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Privacy Policy

A legal disclaimer

The explanations and information provided on this page are only general and high-level explanations and information on how to write your own document of a Privacy Policy. You should not rely on this article as legal advice or as recommendations regarding what you should actually do, because we cannot know in advance what are the specific privacy policies you wish to establish between your business and your customers and visitors. We recommend that you seek legal advice to help you understand and to assist you in the creation of your own Privacy Policy. 

Privacy Policy - the basics 

Having said that, a privacy policy is a statement that discloses some or all of the ways a website collects, uses, discloses, processes, and manages the data of its visitors and customers. It usually also includes a statement regarding the website’s commitment to protecting its visitors’ or customers’ privacy, and an explanation about the different mechanisms the website is implementing in order to protect privacy. 

 

Different jurisdictions have different legal obligations of what must be included in a Privacy Policy. You are responsible to make sure you are following the relevant legislation to your activities and location.

What to include in the Privacy Policy

Generally speaking, a Privacy Policy often addresses these types of issues: the types of information the website is collecting and the manner in which it collects the data; an explanation about why is the website collecting these types of information; what are the website’s practices on sharing the information with third parties; ways in which your visitors an customers can exercise their rights according to the relevant privacy legislation; the specific practices regarding minors’ data collection; and much much more. 


To learn more about this, check out our article “Creating a Privacy Policy”.

Imprint

Address

TruVenturo GmbH 
Große Reichenstraße 27 
20457 Hamburg, Germany
E info(at)truventuro.com

Registered offices

Große Reichenstraße 27, 20457 Hamburg, Germany

Managing director and responsible according to § 5 Telemediengesetz

Dr. Daniel Kreutzmann & Felix Schneider

Trade register

Amtsgericht Hamburg, Handelsregister HRB: 106115 
Umsatzsteuer-ID: DE 261 598 781

Privacy Policy

Last updated: August 29, 2022

Table of Contents

  • Controller

  • Overview of Data Processing

  • Relevant Legal Bases

  • Security Measures

  • Transfer of Personal Data

  • Data Processing in Third Countries

  • Deletion of Data

  • Use of Cookies

  • Business Services

  • Provision of Online Offer and Web Hosting

  • Contact and Request Management

  • Application Procedure

  • Cloud Services

  • Web Analytics, Monitoring and Optimization

  • Social Media Presences

  • Changes and Updates to the Privacy Policy

  • Rights of Data Subjects

  • Definitions

Controller

TruVenturo GmbH

Große Reichenstraße 27

20457 Hamburg, Germany

E-mail: info(at)truventuro.com

Authorized representative:

Dr. Daniel Kreutzmann

 

E-mail address:

info@truventuro.com

Overview of Data Processing

The following overview summarizes the types of data processed, the purposes of their processing, and the categories of data subjects.

Types of Data Processed

  • Inventory data

  • Payment data

  • Contact data

  • Content data

  • Contract data

  • Usage data

  • Meta/communication data

  • Applicant data

Categories of Data Subjects

  • Customers

  • Employees

  • Interested parties

  • Communication partners

  • Users

  • Applicants

  • Business and contractual partners

Purposes of Processing

  • Performance of contractual services and customer support

  • Contact requests and communication

  • Security measures

  • Reach measurement

  • Tracking

  • Office and organizational procedures

  • Conversion measurement

  • Administration and response to inquiries

  • Application procedure

  • Feedback

  • Marketing

  • Profiles with user-related information

  • Provision of our online offering and user-friendliness

  • Information technology infrastructure

Relevant Legal Bases

Below you will find an overview of the legal bases of the GDPR on which we process personal data. Please note that, in addition to the regulations of the GDPR, national data protection regulations in your or our country of residence or registered office may apply. If, in individual cases, more specific legal bases are relevant, we will inform you in the privacy policy.

  • Consent (Art. 6(1)(a) GDPR): The data subject has given consent to the processing of their personal data for one or more specific purposes.

  • Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR): Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

  • Legal obligation (Art. 6(1)(c) GDPR): Processing is necessary for compliance with a legal obligation to which the controller is subject.

  • Legitimate interests (Art. 6(1)(f) GDPR): Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

 

 

In addition to the GDPR, national data protection regulations apply in Germany, in particular the Federal Data Protection Act (BDSG), which includes special provisions on the right to information, deletion, the right to object, the processing of special categories of personal data, processing for other purposes, and transmission and automated decision-making in individual cases, including profiling. It also governs data processing for employment purposes (§ 26 BDSG), especially regarding the establishment, implementation, or termination of employment relationships and employee consent. State data protection laws of the individual federal states may also apply.

