[Data protection TRAFFIC]

A.      Privacy Policy according to the GDPR

I.          Name and Address of the Controller

The Controller within the meaning of the General Data Protection Regulation and other national data protection laws of the Member States as well as other legal data protection provisions is:

ICA Traffic GmbH
Walter-Welp-Straße 27
44149 Dortmund
Germany
Tel.: +49 (231) 917044 – 0

E-mail: DAS@ica.local
Website: www.ica.de

II.       Name and Address of the Data Protection Officer

The Data Protection Officer of the Controller is:

Dirk Tscholitsch
TAROX Aktiengesellschaft
Stellenbachstr. 49−51
44536 Lünen
Germany
Tel.: +49 (231) 98980 – 320

E-mail: Dirk.Tscholitsch@tarox.de
Website: www.tarox.de

III.     General Information on Data Processing

1.        Scope of Personal Data Processing

We collect and use the personal data of our users only where this is required to provide a functional website and our content and services. The personal data of our users are as a rule only processed with the prior consent of the user. An exception applies in cases where prior consent cannot be obtained for practical reasons and statutory regulations permit processing of the data.

2.        Legal Basis for Personal Data Processing

Where we obtain consent from the data subject for personal data processing operations, point (a) of Article 6(1) EU General Data Protection Regulation (GDPR) is the legal basis for personal data processing.

If processing personal data is necessary for the performance of a contract to which the data subject is party, the legal basis is point (b) of Article 6(1) GDPR. This also applies to processing operations that are necessary in order to take steps prior to entering into a contract.

Where personal data processing is necessary for compliance with a legal obligation to which our company is subject, the legal basis is point (c) of Article 6(1) GDPR.

If processing is necessary to protect the vital interests of the data subject or another natural person, the legal basis is point (d) of Article 6(1) GDPR.

If processing is necessary for the purposes of any legitimate interest pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, the legal basis for processing is point (f) of Article 6(1) GDPR.

3.        Erasure of Data and Retention Period

The data subject’s personal data shall be erased or blocked once the purpose of storage ceases to apply. Data can be retained beyond this period if this is provided for by European or national legislators in EU regulations, laws or other regulations to which the Controller is subject. The data shall in such cases be blocked or erased once the retention period specified by the aforementioned standards expires, unless further retention of the data is required for the conclusion or fulfilment of a contract.

IV.     Provision of the Website and Creation of Log Files

1.        Description and Scope of Data Processing

Each time our website is accessed, our system automatically collects data and information from the computer system of the accessing computer.

The following data are collected:

  1. Information on the browser type and version used
  2. The operating system of the user
  3. The Internet service provider of the user
  4. The IP address of the user
  5. Date and time of access
  6. Websites from which the user’s system accesses our website
  7. Websites accessed by the user’s system through our website

The data are also stored in the log files of our system. These data are not stored together with other personal data of the user.

2.        Legal Basis for Data Processing

The legal basis for temporary data storage and log files is point (f) of Article 6(1) GDPR.

3.        Purpose of Data Processing

Temporary system storage of the IP address is necessary to allow the website to be provided on the computer of the user. To this end, the IP address of the user must be stored for the duration of the session.

Storage in log files occurs to ensure the functionality of the website. In addition, the data serve to optimise the website, and ensure the security of our IT systems. The data will not be evaluated for marketing purposes in this context.

Such purposes also constitute our legitimate interest in data processing according to point (f) of Article 6(1) GDPR.

4.        Duration of Storage

The data will be erased as soon as it is no longer required to achieve the purpose of its collection. In the case of collection of data for the provision of the website, this is the case when the relevant session ends.

In the case of storage in log files, this is the case after seven days at the latest. Retention beyond this time is possible. In this case, the IP addresses of the users are erased or modified so that they can no longer be associated with the accessing client.

5.        Option of Objection and Elimination

The collection of data is necessary for the provision of the website, and storage of the data in log files is necessary for the operation of the website. Consequently, the user has no option to object.

