tools
- Changes and updates to this privacy policy
Controller
BB Wertmetall AG
Bachstrasse 40
Postfach 612
CH-5600 Lenzburg 1
Email address:
service@bb-wertmetall.ch
Legal notice:
https://www.bb-wertmetall.ch/impressum/
Bachstrasse 40
Postfach 612
CH-5600 Lenzburg 1
Email address:
service@bb-wertmetall.ch
Legal notice:
https://www.bb-wertmetall.ch/impressum/
Overview of processing operations
The following overview summarises the types of data processed and the purposes of their processing, and refers to the data subjects concerned.
Types of data processed
- Master data.
- Payment data.
- Contact data.
- Content data.
- Contract data.
- Usage data.
- Meta, communication and procedural data.
- Applicant data.
Categories of data subjects
- Customers.
- Employees.
- Prospective customers.
- Communication partners.
- Users.
- Applicants.
- Participants in prize draws and competitions.
- Business and contractual partners.
- Persons depicted.
Purposes of processing
- Provision of contractual services and fulfilment of contractual obligations.
- Contact requests and communication.
- Security measures.
- Direct marketing.
- Reach measurement.
- Tracking.
- Office and organisational procedures.
- Conversion measurement.
- Management and handling of enquiries.
- Application process.
- Conducting prize draws and competitions.
- Feedback.
- Marketing.
- Profiles with user-related information.
- Provision of our online offering and user-friendliness.
- Information technology infrastructure.
Relevant legal bases
Relevant legal bases under the Swiss Federal Act on Data Protection: If you are located in Switzerland, we process your data on the basis of the Federal Act on Data Protection (hereinafter "Swiss FADP"). This also applies if our processing of your data otherwise concerns you in Switzerland and you are affected by the processing. In principle, the Swiss FADP does not require (unlike, for example, the GDPR) that a legal basis be stated for the processing of personal data. We process personal data only if the processing is lawful, carried out in good faith and proportionate (Art. 6 paras. 1 and 2 of the Swiss FADP). Furthermore, we collect personal data only for specific purposes that are recognisable to the data subject and process it only in a way that is compatible with these purposes (Art. 6 para. 3 of the Swiss FADP).
Security measures
In accordance with the statutory requirements, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we implement appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.
These 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 it, input, disclosure, ensuring availability and separation. We have also established procedures to ensure the exercise of data subject rights, the deletion of data and responses to threats to the data. Furthermore, we take the protection of personal data into account already during the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default.
Shortening of the IP address: Where IP addresses are processed by us or by the service providers and technologies used, and processing 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 full stop, are removed or replaced by placeholders. Shortening the IP address is intended to prevent, or make significantly more difficult, the identification of a person on the basis of their IP address.
TLS/SSL encryption (https): To protect the data of users transmitted via our online services, we use TLS/SSL encryption. Secure Sockets Layer (SSL) is the standard technology for securing internet connections by encrypting the data transmitted between a website or app and a browser (or between two servers). Transport Layer Security (TLS) is an updated and more secure version of SSL. Hyper Text Transfer Protocol Secure (HTTPS) is displayed in the URL when a website is secured by an SSL/TLS certificate.
These 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 it, input, disclosure, ensuring availability and separation. We have also established procedures to ensure the exercise of data subject rights, the deletion of data and responses to threats to the data. Furthermore, we take the protection of personal data into account already during the development or selection of hardware, software and procedures, in accordance with the principle of data protection by design and by default.
Shortening of the IP address: Where IP addresses are processed by us or by the service providers and technologies used, and processing 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 full stop, are removed or replaced by placeholders. Shortening the IP address is intended to prevent, or make significantly more difficult, the identification of a person on the basis of their IP address.
TLS/SSL encryption (https): To protect the data of users transmitted via our online services, we use TLS/SSL encryption. Secure Sockets Layer (SSL) is the standard technology for securing internet connections by encrypting the data transmitted between a website or app and a browser (or between two servers). Transport Layer Security (TLS) is an updated and more secure version of SSL. Hyper Text Transfer Protocol Secure (HTTPS) is displayed in the URL when a website is secured by an SSL/TLS certificate.
Disclosure of personal data
In the course of our processing of personal data, data may be transmitted to, or disclosed to, other bodies, companies, legally independent organisational 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 embedded in a website. In such cases we comply with the statutory requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.
Data transfer within the group of companies: We may transmit personal data to other companies within our group of companies or grant them access to this data. Where this disclosure takes place for administrative purposes, it is based on our legitimate business and commercial interests, or takes place where it is necessary to fulfil our contractual obligations or where the consent of the data subjects or a statutory permission exists.
Data transfer within the group of companies: We may transmit personal data to other companies within our group of companies or grant them access to this data. Where this disclosure takes place for administrative purposes, it is based on our legitimate business and commercial interests, or takes place where it is necessary to fulfil our contractual obligations or where the consent of the data subjects or a statutory permission exists.
International data transfers
Data processing in third countries: If we process data in a third country (i.e. outside the European Union (EU) and the European Economic Area (EEA)), or if the processing takes place in the course of using third-party services or the disclosure or transfer of data to other persons, bodies or companies, this only takes place in accordance with the statutory requirements. If the level of data protection in the third country has been recognised by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers only take place if the level of data protection is ensured in another way, in particular by standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), explicit consent or, in the case of transfers required by contract or by law (Art. 49 para. 1 GDPR). Otherwise, we inform you of the basis for the third-country transfer for the individual providers from the third country, with adequacy decisions taking priority as the basis. Information on third-country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de.
Disclosure of personal data abroad: In accordance with the Swiss Federal Act on Data Protection (FADP), we disclose personal data abroad only if adequate protection of the data subjects is ensured (Art. 16 Swiss FADP). Where the Federal Council has not determined adequate protection (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we take alternative security measures. These may include international treaties, specific guarantees, data protection clauses in contracts, standard data protection clauses approved by the Federal Data Protection and Information Commissioner (FDPIC), or binding corporate data protection rules recognised in advance by the FDPIC or by a competent data protection authority of another country.
According to Art. 16 of the Swiss FADP, exceptions to the disclosure of data abroad may be permitted if certain conditions are met, including consent of the data subject, performance of a contract, public interest, protection of life or physical integrity, data made public, or data from a register provided for by law. Such disclosures always take place in accordance with the statutory requirements.