Security Measures

We take appropriate technical and organizational measures, considering the state of the art, implementation costs, nature, scope, circumstances, and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk.


These measures include, in particular, securing the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access, input, transmission, securing availability, and separation of the data. We have procedures in place to ensure the exercise of data subject rights, deletion of data, and response to data threats. Furthermore, we consider the protection of personal data during the development or selection of hardware, software, and processes in accordance with the principle of data protection by design and by default.


SSL Encryption (https): To protect your data transmitted via our online offering, we use SSL encryption. You can recognize encrypted connections by the prefix https:// in your browser’s address bar.

Transfer of Personal Data

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


Data transfer within the corporate group: We may transfer personal data to other companies within our corporate group or grant them access to such data. If the transfer is for administrative purposes, it is based on our legitimate business and economic interests or is necessary to fulfill our contractual obligations, or if consent of the data subjects or legal permission exists.


Data transfer within the organization: We may transfer personal data to other entities within our organization or grant them access to such data. If the transfer is for administrative purposes, it is based on our legitimate business and economic interests or is necessary to fulfill our contractual obligations, or if consent of the data subjects or legal permission exists.

Data Processing in Third Countries

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


Unless explicit consent is given or transfer is contractually or legally required, we process or allow the data to be processed only in third countries with a recognized level of data protection, based on contractual obligations through so-called standard contractual clauses of the EU Commission, with existing certifications, or binding internal data protection regulations (Art. 44 to 49 GDPR, EU Commission information page: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).

Deletion of Data

The data we process is deleted in accordance with legal requirements as soon as the consents permitted for processing are revoked or other permissions lapse (e.g., if the purpose of processing this data no longer applies or it is no longer required for the purpose). If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted to those purposes. That is, the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons or whose storage is necessary for asserting, exercising, or defending legal claims or protecting the rights of another natural or legal person.


Within our privacy notices, we may provide users with additional information regarding deletion and retention of data, which specifically applies to the respective processing operations.

Use of Cookies

Cookies are small text files or other storage notes that store information on end devices and retrieve information from end devices. For example, to store the login status in a user account, a shopping cart content in an online shop, the content accessed, or functions used in an online offering. Cookies can also be used for various purposes, e.g., to ensure the functionality, security, and comfort of online offerings as well as for the analysis of visitor flows.


Consent Notice: We use cookies in accordance with legal requirements. Therefore, we obtain prior consent from users, unless this is not required by law. Consent is not particularly necessary if the storage and retrieval of the information, including cookies, is absolutely necessary to provide users with a telemedia service expressly requested by them (i.e., our online offering). The revocable consent is clearly communicated to users and contains information on the respective use of cookies.


Information on legal bases: The 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 processing their data is the declared consent. Otherwise, the data processed by cookies is processed on the basis of our legitimate interests (e.g., in the economical operation of our online offering and its improvement) or, if necessary for fulfilling our contractual obligations, if the use of cookies is required to fulfill our contractual obligations. We clarify for which purposes the cookies are processed by us in the course of this privacy policy or as part of our consent and processing procedures.


Retention Period: With regard to retention period, the following types of cookies are distinguished:


  • Temporary cookies (also: session or session cookies): These are deleted at the latest after a user leaves an online offering and closes their end device (e.g., browser or mobile application).

  • Permanent cookies: These remain stored even after the device is closed. For example, the login status can be saved, or preferred content can be displayed directly when the user revisits a website. Similarly, the data collected with cookies can be used for reach measurement. Unless we provide explicit information on the type and retention period of cookies (e.g., as part of obtaining consent), users should assume that cookies are permanent and can be stored for up to two years.



General information on withdrawal and objection (opt-out): Users can revoke their consents at any time and object to processing in accordance with legal requirements under Art. 21 GDPR. Users can also declare their objection through the settings of their browser, e.g., by disabling the use of cookies (which may limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.


Further information on processing operations, procedures, and services:


Processing of cookie data on the basis of consent: We use a cookie consent management procedure, in which users’ consents to the use of cookies, or the processing and providers specified within the cookie consent management procedure, are obtained, managed, and revocable by the users. The consent declaration is stored so that its query does not have to be repeated and the consent can be proven according to the legal obligation. The storage can be server-side and/or in a cookie (so-called opt-in cookie, or using comparable technologies) to assign the consent to a user or their device. Unless individual information on providers of cookie management services is provided, the following applies: the duration of consent storage can be up to two years. A pseudonymous user identifier is formed and stored with the time of consent, information on the scope of consent (e.g., which categories of cookies and/or service providers) as well as the browser, system, and device used.