V.       Use of cookies

Our website uses technically necessary cookies.

VI.          Contact Form and E-mail Contact

1.             Description and Scope of Data Processing

There is a contact form on our website which can be used to contact us electronically. If a user uses this option, then the data entered into the input screen will be transferred to us and stored. These data are:

(1)       The recipient (department) of the contact query (service, sales, accounting, management or IT)

(2)       Subject

(3)       Enterprise name

(4)       Name

(5)       Telephone number

(6)       E-mail address

(7)       The method via which you would like to be contacted (telephone or e-mail)

At the time of sending the message, the following data will be stored:

(1 ) The IP address of the sender

(2 ) Date and time of the contact

Alternatively, we can be contacted using the e-mail address provided. In this case, the personal data of the user transferred with the e-mail will be stored.

In this context, data will not be passed on to third parties. The data will exclusively be used for processing the conversation.

2.        Legal Basis for Data Processing

The legal basis for data processing where the user has given their consent thereto is point (a) of Article 6(1) GDPR.

The legal basis for the processing of data in the course of sending an e-mail is point (f) of Article 6(1) GDPR. If the e-mail contact is aimed at concluding a contract, an additional legal basis for processing is point (b) of Article 6(1) GDPR.

3.        Purpose of Data Processing

Processing personal data from the input screen serves solely to handle the contact. In the case of contact by e-mail, the necessary legitimate interest is in processing the data.

The other personal data processed during the sending process serves to prevent abuse of the contact form and ensure the security of our IT systems.

4.        Duration of Storage

The data will be erased as soon as it is no longer required to achieve the purpose of its collection. For personal data from the input screen of the contact form and that sent by e-mail, this is the case when the relevant conversation with the user ends. The conversation ends when it can be seen from the circumstances that the relevant case has been conclusively clarified.

The additional personal data collected during the sending process will be erased after a period of seven days at the latest.

5.        Option of Objection and Elimination

The user can withdraw their consent to personal data processing at any time. If the user contacts us by e-mail, then they can object to the storage of their personal data at any time. In such a case, the conversation cannot be continued.

To withdraw consent and object to the storage of your personal data, please send an e-mail with the subject “objection” to info@ica.de.

All personal data stored in the course of contact will be erased in this case.

VII. Use of Google Analytics

We use Google Analytics to analyse website usage. The data obtained from this is used to optimise our website and advertising measures.

Google Analytics is provided to us by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). Google processes website usage data on our behalf and is contractually committed to measures to ensure the security and confidentiality of the data processed.

During your website visit, the following data is recorded, among others:

– Pages viewed

– Orders including sales and products ordered

– The achievement of “website goals” (e.g. contact requests and newsletter sign-ups)

– Your behaviour on the pages (e.g. dwell time, clicks, scrolling behaviour)

– Your approximate location (country and city)

– Your IP address (in shortened form, so that no clear allocation is possible)

– Technical information such as browser, internet provider, terminal device and screen resolution

– Source of origin of your visit (i.e. via which website or advertising material you came to us)

No personal data such as name, address or contact details are ever transferred to Google Analytics.

This data is transferred to Google servers in the USA. We would like to point out that the same level of protection under data protection law cannot be guaranteed in the USA as within the EU.

Google Analytics stores cookies in your web browser for a period of two years since your last visit. These cookies contain a randomly generated user ID with which you can be recognised on future website visits.

The recorded data is stored together with the randomly generated user ID, which enables the evaluation of pseudonymous user profiles. This user-related data is automatically deleted after 14 months. Other data remains stored in aggregated form indefinitely.

If you do not agree with the collection, you can prevent it by installing the browser add-on Browser-Add-ons zur Deaktivierung von Google Analytics to deactivate Google Analytics once or by rejecting the cookies via our cookie settings dialogue.