Disclosure of personal data abroad: In accordance with the Swiss Federal Act on Data Protection (FADP), we disclose personal data abroad only if adequate protection of the data subjects is ensured (Art. 16 Swiss FADP). Where the Federal Council has not determined adequate protection (list: https://www.bj.admin.ch/bj/de/home/staat/datenschutz/internationales/anerkennung-staaten.html), we take alternative security measures. These may include international treaties, specific guarantees, data protection clauses in contracts, standard data protection clauses approved by the Federal Data Protection and Information Commissioner (FDPIC), or binding corporate data protection rules recognised in advance by the FDPIC or by a competent data protection authority of another country.
According to Art. 16 of the Swiss FADP, exceptions to the disclosure of data abroad may be permitted if certain conditions are met, including consent of the data subject, performance of a contract, public interest, protection of life or physical integrity, data made public, or data from a register provided for by law. Such disclosures always take place in accordance with the statutory requirements.
Rights of data subjects
Rights of data subjects under the GDPR: As a data subject, you have various rights under the GDPR, arising in particular from Art. 15 to 21 GDPR:
Rights of data subjects under the Swiss FADP:
As a data subject, you have the following rights under the provisions of the Swiss FADP:
- Right to object: 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 based on Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. Where personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw any consent given at any time.
- Right of access: You have the right to obtain confirmation as to whether data concerning you is being processed, and to obtain access to this data as well as further information and a copy of the data in accordance with the statutory requirements.
- Right to rectification: In accordance with the statutory requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
- Right to erasure and restriction of processing: In accordance with the statutory requirements, you have the right to request that data concerning you be erased without undue delay or, alternatively, in accordance with the statutory requirements, to request a restriction of the processing of the data.
- Right to data portability: You have the right to receive data concerning you that you have provided to us, in accordance with the statutory requirements, in a structured, commonly used and machine-readable format, or to request its transmission to another controller.
- Complaint to a supervisory authority: In accordance with the statutory requirements, and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the member state where you habitually reside, the supervisory authority of your place of work or of the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.
Rights of data subjects under the Swiss FADP:
As a data subject, you have the following rights under the provisions of the Swiss FADP:
- Right of access: You have the right to obtain confirmation as to whether personal data concerning you is being processed, and to receive the information necessary for you to assert your rights under this Act and for transparent data processing to be ensured.
- Right to the handover or transfer of data: You have the right to request the handover of your personal data that you have disclosed to us, in a commonly used electronic format.
- Right to rectification: You have the right to request the rectification of inaccurate personal data concerning you.
- Right to object, erasure and destruction: You have the right to object to the processing of your data, and to request that personal data concerning you be erased or destroyed.
Use of cookies
Cookies are small text files, or other storage notes, that store information on end devices and read information from end devices. For example, to store the login status in a user account, the contents of a shopping cart in an online shop, the content accessed or the functions used of an online offering. Cookies can also be used for various other purposes, e.g. for the functionality, security and convenience of online offerings and for the creation of analyses of visitor flows.
Notes on consent: We use cookies in accordance with the statutory provisions. We therefore obtain prior consent from users, unless this is not required by law. Consent is in particular not necessary if the storing and reading of the information, including cookies, is strictly necessary in order to provide users with a telemedia service (i.e. our online offering) that they have expressly requested. Strictly necessary cookies generally include cookies with functions that serve the display and operability of the online offering, load balancing, security, the storage of users' preferences and choices, or similar purposes connected with providing the main and secondary functions of the online offering requested by users. Consent, which can be withdrawn, is clearly communicated to users and contains the information on the respective use of cookies.
Notes on data protection legal bases: The data protection legal basis on which we process users' personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for the processing of their data is the consent declared. Otherwise, data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and the improvement of its usability) or, where this takes place in the course of fulfilling our contractual obligations, where the use of cookies is necessary to fulfil our contractual obligations. We explain the purposes for which we process cookies in the course of this privacy policy or within our consent and processing procedures.
Storage period: With regard to the storage period, the following types of cookies are distinguished:
General notes on withdrawal and objection (so-called "opt-out"): Users can withdraw their consent at any time and object to the processing in accordance with the statutory requirements. For this purpose, users can, among other things, restrict the use of cookies in their browser settings (although this may also restrict the functionality of our online offering). 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:
Notes on consent: We use cookies in accordance with the statutory provisions. We therefore obtain prior consent from users, unless this is not required by law. Consent is in particular not necessary if the storing and reading of the information, including cookies, is strictly necessary in order to provide users with a telemedia service (i.e. our online offering) that they have expressly requested. Strictly necessary cookies generally include cookies with functions that serve the display and operability of the online offering, load balancing, security, the storage of users' preferences and choices, or similar purposes connected with providing the main and secondary functions of the online offering requested by users. Consent, which can be withdrawn, is clearly communicated to users and contains the information on the respective use of cookies.
Notes on data protection legal bases: The data protection legal basis on which we process users' personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for the processing of their data is the consent declared. Otherwise, data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and the improvement of its usability) or, where this takes place in the course of fulfilling our contractual obligations, where the use of cookies is necessary to fulfil our contractual obligations. We explain the purposes for which we process cookies in the course of this privacy policy or within our consent and processing procedures.
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 offering and closed their end device (e.g. browser or mobile application).
- Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be stored or preferred content can be displayed directly when the user visits a website again. Likewise, the users' data collected with the help of cookies may be used for reach measurement. Unless we give users explicit information on the type and storage period of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that the storage period may be up to two years.
General notes on withdrawal and objection (so-called "opt-out"): Users can withdraw their consent at any time and object to the processing in accordance with the statutory requirements. For this purpose, users can, among other things, restrict the use of cookies in their browser settings (although this may also restrict the functionality of our online offering). 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/.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Further notes on processing operations, procedures and services:
- Processing of cookie data on the basis of consent: We use a cookie consent management procedure within the framework of which users' consent to the use of cookies, or to the processing operations and providers named in the cookie consent management procedure, is obtained and can be managed and withdrawn by users. The declaration of consent is stored so that the request does not have to be repeated and so that consent can be proven in accordance with the statutory obligation. Storage may take place on the server side and/or in a cookie (a so-called opt-in cookie, or by means of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following notes apply: The consent may be stored for up to two years. A pseudonymous user identifier is created and stored together with the time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) and the browser, system and end device used; legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Business services
We process the data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as "contractual partners"), in the context of contractual and comparable legal relationships and related measures and in the context of communication with the contractual partners (or pre-contractually), e.g. to answer enquiries.
We process this data in order to fulfil our contractual obligations. These include in particular the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to safeguard our rights and for the purposes of the administrative tasks associated with these obligations as well as company organisation. Furthermore, we process the data on the basis of our legitimate interests in proper and economic business management as well as in security measures to protect our contractual partners and our business operations from misuse and from endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisers, payment service providers or tax authorities). Within the scope of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. Contractual partners are informed about further forms of processing, e.g. for marketing purposes, within the framework of this privacy policy.
