The use of our website is usually possible without providing personal data. As far as personal data (e.g. name or e-mail address) is collected on our pages, this is always done on a voluntary basis (e.g. via a contact form or a comment function). This data will not be passed on to third parties without your explicit consent.
In connection with your visit of our website, our server temporarily stores data for data security purposes which may allow identification (for example IP address, date, time and name of the requested file). An evaluation, except for statistical purposes in anonymous form, does not take place.
When contacting us directly (e.g. by contact form, e-mail, telephone or other means), the user’s data is processed for the purpose of handling the contact request and its processing in accordance with Art. 6 Para. 1 lit. b) GDPR.
With the contact form you agree to the processing of your personal data as mentioned above, as far as this is necessary for the purpose of the contract. You can revoke this consent in writing or by e-mail to us at any time with effect for the future.
In principle, the following types of data can be collected on our website:
- Usage data (e.g., websites visited, interest in content, access times).
- Meta- & communication data (e.g. device information, IP addresses)
- Contact data (e.g., name, e-mail – if actively entered (forms)).
- Content data (e.g., text input -if actively entered (forms)).
We process this data for the following purposes:
- Provision of the online offer, including the offered functions and contents.
- Responding to contact requests and communication with users.
- Security measure
- Reach measurement & Marketing
Cookies
Cookies” are small files that are stored on the user’s computer. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his visit to an online service. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the contents of a shopping cart in an online store or a login jam can be stored. Cookies are described as “permanent” or “persistent” if they remain stored even after the browser is closed. For example, the login status can be saved if users visit the site after several days. Likewise, the interests of the users can be stored in such a cookie, which is used for range measurement or marketing purposes. Third-party cookies are cookies that are offered by providers other than the person responsible for operating the online service (otherwise, if it is only their cookies, it is called “first-party cookies”).
We may use temporary and permanent cookies and will provide information on this in our privacy policy.
These technically necessary cookies are set by us:
| Cookie | Duration | Description |
|---|---|---|
| _wpfuuid | 10 Years | Functional Cookie set by Form Plugin |
| PHPSESSID | Session | Functional PHP Cookie |
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional limitations of this online offer.
A general objection to the use of cookies used for online marketing purposes can be declared for many of the services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that in this case not all functions of this online offer can be used.
Privacy policy for the use of Google Analytics
This website uses Google Analytics, a web analysis service of Google Inc. (“Google”). We have concluded a corresponding contract with the provider for commissioned data processing.
The relationship with the web analytics provider is based on the Privacy Shield Agreement of the European Union with the USA. Google is licensed under the Privacy Shield Framework September 2017. https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active
The data processing is based on the legal provisions of § 96 para. 3 TKG and Art 6 para. 1 lit a (consent) of the DSGVO. No data is transmitted to Google before the user has explicitly agreed to the use of Google Analytics on this website. Since the privacy of our users is important to us, the user data is pseudonymized.
By activating IP-anonymization on this website, however, your IP address will be shortened by Google within member states of the European Union or in other states which are party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. Since Google in the USA falls under 50U.S.Code §1881a, the transfer of the IP address and other data to the USA must be regarded as a transfer to an insecure third country and therefore only takes place with the explicit consent of the user.
Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. You can prevent this by setting up your browser so that no cookies are stored.
We set these cookies in your browser via Google Analytics:
Diese Cookies setzen wir über Google Analytics in Ihrem Browser:
| Cookie | Duration | Description |
|---|---|---|
| _ga | 24 Months | This cookie is used by Google Analytics to distinguish individual users and sessions. |
| _gat_UA-ID | 10 minutes | This cookie is used by Google Analytics to throttle the request rates. |
| _gid | 24 hours | This cookie is used by Google Analytics to distinguish individual users and sessions. |
More information on https://policies.google.com/technologies/types?hl=de
On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on the website activities and to provide further services to the website operator in connection with the use of the website and the Internet. The pseudonymised IP address transmitted by your browser within the framework of Google Analytics is not combined with other data from Google.