VIII.  Rights of Data Subjects

If your personal data are processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the Controller:

1.        Right of Access

You can request a confirmation from the Controller of whether we process personal data relating to you.

If such processing takes place, you can request the following information from the Controller:

(1)       the purposes for which personal data are processed;

(2)       the categories of personal data processed;

(3)       the recipients or categories of recipients to which the personal data relating to you have been or are to be disclosed;

(4)       the envisaged period for which personal data relating to you will be stored, or, if specific information on this is not possible, the criteria used to determine that period;

(5)       the existence of the right to request from the Controller rectification or erasure of personal data or restriction of processing of personal data concerning you or to object to such processing;

(6)       the right to lodge a complaint with a supervisory authority;

(7)       any available information as to the source of the data where the personal data are not collected from the data subject;

(8)       the existence of automated decision-making including profiling according to Article 22(1) and (4) GDPR and – at least in those cases – meaningful information about the logic involved as well as the significance and the envisaged consequences of such processing for the data subject.

You have a right to information as to whether the personal data relating to you are transmitted to a third country or to an international organisation. If this is the case, you have the right to be informed of the appropriate safeguards according to Article 46 relating to the transfer.

2.        Right to Rectification

You have a right to rectification and/or completion vis-à-vis the Controller if the personal data processed relating to you is inaccurate or incomplete. The Controller must undertake rectification without undue delay.

3.        Right to Restriction of Processing

Under the following circumstances, you can request us to restrict processing of the personal data relating to you:

(1)       if you contest the accuracy of the personal data relating to you for a period that enables the Controller to verify accuracy of the personal data;

(2)       if processing is unlawful, but you refuse erasure of the personal data, requesting instead that use of the personal data be restricted;

(3)       if the Controller no longer needs the personal data for the purposes of processing, but you need them to assert, exercise or defend legal claims, or

(4)       if you have objected to processing according to Article 21(1) GDPR, pending the verification whether the legitimate grounds of the Controller override your legitimate grounds

Where processing of the personal data relating to you has been restricted, such data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

Where processing has been restricted pursuant to the aforementioned conditions, you shall be notified by the Controller before the restriction is lifted.

4.        Right to Erasure

a)        Obligation to erase

You have the right to obtain from the Controller the erasure of your personal data without undue delay and the Controller is obliged to erase such data without undue delay where one of the following grounds applies:

(1)       Your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.

(2)       You withdraw your consent on which processing is based according to point (a) of Article 6(1) or point (a) of Article 9(2) GDPR, and there is no other legal ground for processing.

(3)       You object to processing according to Article 21(1) and there are no overriding legitimate grounds for processing, or you object to processing according to Article 21(2) GDPR.

(4)       Your personal data have been unlawfully processed.

(5)       Your personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the Controller is subject.

(6)       Your personal data have been collected in relation to the offer of information society services according to Article 8(1) GDPR.

b)        Information to third parties

Where the Controller has made your personal data public and is obliged according to Article 17(1) GDPR to erase them, the Controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform Controllers which are processing the personal data that you as the data subject have requested the erasure by such Controllers of any links to, or copy or replication of, those personal data.

c)        Exceptions

The right to erasure does not apply to the extent that processing is necessary

(1)       for exercising the right of freedom of expression and information;

(2)       for compliance with a legal obligation which requires processing by Union or Member State law to which the Controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;

(3)       for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3) GDPR;

(4)       for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) GDPR insofar as the right referred to in a) is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

(5)       for the establishment, exercise or defence of legal claims.

5.        Right of Information

If you have asserted the right to rectification, erasure or restriction of processing vis-à-vis the Controller, the Controller is obliged to communicate such rectification or erasure of the data or restriction of processing to each recipient to whom your personal data have been disclosed, unless this proves impossible or involves disproportionate effort.

You have the right to request information on those recipients from the Controller.