We inform contractual partners before or in the course of data collection which data is required for the aforementioned purposes, e.g. in online forms, by special marking (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e. in principle after the expiry of 4 years, unless the data is stored in a customer account, e.g. for as long as it must be retained for legal archiving reasons. The statutory retention period is ten years for documents relevant to tax law as well as for commercial books, inventories, opening balance sheets, annual financial statements, the work instructions required to understand these documents and other organisational documents and accounting vouchers, and six years for received commercial and business letters and reproductions of sent commercial and business letters. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was drawn up, the commercial or business letter was received or sent or the accounting voucher was created, and in which the record was made or the other documents were created.
Where we use third-party providers or platforms to provide our services, the terms and conditions and privacy notices of the respective third-party providers or platforms apply in the relationship between users and the providers.
Further notes on processing operations, procedures and services:
We process this data in order to fulfil our contractual obligations. These include in particular the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to safeguard our rights and for the purposes of the administrative tasks associated with these obligations as well as company organisation. Furthermore, we process the data on the basis of our legitimate interests in proper and economic business management as well as in security measures to protect our contractual partners and our business operations from misuse and from endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisers, payment service providers or tax authorities). Within the scope of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations. Contractual partners are informed about further forms of processing, e.g. for marketing purposes, within the framework of this privacy policy.
We inform contractual partners before or in the course of data collection which data is required for the aforementioned purposes, e.g. in online forms, by special marking (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
We delete the data after the expiry of statutory warranty and comparable obligations, i.e. in principle after the expiry of 4 years, unless the data is stored in a customer account, e.g. for as long as it must be retained for legal archiving reasons. The statutory retention period is ten years for documents relevant to tax law as well as for commercial books, inventories, opening balance sheets, annual financial statements, the work instructions required to understand these documents and other organisational documents and accounting vouchers, and six years for received commercial and business letters and reproductions of sent commercial and business letters. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was drawn up, the commercial or business letter was received or sent or the accounting voucher was created, and in which the record was made or the other documents were created.
Where we use third-party providers or platforms to provide our services, the terms and conditions and privacy notices of the respective third-party providers or platforms apply in the relationship between users and the providers.
- Types of data processed: Master data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. email, telephone numbers); contract data (e.g. subject matter of the contract, term, customer category).
- Data subjects: Prospective customers. Business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; contact requests and communication; office and organisational procedures. Management and handling of enquiries.
- Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further notes on processing operations, procedures and services:
- Precious metals dealer: Our precious metals trade deals with the purchase and sale of silver and gold. The primary function of our company is to offer both private individuals and business customers a platform for trading precious metals, whether in the form of medals or other precious metal products. We use modern technologies and proven procedures to ensure the best possible service and to safeguard the integrity of all transactions. In the course of our business activities, we collect and process certain personal data of our customers in order to conclude contracts, to ensure the authenticity of transactions and to comply with legal provisions. We undertake to treat this data confidentially and to protect it in accordance with the applicable data protection provisions. Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Providers and services used in the course of business
In the course of our business activities, we use, in compliance with the statutory requirements, additional services, platforms, interfaces or plug-ins from third-party providers (in short "services"). Their use is based on our interests in the proper, lawful and economic conduct of our business operations and our internal organisation.
- Types of data processed: Master data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); contract data (e.g. subject matter of the contract, term, customer category).
- Data subjects: Customers; prospective customers; users (e.g. website visitors, users of online services). Business and contractual partners.
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations. Office and organisational procedures.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Payment methods
In the context of contractual and other legal relationships, on the basis of legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and, for this purpose, use other service providers in addition to banks and credit institutions (collectively "payment service providers").
The data processed by the payment service providers includes master data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, amount and recipient-related information. This information is required to carry out the transactions. However, the data entered is processed and stored only by the payment service providers. That means we do not receive any account or credit card-related information, but only information confirming or rejecting the payment. In certain circumstances, the data may be transmitted by the payment service providers to credit reference agencies. The purpose of this transmission is to verify identity and creditworthiness. In this regard, we refer to the terms and conditions and the privacy notices of the payment service providers.
The terms and conditions and privacy notices of the respective payment service providers, which can be accessed within the respective websites or transaction applications, apply to the payment transactions. We also refer to these for further information and for the exercise of rights of withdrawal, access and other data subject rights.
The data processed by the payment service providers includes master data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, amount and recipient-related information. This information is required to carry out the transactions. However, the data entered is processed and stored only by the payment service providers. That means we do not receive any account or credit card-related information, but only information confirming or rejecting the payment. In certain circumstances, the data may be transmitted by the payment service providers to credit reference agencies. The purpose of this transmission is to verify identity and creditworthiness. In this regard, we refer to the terms and conditions and the privacy notices of the payment service providers.
The terms and conditions and privacy notices of the respective payment service providers, which can be accessed within the respective websites or transaction applications, apply to the payment transactions. We also refer to these for further information and for the exercise of rights of withdrawal, access and other data subject rights.
- Types of data processed: Master data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
- Data subjects: Customers. Prospective customers.
- Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Provision of the online offering and web hosting
We process users' data in order to be able to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the users' browser or end device.
Further notes on processing operations, procedures and services:
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status); content data (e.g. entries in online forms).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further notes on processing operations, procedures and services:
- Provision of the online offering on rented storage space: To provide our online offering, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called a "web host"); legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Service provider: undefined; Website: undefined. Privacy policy: undefined.
- Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". Server log files may include the address and name of the web pages and files accessed, the 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. Server log files can be used, on the one hand, for security purposes, e.g. to avoid overloading the servers (in particular in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the load and stability of the servers; legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further retention is necessary for evidential purposes is excluded from deletion until the respective incident has been finally clarified.
- WordPress.com: Hosting and software for the creation, provision and operation of websites, blogs and other online offerings; Service provider: Aut O’Mattic A8C Irland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://wordpress.com; Privacy policy: https://automattic.com/de/privacy/; Data processing agreement: https://wordpress.com/support/data-processing-agreements/. Basis for third-country transfer: EU-US Data Privacy Framework (DPF).
Registration, login and user account
Users can create a user account. During registration, users are informed of the mandatory information required, and this is processed for the purpose of providing the user account on the basis of contractual obligations. The data processed includes in particular the login information (user name, password and an email address).
When our registration and login functions are used, and when the user account is used, we store the IP address and the time of the respective user action. This storage takes place on the basis of our legitimate interests as well as those of the users in protection against misuse and other unauthorised use. This data is in principle not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users may be informed by email about events relevant to their user account, such as technical changes.