Business Services

We process the data of our contractual and business partners, e.g., customers and interested parties (collectively referred to as “contractual partners”) within the framework of contractual and similar legal relationships and related measures and in the context of communication with the contractual partners (or pre-contractually), e.g., to answer inquiries.

 

We process this data to fulfill our contractual obligations. This includes, in particular, obligations to provide the agreed services, any update obligations, and remedies for warranty and other performance disruptions. We also process the data to protect our rights and for administrative tasks associated with these obligations and for company organization. Furthermore, we process the data on the basis of our legitimate interests in proper and economical business management as well as security measures to protect our contractual partners and our business operations from misuse, risks to their data, secrets, information, and rights (e.g., involving telecommunications, transport, and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers, or tax authorities). Under applicable law, we only disclose data from contractual partners to third parties to the extent required for the above purposes or to fulfill legal obligations. Contractual partners are informed of further forms of processing, e.g., for marketing purposes, as part of this privacy policy.

 

Which data is necessary for the above purposes is communicated to the contractual partners prior to or during the data collection process, e.g., in online forms, by special markings (e.g., colors) or symbols (e.g., asterisks), or personally.

 

We delete the data after the expiry of statutory warranty and similar obligations, i.e., as a rule after four years, unless the data is stored in a customer account, e.g., as long as it must be retained for legal reasons. The statutory retention period for tax-relevant documents as well as commercial books, inventories, opening balances, annual financial statements, and the documents required for their understanding, as well as other organizational documents and booking receipts, is ten years, and for received commercial and business letters and reproductions of sent commercial and business letters, six years. The period begins at the end of the calendar year in which the last entry was made, the inventory, opening balance, annual financial statement, or management report was prepared, the commercial or business letter was received or sent, or the booking receipt was created, and in which the record was made or the other documents were created.

 

If we use third-party providers or platforms for the provision of our services, the terms and privacy policies of the respective third-party providers or platforms apply in the relationship between the users and the providers.

 

Data types processed: Inventory 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, duration, customer category); usage data (e.g., visited websites, interest in content, access times); meta/communication data (e.g., device information, IP addresses); applicant data (e.g., information about the person, postal and contact addresses, application documents, and the information contained therein, such as cover letters, CVs, certificates, as well as other information about the person or qualifications provided voluntarily by applicants).

 

Data subjects: Interested parties; business and contractual partners; customers; applicants.

 

Purposes of processing: Performance of contractual services and customer support; contact requests and communication; office and organizational procedures; administration and response to inquiries; conversion measurement (measuring the effectiveness of marketing measures); profiles with user-related information (creating user profiles).

 

Legal bases: Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR); legal obligation (Art. 6(1)(c) GDPR); legitimate interests (Art. 6(1)(f) GDPR).

Contact and Request Management

When contacting us (e.g., via contact form, email, telephone, or social media) and within the framework of existing user and business relationships, the information of the requesting persons is processed to the extent necessary to answer the contact requests and any requested measures.


The response to contact requests and the management of contact and request data within the context of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to respond to (pre-)contractual inquiries and otherwise on the basis of legitimate interests in responding to inquiries and maintaining user or business relationships.


Data types processed: Contact data (e.g., email, telephone numbers); content data (e.g., entries in online forms); usage data (e.g., visited websites, interest in content, access times); meta/communication data (e.g., device information, IP addresses).


Data subjects: Communication partners.


Purposes of processing: Contact requests and communication; administration and response to inquiries; feedback (e.g., collecting feedback via online form); provision of our online offer and user-friendliness; performance of contractual services and customer support.


Legal bases: Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR); legitimate interests (Art. 6(1)(f) GDPR).

Application Procedure

The application procedure requires applicants to provide us with the data necessary for their assessment and selection. Which information is required can be found in the job description or, in the case of online forms, in the relevant information provided there.


As a rule, the required information includes details about the person, such as name, address, contact information, and evidence of qualifications required for the position. Upon request, we will provide additional information about which details are necessary.


If provided, applicants may submit their applications via an online form. The data will be encrypted in accordance with the state of the art when transmitted to us. Applicants may also submit their applications via email. Please note that emails are generally not sent encrypted over the Internet. Typically, emails are encrypted during transport, but not on the servers from which they are sent and received. Therefore, we cannot take responsibility for the transmission path of the application between the sender and receipt on our server.