6.        Right to Data Portability

You have the right to receive any personal data related to you that has been provided by you to the Controller in a structured, commonly used and machine-readable format. You also have the right to transmit those data to another Controller without hindrance from the Controller to which the personal data have been provided, where

(1)       the processing is based on consent according to point (a) of Article 6(1) GDPR or point (a) of Article 9(2) GDPR or on a contract according to point (b) of Article 6(1) GDPR and

(2)       processing is carried out by automated means.

In exercising this right, you also have the right to have the personal data concerning you transmitted directly from one Controller to another, where technically feasible. This must not adversely affect the rights and freedoms of others.

The right to data portability does not apply to any personal data processing that is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller.

7.        Right to Object

You have the right to object, on grounds relating to your particular situation, at any time to any processing of your personal data which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions.

The Controller shall no longer process your personal data, unless the Controller demonstrates compelling legitimate grounds for processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Where your personal data are processed for direct marketing purposes, you have the right to object at any time to any processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Where you object to processing for direct marketing purposes, your personal data will no longer be processed for such purposes.

In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, you may exercise your right to object by automated means using technical specifications.

8.        Right to Withdraw Consent

You have the right to withdraw your data consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

9.        Automated Individual Decision-Making Including Profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

(1)       is necessary for entering into, or performance of, a contract between you and the Controller;

(2)       is authorised by Union or Member State law to which the Controller is subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or

(3)       is made with your explicit consent.

Nevertheless, such decisions must not be based on special categories of personal data according to Article 9(1) GDPR, unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard your rights and freedoms and legitimate interests are in place.

In the cases referred to in (1) and (3), the Controller implements suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the Controller, to express his or her point of view and to contest the decision.

10.    Right to Lodge a Complaint with a Supervisory Authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of your personal data infringes the GDPR.

The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy according to Article 78 GDPR.

IX. Google Maps

This site uses the mapping service Google Maps via an API. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

To use the functions of Google Maps, it is necessary to store your IP address. This information is usually transferred to a Google server in the USA and stored there. The provider of this site has no influence on this data transmission.

Google Maps is used in the interest of an appealing presentation of our online offers and to make it easy to find the places we indicate on the website. This constitutes a legitimate interest within the meaning of Art. 6 Para. 1 lit. f DSGVO.

More information on the handling of user data can be found in Google’s privacy policy: https://www.google.de/intl/de/policies/privacy/ .

For users of Google services in the European Economic Area (EEA) and Switzerland, Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, Ireland has been legally responsible since 22.01.2019.

X. Google Tag Manager order processing agreement (AVV)

We have concluded an order processing agreement (OPA) with Google in accordance with Article 28 of the General Data Protection Regulation (GDPR). You can read more about what exactly a GCU is and, in particular, what must be included in a GCU in our general section “Order processing agreement (GCU)”.

This contract is required by law because Google processes personal data on our behalf. It clarifies that Google may only process data they receive from us according to our instructions and must comply with the GDPR. You can find the link to the order processing agreement (AVV) at https://business.safety.google/adsprocessorterms/ .

XI. reCAPTCHA

Our primary goal is to secure and protect our website for you and for us in the best possible way. To ensure this, we use Google reCAPTCHA from the company Google Inc. For the European region, the company Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland) is responsible for all Google services. With reCAPTCHA we can determine whether you are really a flesh and blood human being and not a robot or other spam software. By spam we mean any unsolicited information sent to us electronically. With the classic CAPTCHAS, you usually had to solve text or picture puzzles to verify the information. With reCAPTCHA from Google, we usually don’t have to bother you with such puzzles. Here, in most cases, it is enough to simply tick a box and thus confirm that you are not a bot. With the new Invisible reCAPTCHA version, you don’t even have to set a tick anymore. You will find out exactly how this works and, above all, what data is used for this purpose in the course of this privacy policy. reCAPTCHA is a free captcha service from Google that protects websites from spam software and abuse by non-human visitors. The most common use of this service is when you fill out forms on the internet. A captcha service is a type of automatic Turing test that is designed to ensure that an action on the internet is performed by a human and not a bot. In the classic Turing test (named after the computer scientist Alan Turing), a human determines the distinction between a bot and a human. With captchas, this is also done by the computer or a software programme. Classic captchas work with small tasks that are easy for humans to solve, but present considerable difficulties for machines. With reCAPTCHA, you no longer have to actively solve puzzles. The tool uses modern risk techniques to distinguish humans from bots. Here you only have to tick the text field “I am not a robot” or with Invisible reCAPTCHA even that is no longer necessary. With reCAPTCHA, a JavaScript element is integrated into the source code and then the tool runs in the background and analyses your user behaviour. From these user actions, the software calculates a so-called captcha score. Google uses this score to calculate how likely you are to be a human even before you enter the captcha. reCAPTCHA, or captchas in general, are always used when bots could manipulate or abuse certain actions (such as registrations, surveys, etc.).