Further notes on processing operations, procedures and services:
When our registration and login functions are used, and when the user account is used, we store the IP address and the time of the respective user action. This storage takes place on the basis of our legitimate interests as well as those of the users in protection against misuse and other unauthorised use. This data is in principle not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so.
Users may be informed by email about events relevant to their user account, such as technical changes.
- Types of data processed: Master data (e.g. names, addresses); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; security measures; management and handling of enquiries. Provision of our online offering and user-friendliness.
- Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further notes on processing operations, procedures and services:
- User profiles are not public: User profiles are neither visible nor accessible to the public.
Blogs and publication media
We use blogs or comparable means of online communication and publication (hereinafter "publication medium"). Readers' data is processed for the purposes of the publication medium only to the extent necessary for its presentation and for communication between authors and readers, or for security reasons. Otherwise, we refer to the information on the processing of visitors to our publication medium within this privacy notice.
Further notes on processing operations, procedures and services:
- Types of data processed: Master data (e.g. names, addresses); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; feedback (e.g. collecting feedback via online form); provision of our online offering and user-friendliness; security measures. Management and handling of enquiries.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further notes on processing operations, procedures and services:
- Comments and posts: When users leave comments or other posts, their IP addresses may be stored on the basis of our legitimate interests. This is done for our security, in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves may be held liable for the comment or post and are therefore interested in the identity of the author.
Furthermore, we reserve the right to process users' information for the purpose of spam detection on the basis of our legitimate interests.
On the same legal basis, we reserve the right, in the case of polls, to store users' IP addresses for the duration of the poll and to use cookies in order to avoid multiple votes.
The personal information, any contact and website information, and the content provided in the comments and posts are stored by us permanently until the users object;
legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Contact and enquiry management
When contacting us (e.g. by post, contact form, email, telephone or via social media) and within the framework of existing user and business relationships, the information provided by the persons making the enquiry is processed to the extent necessary to respond to the contact requests and any measures requested.
- Types of data processed: Contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
- Data subjects: Communication partners.
- Purposes of processing: Contact requests and communication; management and handling of enquiries; feedback (e.g. collecting feedback via online form). Provision of our online offering and user-friendliness.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Communication via messenger
We use messengers for communication purposes and therefore ask you to note the following information on how messengers work, on encryption, on the use of the metadata of the communication and on your options to object.
You can also contact us by alternative means, e.g. by telephone or email. Please use the contact options provided to you or the contact options stated within our online offering.
In the case of end-to-end encryption of content (i.e. the content of your message and attachments), we point out that the communication content (i.e. the content of the message and attached images) is encrypted end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messenger with encryption activated so that the encryption of the message content is ensured.
However, we also point out to our communication partners that although the messenger providers cannot view the content, they can find out that and when communication partners communicate with us, and technical information on the device used by the communication partners and, depending on the settings of their device, also location information (so-called metadata) is processed.
Notes on legal bases: If we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us of their own accord, for example, we use messengers in relation to our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other prospective customers and communication partners, on the basis of our legitimate interests in fast and efficient communication and in meeting the needs of our communication partners for communication via messenger. We also point out that we do not transmit the contact data provided to us to the messengers for the first time without your consent.
Withdrawal, objection and deletion: You can withdraw any consent given at any time and object to communication with us via messenger at any time. In the case of communication via messenger, we delete the messages in accordance with our general deletion policies (i.e. for example, as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any enquiries from the communication partners, no reference back to a previous conversation is to be expected and no statutory retention obligations stand in the way of deletion.
Reservation of referral to other means of communication: Finally, we would like to point out that, for reasons of your security, we reserve the right not to respond to enquiries via messenger. This is the case, for example, if contract internals require special confidentiality or a reply via messenger does not meet the formal requirements. In such cases we refer you to more appropriate means of communication.
You can also contact us by alternative means, e.g. by telephone or email. Please use the contact options provided to you or the contact options stated within our online offering.
In the case of end-to-end encryption of content (i.e. the content of your message and attachments), we point out that the communication content (i.e. the content of the message and attached images) is encrypted end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messenger with encryption activated so that the encryption of the message content is ensured.
However, we also point out to our communication partners that although the messenger providers cannot view the content, they can find out that and when communication partners communicate with us, and technical information on the device used by the communication partners and, depending on the settings of their device, also location information (so-called metadata) is processed.
Notes on legal bases: If we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us of their own accord, for example, we use messengers in relation to our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other prospective customers and communication partners, on the basis of our legitimate interests in fast and efficient communication and in meeting the needs of our communication partners for communication via messenger. We also point out that we do not transmit the contact data provided to us to the messengers for the first time without your consent.
Withdrawal, objection and deletion: You can withdraw any consent given at any time and object to communication with us via messenger at any time. In the case of communication via messenger, we delete the messages in accordance with our general deletion policies (i.e. for example, as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume that we have answered any enquiries from the communication partners, no reference back to a previous conversation is to be expected and no statutory retention obligations stand in the way of deletion.
Reservation of referral to other means of communication: Finally, we would like to point out that, for reasons of your security, we reserve the right not to respond to enquiries via messenger. This is the case, for example, if contract internals require special confidentiality or a reply via messenger does not meet the formal requirements. In such cases we refer you to more appropriate means of communication.
- Types of data processed: Contact data (e.g. email, telephone numbers); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status); content data (e.g. entries in online forms).
- Data subjects: Communication partners.
- Purposes of processing: Contact requests and communication; direct marketing (e.g. by email or post).
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Video conferences, online meetings, webinars and screen sharing
We use platforms and applications of other providers (hereinafter referred to as "conference platforms") for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as "conference"). When selecting the conference platforms and their services, we comply with the statutory requirements.
Data processed by conference platforms: In the course of participating in a conference, the conference platforms process the following personal data of the participants. The scope of the processing depends, on the one hand, on which data is requested in the context of a specific conference (e.g. provision of access data or real names) and which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants' data may also be processed by the conference platforms for security purposes or service optimisation. The data processed includes personal data (first name, last name), contact information (email address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the internet access, information on the participants' end devices, their operating system, the browser and its technical and language settings, information on the content-related communication processes, i.e. entries in chats as well as audio and video data, as well as the use of other available functions (e.g. polls). The content of communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users with the conference platforms, further data may be processed in accordance with the agreement with the respective conference provider.
Logging and recordings: If text entries, participation results (e.g. from polls) and video or audio recordings are logged, participants will be informed of this transparently in advance and, where necessary, asked for their consent.