For the purposes of applicant search, submission of applications, and selection of applicants, we may use applicant management or recruitment software and platforms and services of third-party providers in compliance with legal requirements.


Applicants are welcome to contact us about the type of submission of their application or to send the application by post.


Processing of special categories of data: Where special categories of personal data within the meaning of Art. 9(1) GDPR (e.g., health data such as information about a disability or ethnic origin) are requested as part of the application procedure so that the controller or the data subject can exercise the rights arising from employment law and social security and social protection law and fulfill their obligations in this regard, processing is carried out in accordance with Art. 9(2)(b) GDPR, in the case of the protection of vital interests of applicants or other persons in accordance with Art. 9(2)(c) GDPR, or for purposes of preventive health care or occupational medicine, for the assessment of the working capacity of the employee, for medical diagnosis, care or treatment in the health or social sector, or for the management of systems and services in the health or social sector in accordance with Art. 9(2)(h) GDPR. If, on a voluntary basis, applicants provide special categories of data based on consent, processing is carried out on the basis of Art. 9(2)(a) GDPR.


Deletion of data: Data provided by applicants may, in the case of a successful application, 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. Applicant data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. Unless there is a justified revocation by the applicants, deletion takes place at the latest after six months, so that we can answer any follow-up questions about the application and meet our obligations under the provisions on equal treatment of applicants. Invoices for any travel expense reimbursement are archived in accordance with tax regulations.


Inclusion in an applicant pool: Inclusion in a pool of applicants, if offered, is based on consent. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application procedure, and that they can withdraw their consent at any time for the future.


Duration of data retention in the applicant pool (in months): 24


Data types processed: Inventory data (e.g., names, addresses); contact data (e.g., email, telephone numbers); content data (e.g., entries in online forms); applicant data (e.g., information about the person, postal and contact addresses, application documents, and the information contained therein, such as cover letters, CVs, certificates, as well as other information about the person or qualifications provided voluntarily by applicants).


Data subjects: Applicants.


Purposes of processing: Application procedure (establishment and possible subsequent implementation and possible subsequent termination of the employment relationship).


Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Cloud Services

We use software services accessible via the Internet and operated on the servers of their providers (so-called “cloud services” or “Software as a Service”) for the following purposes: document storage and management, calendar management, email dispatch, spreadsheet and presentation processing, exchange of documents, content, and information with specific recipients or the publication of web pages, forms, or other content and information, as well as chats and participation in audio and video conferences.


In this context, personal data may be processed and stored on the servers of the providers, to the extent that they are part of communications with us or otherwise processed by us as described in this privacy policy. These data may include, in particular, inventory and contact data of users, data concerning processes, contracts, other procedures, and their contents. The providers of the cloud services also process usage data and metadata, which are used by them for security purposes and service optimization.


If we make forms or similar documents and content available to other users or publicly accessible websites using the cloud services, 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).


Data types processed: Inventory data (e.g., names, addresses); contact data (e.g., email, telephone numbers); content data (e.g., entries in online forms); usage data (e.g., visited websites, interest in content, access times); meta/communication data (e.g., device information, IP addresses).


Data subjects: Customers; employees (e.g., employees, applicants, former employees); interested parties; communication partners; users (e.g., website visitors, users of online services).


Purposes of processing: Office and organizational procedures; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)).


Legal bases: Contract performance and pre-contractual inquiries (Art. 6(1)(b) GDPR); legitimate interests (Art. 6(1)(f) GDPR).

Web Analytics, Monitoring, and Optimization

Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and can include behavior, interests, or demographic information about the visitors, such as age or gender, as pseudonymous values. With reach analysis, we can recognize, for example, at what time our online offering or its features or content are used most frequently or invite reuse. We can also track which areas require optimization.


In addition to web analytics, we may use testing procedures to test and optimize different versions of our online offering or its components.


Unless otherwise stated below, profiles can be created for these purposes, i.e., data grouped for a usage process and information stored and read in a browser or device. Collected information includes, in particular, visited websites and elements used there as well as technical information, such as the browser used, the computer system used, and information about usage times. If users have agreed to the collection of their location data, we or the providers of the services we use may process location data.


IP addresses of users are also stored. However, we use IP masking (i.e., pseudonymization by shortening the IP address) to protect users. Generally, in web analytics, A/B testing, and optimization, no clear data of users (such as email addresses or names) is stored, but rather pseudonyms. That is, we and the providers of the software used do not know the actual identity of the users, only the information stored in their profiles for the purposes of the respective procedures.