Why do we use reCAPTCHA on our website?

We only want to welcome flesh and blood people to our site. Bots or spam software of any kind can safely stay at home. That’s why we pull out all the stops to protect ourselves and offer the best possible user experience for you. For this reason, we use Google reCAPTCHA from Google. This way we can be pretty sure that we remain a “bot-free” website. By using reCAPTCHA, data is transmitted to Google to determine whether you are actually a human being. reCAPTCHA therefore serves the security of our website and, by extension, your security. For example, without reCAPTCHA, it could happen that a bot registers as many email addresses as possible during registration in order to “spam” forums or blogs with unwanted advertising content. With reCAPTCHA, we can avoid such bot attacks.

What data is stored by reCAPTCHA?

reCAPTCHA collects personal data from users in order to determine whether the actions on our website actually originate from people. This means that the IP address and other data required by Google for the reCAPTCHA service may be sent to Google. IP addresses are almost always shortened beforehand within the member states of the EU or other contracting states to the Agreement on the European Economic Area before the data ends up on a server in the USA. The IP address is not combined with other data from Google unless you are logged in with your Google account while using reCAPTCHA. First, the reCAPTCHA algorithm checks whether Google cookies from other Google services (YouTube. Gmail, etc.) are already placed on your browser. Then, reCAPTCHA sets an additional cookie in your browser and captures a snapshot of your browser window.

The following list of collected browser and user data does not claim to be complete. Rather, they are examples of data that, to our knowledge, are processed by Google.

– Referrer URL (the address of the page from which the visitor came)

– IP address (e.g. 256.123.123.1)

– Information about the operating system (the software that enables your computer to operate. Known operating systems are Windows, Mac OS X or Linux)

– Cookies (small text files that store data in your browser)

– Mouse and keyboard behaviour (every action you perform with the mouse or keyboard is stored)

– Date and language settings (which language or date you have preset on your PC is saved)

– All JavaScript objects (JavaScript is a programming language that allows websites to adapt to the user. JavaScript objects can collect all kinds of data under one name)

– Screen resolution (shows how many pixels the image display consists of)

It is undisputed that Google uses and analyses this data even before you click on the “I am not a robot” checkbox. With the Invisible reCAPTCHA version, even the ticking is omitted and the entire recognition process runs in the background. Google does not tell you in detail how much and which data it stores.

The following cookies are used by reCAPTCHA: Here we refer to the reCAPTCHA demo version from Google at https://www.google.com/recaptcha/api2/demo. All these cookies require a unique identifier for tracking purposes. Here is a list of cookies that Google reCAPTCHA has set on the demo version:

Name: IDE

Value: WqTUmlnmv_qXyi_DGNPLESKnRNrpgXoy1K-pAZtAkMbHI-312574961-8

Purpose: This cookie is set by DoubleClick (also owned by Google) to record and report a user’s actions on the website in dealing with advertisements. This allows advertising effectiveness to be measured and appropriate optimisation measures to be taken. IDE is stored in browsers under the domain doubleclick.net.