Data protection measures of the participants: For details on the processing of your data by the conference platforms, please refer to their privacy notices and select the security and privacy settings that are optimal for you within the settings of the conference platforms. Please also ensure data and personality protection in the background of your recording for the duration of a video conference (e.g. by informing housemates, locking doors and, as far as technically possible, using the function to blur the background). Links to the conference rooms and access data must not be passed on to unauthorised third parties.
Notes on legal bases: If, in addition to the conference platforms, we also process users' data and ask users for their consent to the use of the conference platforms or certain functions (e.g. consent to the recording of conferences), this consent is the legal basis for the processing. Furthermore, our processing may be necessary to fulfil our contractual obligations (e.g. in participant lists, in the case of follow-up on discussion outcomes, etc.). Otherwise, users' data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.
Data processed by conference platforms: In the course of participating in a conference, the conference platforms process the following personal data of the participants. The scope of the processing depends, on the one hand, on which data is requested in the context of a specific conference (e.g. provision of access data or real names) and which optional information is provided by the participants. In addition to processing for the purpose of conducting the conference, participants' data may also be processed by the conference platforms for security purposes or service optimisation. The data processed includes personal data (first name, last name), contact information (email address, telephone number), access data (access codes or passwords), profile pictures, information on professional position/function, the IP address of the internet access, information on the participants' end devices, their operating system, the browser and its technical and language settings, information on the content-related communication processes, i.e. entries in chats as well as audio and video data, as well as the use of other available functions (e.g. polls). The content of communications is encrypted to the extent technically provided by the conference providers. If participants are registered as users with the conference platforms, further data may be processed in accordance with the agreement with the respective conference provider.
Logging and recordings: If text entries, participation results (e.g. from polls) and video or audio recordings are logged, participants will be informed of this transparently in advance and, where necessary, asked for their consent.
Data protection measures of the participants: For details on the processing of your data by the conference platforms, please refer to their privacy notices and select the security and privacy settings that are optimal for you within the settings of the conference platforms. Please also ensure data and personality protection in the background of your recording for the duration of a video conference (e.g. by informing housemates, locking doors and, as far as technically possible, using the function to blur the background). Links to the conference rooms and access data must not be passed on to unauthorised third parties.
Notes on legal bases: If, in addition to the conference platforms, we also process users' data and ask users for their consent to the use of the conference platforms or certain functions (e.g. consent to the recording of conferences), this consent is the legal basis for the processing. Furthermore, our processing may be necessary to fulfil our contractual obligations (e.g. in participant lists, in the case of follow-up on discussion outcomes, etc.). Otherwise, users' data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners.
- Types of data processed: Master data (e.g. names, addresses); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
- Data subjects: Communication partners; users (e.g. website visitors, users of online services). Persons depicted.
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations; contact requests and communication. Office and organisational procedures.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Audio content
We use hosting and analysis offerings from service providers in order to offer our audio content for listening or download and to obtain statistical information on the access to the audio content.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); conversion measurement (measuring the effectiveness of marketing measures); profiles with user-related information (creating user profiles). Provision of our online offering and user-friendliness.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Application process
The application process requires applicants to provide us with the data necessary for their assessment and selection. Which information is required is set out in the job description or, in the case of online forms, in the information provided there.
In principle, the required information includes personal details such as name, address, a means of contact and proof of the qualifications necessary for a position. On request, we will also gladly tell you which information is required.
Where available, applicants can submit their applications to us by means of an online form. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications by email. In this case, however, please note that emails are generally not sent encrypted over the internet. As a rule, emails are encrypted in transit, but not on the servers from which they are sent and received. We therefore cannot accept any responsibility for the transmission path of the application between the sender and its receipt on our server.
For the purposes of searching for applicants, submitting applications and selecting applicants, we may, in compliance with the statutory requirements, use applicant management or recruitment software and platforms and services of third-party providers.
Applicants are welcome to contact us about the way in which the application is submitted or to send us their application by post.
Processing of special categories of data: Where special categories of personal data (Art. 9 para. 1 GDPR, e.g. health data, such as severe disability status, or ethnic origin) are requested from applicants as part of the application process, they are processed so that the controller or the data subject can exercise the rights arising from employment law and the law of social security and social protection and fulfil their obligations in this regard, in the case of protecting the vital interests of applicants or other persons, or for the purposes of preventive medicine or occupational medicine, for assessing the employee's working capacity, for medical diagnostics, for the provision or treatment of health or social care, or for the management of health or social care systems and services.
Deletion of data: In the event of a successful application, the data provided by applicants may be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicants' data will be deleted. Applicants' data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to a legitimate withdrawal by the applicants, deletion takes place at the latest after a period of six months has elapsed, so that we can answer any follow-up questions about the application and meet our obligations to provide evidence under the regulations on equal treatment of applicants. Invoices for any travel expense reimbursement are archived in accordance with tax law requirements.
Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, takes place on the basis of consent. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application process and that they can withdraw their consent at any time for the future.
In principle, the required information includes personal details such as name, address, a means of contact and proof of the qualifications necessary for a position. On request, we will also gladly tell you which information is required.
Where available, applicants can submit their applications to us by means of an online form. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications by email. In this case, however, please note that emails are generally not sent encrypted over the internet. As a rule, emails are encrypted in transit, but not on the servers from which they are sent and received. We therefore cannot accept any responsibility for the transmission path of the application between the sender and its receipt on our server.
For the purposes of searching for applicants, submitting applications and selecting applicants, we may, in compliance with the statutory requirements, use applicant management or recruitment software and platforms and services of third-party providers.
Applicants are welcome to contact us about the way in which the application is submitted or to send us their application by post.
Processing of special categories of data: Where special categories of personal data (Art. 9 para. 1 GDPR, e.g. health data, such as severe disability status, or ethnic origin) are requested from applicants as part of the application process, they are processed so that the controller or the data subject can exercise the rights arising from employment law and the law of social security and social protection and fulfil their obligations in this regard, in the case of protecting the vital interests of applicants or other persons, or for the purposes of preventive medicine or occupational medicine, for assessing the employee's working capacity, for medical diagnostics, for the provision or treatment of health or social care, or for the management of health or social care systems and services.
Deletion of data: In the event of a successful application, the data provided by applicants may be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicants' data will be deleted. Applicants' data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Subject to a legitimate withdrawal by the applicants, deletion takes place at the latest after a period of six months has elapsed, so that we can answer any follow-up questions about the application and meet our obligations to provide evidence under the regulations on equal treatment of applicants. Invoices for any travel expense reimbursement are archived in accordance with tax law requirements.
Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, takes place on the basis of consent. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application process and that they can withdraw their consent at any time for the future.
- Types of data processed: Master data (e.g. names, addresses); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); applicant data (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, such as cover letter, curriculum vitae, certificates, as well as further information about their person or qualifications provided in relation to a specific position or voluntarily by applicants).
- Data subjects: Applicants.
- Purposes of processing: Application process (establishment and any subsequent performance as well as possible subsequent termination of the employment relationship).
- Legal bases: Application process as a pre-contractual or contractual relationship (Art. 6 para. 1 sentence 1 lit. b) GDPR); processing of special categories of personal data relating to healthcare, occupation and social security (Art. 9 para. 2 lit. h) GDPR); consent to the processing of special categories of personal data (Art. 9 para. 2 lit. a) GDPR). Processing of special categories of personal data to protect vital interests (Art. 9 para. 2 lit. c) GDPR).
Cloud services
We use software services accessible via the internet and run on the servers of their providers (so-called "cloud services", also referred to as "Software as a Service") for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with specific recipients or publication of content and information).
In this context, personal data may be processed and stored on the providers' servers, insofar as it is part of communication processes with us or is otherwise processed by us as set out in this privacy policy. This data may include in particular users' master data and contact data, data on transactions, contracts, other processes and their content. The providers of the cloud services also process usage data and metadata, which they use for security purposes and for service optimisation.
Where we use the cloud services to provide forms or other documents and content for other users or publicly accessible websites, the providers may store cookies on users' devices for web analytics purposes or to remember user settings (e.g. in the case of media control).
In this context, personal data may be processed and stored on the providers' servers, insofar as it is part of communication processes with us or is otherwise processed by us as set out in this privacy policy. This data may include in particular users' master data and contact data, data on transactions, contracts, other processes and their content. The providers of the cloud services also process usage data and metadata, which they use for security purposes and for service optimisation.
Where we use the cloud services to provide forms or other documents and content for other users or publicly accessible websites, the providers may store cookies on users' devices for web analytics purposes or to remember user settings (e.g. in the case of media control).
- Types of data processed: Master data (e.g. names, addresses); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
- Data subjects: Customers; employees (e.g. staff, applicants, former employees); prospective customers. Communication partners.
- Purposes of processing: Office and organisational procedures. Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Newsletters and electronic notifications
We send newsletters, emails and other electronic notifications (hereinafter "newsletters") only with the consent of the recipients or a statutory permission. If the content of the newsletter is specifically described when signing up, it is decisive for the users' consent. Otherwise, our newsletters contain information about our services and about us.
To subscribe to our newsletters, it is in principle sufficient to provide your email address. However, we may ask you to provide a name, for personal address in the newsletter, or further information, if this is required for the purposes of the newsletter.
Double opt-in procedure: Subscription to our newsletter takes place in principle in a so-called double opt-in procedure. This means that after signing up you receive an email asking you to confirm your subscription. This confirmation is necessary so that nobody can sign up with someone else's email address. Newsletter subscriptions are logged in order to be able to prove the sign-up process in accordance with the legal requirements. This includes storing the time of sign-up and confirmation as well as the IP address. Changes to your data stored with the dispatch service provider are likewise logged.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them, in order to be able to prove consent previously given. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a block list (so-called "blocklist").
The logging of the sign-up procedure takes place on the basis of our legitimate interests for the purpose of proving that it was carried out properly. Where we commission a service provider to send emails, this takes place on the basis of our legitimate interests in an efficient and secure dispatch system.
Content:
Information about our products, content on silver/gold/finance, a report on developments on the financial market and special promotions.
Further notes on processing operations, procedures and services:
To subscribe to our newsletters, it is in principle sufficient to provide your email address. However, we may ask you to provide a name, for personal address in the newsletter, or further information, if this is required for the purposes of the newsletter.
Double opt-in procedure: Subscription to our newsletter takes place in principle in a so-called double opt-in procedure. This means that after signing up you receive an email asking you to confirm your subscription. This confirmation is necessary so that nobody can sign up with someone else's email address. Newsletter subscriptions are logged in order to be able to prove the sign-up process in accordance with the legal requirements. This includes storing the time of sign-up and confirmation as well as the IP address. Changes to your data stored with the dispatch service provider are likewise logged.
Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them, in order to be able to prove consent previously given. The processing of this data is limited to the purpose of a possible defence against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address solely for this purpose in a block list (so-called "blocklist").
The logging of the sign-up procedure takes place on the basis of our legitimate interests for the purpose of proving that it was carried out properly. Where we commission a service provider to send emails, this takes place on the basis of our legitimate interests in an efficient and secure dispatch system.
Content:
Information about our products, content on silver/gold/finance, a report on developments on the financial market and special promotions.
- Types of data processed: Master data (e.g. names, addresses); contact data (e.g. email, telephone numbers); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status); usage data (e.g. websites visited, interest in content, access times).
- Data subjects: Communication partners; users (e.g. website visitors, users of online services).
- Purposes of processing: Direct marketing (e.g. by email or post). Provision of contractual services and fulfilment of contractual obligations.
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
- Option to object (opt-out): You can cancel the receipt of our newsletter at any time, i.e. withdraw your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options stated above, preferably email.
Further notes on processing operations, procedures and services:
- Measurement of open and click rates: The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a dispatch service provider, from its server. In the course of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of retrieval, is first collected.
This information is used for the technical improvement of our newsletter on the basis of the technical data or the target groups and their reading behaviour, based on their retrieval locations (which can be determined with the help of the IP address) or access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until their deletion. The evaluations serve us to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The measurement of open rates and click rates and the storage of the measurement results in the users' profiles, as well as their further processing, take place on the basis of the users' consent.
Unfortunately, a separate withdrawal of the success measurement is not possible; in this case the entire newsletter subscription must be cancelled or objected to. In this case, the stored profile information will be deleted;
legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). - Prerequisite for using free services: Consent to the sending of mailings may be made a prerequisite for using free services (e.g. access to certain content or participation in certain promotions). If users wish to use the free service without subscribing to the newsletter, please contact us.
Promotional communication via email, post, fax or telephone
We process personal data for the purposes of promotional communication, which may take place via various channels, such as email, telephone, post or fax, in accordance with the statutory requirements.
Recipients have the right to withdraw any consent given at any time or to object to promotional communication at any time.
After withdrawal or objection, we store the data required to prove the previous authorisation to contact or send for up to three years after the end of the year of withdrawal or objection, on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defence against claims. On the basis of the legitimate interest in permanently observing users' withdrawal or objection, we also store the data required to avoid renewed contact (e.g., depending on the communication channel, the email address, telephone number, name).