Data types processed: Usage data (e.g., visited websites, interest in content, access times); meta/communication data (e.g., device information, IP addresses).


Data subjects: Users (e.g., website visitors, users of online services).


Purposes of processing: Reach measurement (e.g., access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles); tracking (e.g., interest-/behavior-based profiling, use of cookies); provision of our online offer and user-friendliness.


Security measures: IP masking (pseudonymization of IP addresses).


Legal bases: Consent (Art. 6(1)(a) GDPR).

Social Media Presences

We maintain online presences within social networks and process users’ data in this context to communicate with users active there or to offer information about us.


We point out that users’ data may be processed outside the European Union. This may entail risks for users because, for example, the enforcement of users’ rights may be more difficult.


Furthermore, users’ data within social networks are generally processed for market research and advertising purposes. For example, usage profiles can be created based on users’ usage behavior and resulting interests. These usage profiles can in turn be used, for example, to display advertisements inside and outside the networks that are likely to correspond to users’ interests. Cookies are generally stored on users’ computers for these purposes, in which users’ usage behavior and interests are stored. Data can also be stored in the usage profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in).


For a detailed presentation of the respective processing forms and opt-out options, we refer to the privacy policies and information provided by the operators of the respective networks.


Also, in the case of requests for information and the exercise of data subject rights, we point out that these can be most effectively asserted with the providers. Only the providers have access to the users’ data and can take direct action and provide information. Should you need help nonetheless, you can contact us.


Data types processed: Contact data (e.g., email, telephone numbers); content data (e.g., entries in online forms); usage data (e.g., visited websites, interest in content, access times); meta/communication data (e.g., device information, IP addresses).


Data subjects: Users (e.g., website visitors, users of online services).


Purposes of processing: Contact requests and communication; feedback (e.g., collecting feedback via online form); marketing.


Legal bases: Legitimate interests (Art. 6(1)(f) GDPR).

Changes and Updates to the Privacy Policy

We ask you to regularly inform yourself about the content of our privacy policy. We will adjust the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your participation (e.g., consent) or other individual notification.


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

Rights of Data Subjects

As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:

  • Right to object: You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you, which is based on Art. 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions. If 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 consents at any time.

  • Right to information: You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about this data as well as further information and a copy of the data in accordance with legal requirements.

  • Right to rectification: You have the right to request the completion or correction of data concerning you in accordance with legal requirements.

  • Right to erasure and restriction of processing: You have the right to request, in accordance with legal requirements, that data concerning you be deleted without undue delay or, alternatively, to request restriction of processing of the data in accordance with legal requirements.

  • Right to data portability: You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format in accordance with legal requirements, or to request its transmission to another controller.

  • Right to lodge a complaint with a supervisory authority: In accordance with legal 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 in the Member State of your habitual residence, place of work, or place of the alleged infringement, if you believe that the processing of personal data concerning you violates the GDPR.

Definitions

This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined primarily in Article 4 of the GDPR. The legal definitions are binding. The following explanations serve primarily to promote understanding. The terms are listed alphabetically.


  • Conversion measurement: Conversion measurement (also referred to as “visit action evaluation”) is a procedure that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on users’ devices within the websites on which the marketing activities take place and then retrieved again on the target website. For example, we can thus track whether the advertisements we have placed on other websites were successful.

  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

  • Profiles with user-related information: Processing of “profiles with user-related information,” or simply “profiles,” includes any type of automated processing of personal data that consists of using such personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, different information concerning demographics, behavior, and interests, such as interaction with websites and their content, etc., may be analyzed, evaluated, or predicted; e.g., interests in certain content or products, click behavior on a website, or location). Cookies and web beacons are often used for profiling purposes.

  • Reach measurement: Reach measurement (also referred to as web analytics) is used to evaluate the flow of visitors to an online offering and may include behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can, for example, recognize at what time visitors visit their website and which content they are interested in. This allows them, for example, to better adapt the content of the website to the needs of their visitors. For reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offering.

  • Tracking: “Tracking” refers to the ability to track user behavior across multiple online offerings. As a rule, behavioral and interest information regarding the used online offerings is stored in cookies or on the servers of the providers of tracking technologies (so-called profiling). This information can then, for example, be used to display advertisements to users that are likely to correspond to their interests.

  • Controller: A “controller” is the natural or legal person, authority, institution, or other body that alone or jointly with others determines the purposes and means of the processing of personal data.

  • Processing: “Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers virtually any handling of data, whether collection, evaluation, storage, transmission, or erasure.

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