Expiry date: after one year

Name: 1P_JAR

Value: 2019-5-14-12

Purpose: This cookie collects statistics on website usage and measures conversions. A conversion occurs, for example, when a user becomes a buyer. The cookie is also used to display relevant advertisements to users. Furthermore, the cookie can be used to prevent a user from seeing the same ad more than once.

Expiry date: after one month

Name: ANID

Wert: U7j1v3dZa3125749610xgZFmiqWppRWKOr

Purpose: We could not find out much information about this cookie. In Google’s privacy policy, the cookie is mentioned in connection with “advertising cookies” such as “DSID”, “FLC”, “AID”, “TAID”. ANID is stored under domain google.com.

Expiry date: after 9 months

Name: CONSENT

Value: YES+AT.en+20150628-20-0

Purpose: The cookie stores the status of a user’s consent to use various Google services. CONSENT is also used for security purposes to verify users, prevent login fraud and protect user data from unauthorised attacks.

Expiry date: after 19 years

Name: NID

Wert: 0WmuWqy312574961zILzqV_nmt3sDXwPeM5Q

Purpose: NID is used by Google to customise advertisements to your Google search. With the help of the cookie, Google “remembers” your most frequently entered search queries or your previous interaction with ads. This way you always get tailored ads. The cookie contains a unique ID to collect the user’s personal preferences for advertising purposes.

Expiry date: after 6 months

Name: DV

Wert: gEAABBCjJMXcI0dSAAAANbqc312574961-4

Purpose: Once you have ticked the “I am not a robot” box, this cookie will be set. The cookie is used by Google Analytics for personalised advertising. DV collects information in an anonymous form and is also used to make user distinctions.

Expiry date: after 10 minutes

Note: This list cannot claim to be exhaustive, as Google’s experience shows that it changes its choice of cookies time and again.

How long and where is the data stored?

By inserting reCAPTCHA, data is transferred from you to the Google server. Where exactly this data is stored is not made clear by Google, even after repeated enquiries. Without having received confirmation from Google, it can be assumed that data such as mouse interaction, time spent on the website or language settings are stored on Google’s European or American servers. The IP address that your browser transmits to Google is generally not merged with other Google data from other Google services. However, if you are logged into your Google account while using the reCAPTCHA plug-in, the data will be merged. The deviating data protection regulations of the Google company apply to this.

How can I delete my data or prevent data storage?

If you do not want any data about you and your behaviour to be transmitted to Google, you must log out of Google completely and delete all Google cookies before you visit our website or use the reCAPTCHA software. In principle, data is automatically transmitted to Google as soon as you visit our site. To delete this data again, you must contact Google support at https://support.google.com/?hl=de&tid=312574961.

Therefore, by using our website, you consent to the automatic collection, processing and use of data by Google LLC and its agents.

Please note that when you use this tool, data about you may be stored and processed outside the EU. Most third countries (including the USA) are not considered secure under current European data protection law. Data to insecure third countries may therefore not simply be transferred, stored and processed there unless there are suitable safeguards (such as EU standard contractual clauses) between us and the non-European service provider.

Legal basis

If you have consented to Google reCAPTCHA being used, the legal basis for the corresponding data processing is this consent. According to Art. 6 para. 1 lit. a DSGVO (consent), this consent constitutes the legal basis for the processing of personal data as it may occur in the collection by Google reCAPTCHA.

On our part, there is also a legitimate interest in using Google reCAPTCHA to optimise our online service and make it more secure. The corresponding legal basis for this is Art. 6 para. 1 lit. f DSGVO (Legitimate Interests). Nevertheless, we only use Google reCAPTCHA if you have given your consent.

Google also processes your data in the USA, among other places. We would like to point out that according to the opinion of the European Court of Justice, there is currently no adequate level of protection for the transfer of data to the USA. This may be associated with various risks for the legality and security of the data processing.