Recipients have the right to withdraw any consent given at any time or to object to promotional communication at any time.
After withdrawal or objection, we store the data required to prove the previous authorisation to contact or send for up to three years after the end of the year of withdrawal or objection, on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defence against claims. On the basis of the legitimate interest in permanently observing users' withdrawal or objection, we also store the data required to avoid renewed contact (e.g., depending on the communication channel, the email address, telephone number, name).
- Types of data processed: Master data (e.g. names, addresses); contact data (e.g. email, telephone numbers).
- Data subjects: Communication partners.
- Purposes of processing: Direct marketing (e.g. by email or post).
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Prize draws and competitions
We process the personal data of participants in prize draws and competitions only in compliance with the relevant data protection provisions, insofar as the processing is contractually necessary for the provision, conduct and handling of the prize draw, the participants have consented to the processing, or the processing serves our legitimate interests (e.g. in the security of the prize draw or the protection of our interests against misuse through the possible recording of IP addresses when submitting entries).
If participants' entries are published in the course of the prize draws (e.g. as part of a vote or presentation of the entries or the winners or reporting on the prize draw), we point out that the participants' names may also be published in this context. Participants can object to this at any time.
If the prize draw takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as "online platform"), the terms of use and privacy provisions of the respective platforms also apply. In these cases, we point out that we are responsible for the information provided by participants in the course of the prize draw and that enquiries regarding the prize draw are to be addressed to us.
Participants' data is deleted as soon as the prize draw or competition has ended and the data is no longer required to inform the winners or because queries about the prize draw are no longer to be expected. In principle, participants' data is deleted no later than 6 months after the end of the prize draw. Winners' data may be retained for longer, e.g. in order to be able to answer queries about the prizes or to fulfil the prizes; in this case, the retention period depends on the nature of the prize and is, for example, up to three years for goods or services, in order to be able to process warranty cases, for example. In addition, participants' data may be stored for longer, e.g. in the form of reporting on the prize draw in online and offline media.
Where data was also collected in the course of the prize draw for other purposes, its processing and retention period are governed by the privacy notices on that use (e.g. in the case of a newsletter subscription in the course of a prize draw).
If participants' entries are published in the course of the prize draws (e.g. as part of a vote or presentation of the entries or the winners or reporting on the prize draw), we point out that the participants' names may also be published in this context. Participants can object to this at any time.
If the prize draw takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as "online platform"), the terms of use and privacy provisions of the respective platforms also apply. In these cases, we point out that we are responsible for the information provided by participants in the course of the prize draw and that enquiries regarding the prize draw are to be addressed to us.
Participants' data is deleted as soon as the prize draw or competition has ended and the data is no longer required to inform the winners or because queries about the prize draw are no longer to be expected. In principle, participants' data is deleted no later than 6 months after the end of the prize draw. Winners' data may be retained for longer, e.g. in order to be able to answer queries about the prizes or to fulfil the prizes; in this case, the retention period depends on the nature of the prize and is, for example, up to three years for goods or services, in order to be able to process warranty cases, for example. In addition, participants' data may be stored for longer, e.g. in the form of reporting on the prize draw in online and offline media.
Where data was also collected in the course of the prize draw for other purposes, its processing and retention period are governed by the privacy notices on that use (e.g. in the case of a newsletter subscription in the course of a prize draw).
- Types of data processed: Master data (e.g. names, addresses); content data (e.g. entries in online forms); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
- Data subjects: Participants in prize draws and competitions.
- Purposes of processing: Conducting prize draws and competitions.
- Legal bases: Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
Web analytics, monitoring and optimisation
Web analytics (also referred to as "reach measurement") serves to evaluate the flows of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis we can, for example, recognise at what time our online offering, its functions or content are used most frequently or invite repeat use. We can also understand which areas require optimisation.
In addition to web analytics, we may also use testing procedures, e.g. to test and optimise different versions of our online offering or its components.
Unless stated otherwise below, profiles, i.e. data summarised into a usage process, may be created for these purposes and information may be stored in a browser or end device and read from it. The information collected includes in particular websites visited and elements used there, as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data by us or by the providers of the services we use, location data may also be processed.
Users' IP addresses are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored in the context of web analytics, A/B testing and optimisation, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.
In addition to web analytics, we may also use testing procedures, e.g. to test and optimise different versions of our online offering or its components.
Unless stated otherwise below, profiles, i.e. data summarised into a usage process, may be created for these purposes and information may be stored in a browser or end device and read from it. The information collected includes in particular websites visited and elements used there, as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data by us or by the providers of the services we use, location data may also be processed.
Users' IP addresses are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored in the context of web analytics, A/B testing and optimisation, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors). Profiles with user-related information (creating user profiles).
- Security measures: IP masking (pseudonymisation of the IP address).
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Online marketing
We process personal data for online marketing purposes, which may include in particular the marketing of advertising space or the display of promotional and other content (collectively referred to as "content") based on users' potential interests, as well as measuring its effectiveness.
For these purposes, so-called user profiles are created and stored in a file (a so-called "cookie") or similar procedures are used, by means of which the information about the user that is relevant for the display of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times and functions used. If users have consented to the collection of their location data, this may also be processed.
Users' IP addresses are also stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored in the context of online marketing procedures, but pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is as a rule stored in cookies or by means of similar procedures. These cookies can generally later also be read on other websites that use the same online marketing procedure, analysed for the purpose of displaying content, supplemented with further data and stored on the server of the online marketing procedure provider.
As an exception, clear data may be assigned to the profiles. This is the case if users are, for example, members of a social network whose online marketing procedure we use and the network links the users' profiles with the aforementioned information. Please note that users may enter into additional agreements with the providers, e.g. by consenting during registration.
In principle, we only have access to summarised information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e. for example to a contract being concluded with us. Conversion measurement is used solely to analyse the success of our marketing measures.
Unless stated otherwise, please assume that cookies used are stored for a period of two years.
Further notes on processing operations, procedures and services:
For these purposes, so-called user profiles are created and stored in a file (a so-called "cookie") or similar procedures are used, by means of which the information about the user that is relevant for the display of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times and functions used. If users have consented to the collection of their location data, this may also be processed.
Users' IP addresses are also stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear data of users (such as email addresses or names) is stored in the context of online marketing procedures, but pseudonyms. This means that neither we nor the providers of the online marketing procedures know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is as a rule stored in cookies or by means of similar procedures. These cookies can generally later also be read on other websites that use the same online marketing procedure, analysed for the purpose of displaying content, supplemented with further data and stored on the server of the online marketing procedure provider.
As an exception, clear data may be assigned to the profiles. This is the case if users are, for example, members of a social network whose online marketing procedure we use and the network links the users' profiles with the aforementioned information. Please note that users may enter into additional agreements with the providers, e.g. by consenting during registration.
In principle, we only have access to summarised information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e. for example to a contract being concluded with us. Conversion measurement is used solely to analyse the success of our marketing measures.
Unless stated otherwise, please assume that cookies used are stored for a period of two years.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); tracking (e.g. interest/behaviour-based profiling, use of cookies); marketing. Profiles with user-related information (creating user profiles).
- Security measures: IP masking (pseudonymisation of the IP address).
- Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
- Option to object (opt-out): We refer to the privacy notices of the respective providers and the objection options stated for the providers (so-called "opt-out"). If no explicit opt-out option has been specified, you can, firstly, switch off cookies in your browser settings. However, this may restrict functions of our online offering. We therefore additionally recommend the following opt-out options, which are offered collectively for the respective regions:
a) Europe: https://www.youronlinechoices.eu.
b) Canada: https://www.youradchoices.ca/choices.
c) USA: https://www.aboutads.info/choices.
d) Cross-regional: https://optout.aboutads.info.
Further notes on processing operations, procedures and services:
- FunnelCockpit: Creation and management of websites as well as website elements and marketing functions (in particular reach measurement, A/B testing, interest-based marketing, processing of user profiles, online forms, sending of messages and direct communication); Service provider: Denis Hoeger Caballero, Inhaber: Denis Hoeger - Caballero, Nobelstr- 3-5, 41189 Mönchengladbach, Germany; legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); Website: https://funnelcockpit.com/. Privacy policy: https://funnelcockpit.com/datenschutz/.
- Matomo: Matomo is software used for web analytics and reach measurement. When Matomo is used, cookies are generated and stored on the users' end devices. The users' data collected through the use of Matomo is processed only by us and is not shared with third parties. The cookies are stored for a maximum period of 13 months: https://matomo.org/faq/general/faq_146/; legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). Deletion of data: The cookies have a maximum storage period of 13 months.
Customer reviews and rating procedures
We participate in review and rating procedures in order to evaluate, optimise and promote our services. If users rate us via the participating rating platforms or procedures or otherwise give feedback, the general terms and conditions or terms of use and the privacy notices of the providers also apply. As a rule, the rating also requires registration with the respective providers.
To ensure that the persons giving ratings have actually used our services, we transmit, with the customers' consent, the data required for this purpose with regard to the customer and the service used to the respective rating platform (including name, email address and order number or item number). This data is used solely to verify the authenticity of the user.
Further notes on processing operations, procedures and services:
To ensure that the persons giving ratings have actually used our services, we transmit, with the customers' consent, the data required for this purpose with regard to the customer and the service used to the respective rating platform (including name, email address and order number or item number). This data is used solely to verify the authenticity of the user.
- Types of data processed: Contract data (e.g. subject matter of the contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
- Data subjects: Customers; users (e.g. website visitors, users of online services).
- Purposes of processing: Feedback (e.g. collecting feedback via online form). Marketing.
- Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further notes on processing operations, procedures and services:
- Google Customer Reviews: Service for collecting and/or displaying customer satisfaction and customer opinions; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.google.com/; Privacy policy: https://policies.google.com/privacy; Basis for third-country transfer: EU-US Data Privacy Framework (DPF); Further information: In the course of collecting customer reviews, an identification number and the time of the business transaction to be rated are processed; in the case of review requests sent directly to customers, the customer's email address and their country of residence, as well as the review details themselves, are processed; further information on the types of processing and the data processed: https://business.safety.google/adsservices/. Data processing terms for Google advertising products: Information on the services, data processing terms between controllers and standard contractual clauses for third-country data transfers: https://business.safety.google/adscontrollerterms.
Plugins and embedded functions and content
We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may be, for example, graphics, videos or city maps (hereinafter uniformly referred to as "content").
The integration always requires that the third-party providers of this content process the users' IP address, since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content or these functions. We endeavour to use only content whose respective providers use the IP address solely to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the users' device and may contain, among other things, technical information on the browser and operating system, referring websites, time of visit and further information on the use of our online offering, and may be combined with such information from other sources.
The integration always requires that the third-party providers of this content process the users' IP address, since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content or these functions. We endeavour to use only content whose respective providers use the IP address solely to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also referred to as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the users' device and may contain, among other things, technical information on the browser and operating system, referring websites, time of visit and further information on the use of our online offering, and may be combined with such information from other sources.
- Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
- Data subjects: Users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of our online offering and user-friendliness.
Management, organisation and auxiliary tools
We use services, platforms and software of other providers (hereinafter referred to as "third-party providers") for the purposes of organisation, management, planning and the provision of our services. When selecting third-party providers and their services, we comply with the statutory requirements.
In this context, personal data may be processed and stored on the servers of the third-party providers. Various data that we process in accordance with this privacy policy may be affected. This data may include in particular users' master data and contact data, data on transactions, contracts, other processes and their content.
If users are referred to the third-party providers or their software or platforms in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, for service optimisation or for marketing purposes. We therefore ask you to note the privacy notices of the respective third-party providers.
Further notes on processing operations, procedures and services:
In this context, personal data may be processed and stored on the servers of the third-party providers. Various data that we process in accordance with this privacy policy may be affected. This data may include in particular users' master data and contact data, data on transactions, contracts, other processes and their content.
If users are referred to the third-party providers or their software or platforms in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security purposes, for service optimisation or for marketing purposes. We therefore ask you to note the privacy notices of the respective third-party providers.
- Types of data processed: Content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time stamps, identification numbers, consent status).
- Data subjects: Communication partners; users (e.g. website visitors, users of online services).
- Purposes of processing: Provision of contractual services and fulfilment of contractual obligations. Office and organisational procedures.
Further notes on processing operations, procedures and services:
- KYC Services: We would like to inform you that, with the help of the tools KYC Spider and PXL Vision, we carry out a check under the Anti-Money Laundering Act (AMLA).
The AMLA check takes place for every customer who is set up via our online onboarding service. Your data is transmitted to our partners KYC Spider and PXL Vision only after (with) your consent (confirmation) in our online onboarding system (application process).
Information about your data can be requested in writing at service@bb-wertmetall.ch.
Changes and updates to this privacy policy
We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
Where we state addresses and contact information of companies and organisations in this privacy policy, please note that addresses may change over time and please check the information before making contact.
Where we state addresses and contact information of companies and organisations in this privacy policy, please note that addresses may change over time and please check the information before making contact.