Als Grundlage der Datenverarbeitung bei Empfängern mit Sitz in Drittstaaten (außerhalb der Europäischen Union, Island, Liechtenstein, Norwegen, also insbesondere in den USA) oder einer Datenweitergabe dorthin verwendet Google sogenannte Standardvertragsklauseln (= Art. 46. Abs. 2 und 3 DSGVO). Standardvertragsklauseln (Standard Contractual Clauses – SCC) sind von der EU-Kommission bereitgestellte Mustervorlagen und sollen sicherstellen, dass Ihre Daten auch dann den europäischen Datenschutzstandards entsprechen, wenn diese in Drittländer (wie beispielsweise in die USA) überliefert und dort gespeichert werden. Durch diese Klauseln verpflichtet sich Google, bei der Verarbeitung Ihrer relevanten Daten, das europäische Datenschutzniveau einzuhalten, selbst wenn die Daten in den USA gespeichert, verarbeitet und verwaltet werden. Diese Klauseln basieren auf einem Durchführungsbeschluss der EU-Kommission. Sie finden den Beschluss und die entsprechenden Standardvertragsklauseln u.a. hier: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de

Die Google Ads Datenverarbeitungsbedingungen (Google Ads Data Processing Terms), welche auf die Standardvertragsklauseln verweisen, finden Sie unter https://business.safety.google/intl/de/adsprocessorterms/ .

You can learn a little more about reCAPTCHA on Google’s web developer page at https://developers.google.com/recaptcha/. Google does go into more detail here about the technical development of reCAPTCHA, but you will search in vain for precise information about data storage and privacy-related topics there as well. A good overview of Google’s basic use of data can be found in the company’s own privacy policy at https://policies.google.com/privacy .

XII. BorlabsCookie

We use BorlabsCookie on our website, which is, among other things, a tool for storing your cookie consent. The service provider is the German company Borlabs – Benjamin A. Bornschein, Rübenkamp 32, 22305 Hamburg, Germany. You can find out more about the data processed through the use of BorlabsCookie in the Privacy Policy at https://de.borlabs.io/datenschutz/ .

XIII Google Fonts Privacy Policy

What are Google Fonts?

We use Google Fonts on our website. These are the “Google Fonts” of the company Google Inc. For the European area, the company Google Ireland Limited (Gordon House, Barrow Street Dublin 4, Ireland) is responsible for all Google services.

You do not have to log in or enter a password to use Google fonts. Furthermore, no cookies are stored in your browser. The files (CSS, fonts) are requested via the Google domains fonts.googleapis.com and fonts.gstatic.com. According to Google, the requests for CSS and fonts are completely separate from all other Google services. If you have a Google account, you do not need to worry about your Google account information being transmitted to Google while using Google Fonts. Google records the use of CSS (Cascading Style Sheets) and the fonts used and stores this data securely. We will look at exactly how this data is stored in more detail.

Google Fonts (formerly Google Web Fonts) is a directory of over 800 fonts that Google makes available to its users free of charge.

Many of these fonts are published under the SIL Open Font License, while others are published under the Apache License. Both are free software licences.

Why do we use Google Fonts on our website?

With Google Fonts, we can use fonts on our own website and do not have to upload them to our own server. Google Fonts is an important component in keeping the quality of our website high. All Google Fonts are automatically optimised for the web and this saves data volume and is a great advantage especially for use on mobile devices. When you visit our site, the low file size ensures a fast loading time. Furthermore, Google Fonts are secure web fonts. Different image synthesis systems (rendering) in different browsers, operating systems and mobile devices can lead to errors. Such errors can sometimes distort the appearance of texts or entire web pages. Thanks to the fast Content Delivery Network (CDN), there are no cross-platform problems with Google Fonts. Google Fonts supports all major browsers (Google Chrome, Mozilla Firefox, Apple Safari, Opera) and works reliably on most modern mobile operating systems, including Android 2.2+ and iOS 4.2+ (iPhone, iPad, iPod). So we use Google Fonts so that we can present our entire online service as beautifully and consistently as possible.

What data is stored by Google?

When you visit our website, the fonts are reloaded via a Google server. This external call-up transmits data to the Google servers. In this way, Google also recognises that you or your IP address is visiting our website. The Google Fonts API was developed to reduce the use, storage and collection of end user data to what is necessary for the proper provision of fonts. By the way, API stands for “Application Programming Interface” and serves, among other things, as a data transmitter in the software sector.

Google Fonts stores CSS and font requests securely at Google and is thus protected. Through the collected usage figures, Google can determine how well the individual fonts are received. Google publishes the results on internal analysis pages, such as Google Analytics. In addition, Google also uses data from its own web crawler to determine which websites use Google Fonts. This data is published in the Google Fonts BigQuery database. Entrepreneurs and developers use the Google web service BigQuery to be able to examine and move large amounts of data.

However, it is important to remember that each Google Font request also automatically transmits information such as language settings, IP address, browser version, browser screen resolution and browser name to the Google servers. Whether this data is also stored cannot be clearly determined or is not clearly communicated by Google.

How long and where is the data stored?

Google stores requests for CSS assets for one day on its servers, which are mainly located outside the EU. This allows us to use fonts with the help of a Google stylesheet. A stylesheet is a format template that can be used to easily and quickly change the design or font of a website, for example.

The font files are stored by Google for one year. Google’s aim is to fundamentally improve the loading time of websites. If millions of web pages refer to the same fonts, they are cached after the first visit and immediately reappear on all other web pages visited later. Sometimes Google updates font files to reduce file size, increase language coverage and improve design.

How can I delete my data or prevent data storage?

The data that Google stores for one day or one year cannot simply be deleted. The data is automatically transmitted to Google when you visit the site. In order to delete this data prematurely, you must contact Google support at https://support.google.com/?hl=de&tid=312574961 . Data storage can only be prevented in this case if you do not visit our site.

Unlike other web fonts, Google allows us unlimited access to all fonts. So we can access an unlimited sea of fonts and get the most out of our website. You can find out more about Google Fonts and other issues at https://developers.google.com/fonts/faq?tid=312574961 . There, Google does go into privacy-related matters, but really detailed information about data storage is not included. It is relatively difficult to get really precise information about stored data from Google.

Legal basis

If you have consented to Google Fonts being used, the legal basis for the corresponding data processing is this consent. According to Art. 6 para. 1 lit. a DSGVO (consent), this consent constitutes the legal basis for the processing of personal data as it may occur in the collection by Google Fonts.

On our part, there is also a legitimate interest in using Google Font to optimise our online service. The corresponding legal basis for this is Art. 6 para. 1 lit. f DSGVO (Legitimate Interests). Nevertheless, we only use Google Font if you have given your consent.

Google also processes your data in the USA, among other places. We would like to point out that according to the opinion of the European Court of Justice, there is currently no adequate level of protection for the transfer of data to the USA. This may be associated with various risks for the legality and security of the data processing.

Google uses so-called standard contractual clauses (= Art. 46 para. 2 and 3 DSGVO) as the basis for data processing for recipients based in third countries (outside the European Union, Iceland, Liechtenstein, Norway, i.e. in particular the USA) or for data transfer there. Standard Contractual Clauses (SCC) are templates provided by the EU Commission and are intended to ensure that your data comply with European data protection standards even if they are transferred to third countries (such as the USA) and stored there. Through these clauses, Google undertakes to comply with the European level of data protection when processing your relevant data, even if the data is stored, processed and managed in the US. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses here, among other places: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de

The Google Ads Data Processing Terms, which also correspond to the standard contractual clauses for Google Fonts, can be found at https://business.safety.google/adsprocessorterms/ .

You can also find out what data is generally collected by Google and what this data is used for at https://www.google.com/intl/de/policies/privacy/ .


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