You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link http://tools.google.com/dlpage/gaoptout?hl=de.
As an alternative to the browser add-on, especially for browsers on mobile devices, you can also prevent Google Analytics from collecting data by clicking the following button:
Google marketing and remarketing services
.kloos uses the marketing and remarketing services (in short “Google Marketing Services”) of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”). Google’s marketing services allow .kloos to display ads on other websites in a more targeted manner to show users only ads that potentially match their interests.
One speaks of “remarketing” when a user is shown ads for products, for example, that he or she has been interested in on other websites.
For these purposes, when calling up our and other websites on which Google marketing services are active, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (instead of cookies, comparable technologies can also be used). The cookies can be set by various Google domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which websites the user has visited, what content he is interested in and which offers he has clicked on, as well as technical information about the browser and operating system, referring websites, visiting time and other information about the use of the online offer.
In the course of remarketing, Google may set the following cookies on our site in your browser:
| Cookie | Duration | Description |
|---|---|---|
| 1P_JAR | 12 months | These are set by Google to track how you use our website and show you advertisements that may be of interest to you. |
| CONSENT | 20 years | This cookie is used to store preferences and other information of the user. This includes in particular the preferred language, the number of search results to be displayed on the page and the decision whether or not to activate the Google SafeSearch filter. |
| IDE | 12 months | Used by Google AdWords through a DoubleClick domain to register and report the user’s actions on the web page after viewing or clicking on one of the provider’s ads. The purpose is to measure the effectiveness of an advertisement and to display targeted advertising to the user |
| NID | 6 months | Google uses cookies, such as the NID and SID cookies, to customize advertising in Google products such as Google Search. For example, Gogole uses such cookies to track your most recent searches, your past interactions with an advertiser’s ads or search results, and your visits to an advertiser’s website. In this way, it is possible to display customized ads on Google. |
| DV | 12 months | These are set by Google to track how you use our website and show you advertisements that may be of interest to you. |
More information on https://policies.google.com/technologies/types?hl=de
The IP address of the user is also recorded, whereby .kloos informs within the framework of Google Analytics that the IP address is shortened (pseudonymized) within member states of the European Union or in other states which are party to the Agreement on the European Economic Area and only in exceptional cases is it transferred in its entirety to a Google server in the USA and shortened there (see paragraph on the use of Google Analytics).
Since Google in the USA falls under 50U.S.Code §1881a, the transfer of the IP address and other data to the USA must be regarded as a transfer to an insecure third country and therefore only takes place with the explicit consent of the user.
The IP address is not merged with user data within other Google offers. Google may also combine the above-mentioned information with information from other sources. If the user subsequently visits other websites, the ads tailored to his interests can be displayed.
The data of the users are processed pseudonymously within the framework of the Google marketing services, i.e. Google does not store and process e.g. the name or the e-mail address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. This means that from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who that cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymization. The information collected by Google marketing services about users is transmitted to Google and stored on Google’s servers in the USA.
Among the Google marketing services we use is the online advertising program “Google AdWords”. In the case of Google AdWords, each AdWords customer receives a different “conversion cookie”. Cookies can therefore not be tracked through the websites of AdWords customers. The information collected through the cookie is used to compile conversion statistics for us as AdWords customers. This tells us the total number of users who clicked on our ad and were redirected to a page with a conversion tracking tag. However, .kloos does not receive any information that can be used to identify users personally.
Furthermore, we use the “Google Tag Manager” to integrate and manage the Google analysis and marketing services into our website. Further information on the use of data for marketing purposes by Google can be found on the overview page: https://www.google.com/policies/technologies/ads, the Google data protection policy can be reached at www.google.com/policies/privacy. If you wish to object to interest-related advertising by Google marketing services, you can use the setting and opt-out options provided by Google: www.google.com/ads/preferences.
Newsletter
With the following information, we will inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the described procedures.
Content of the newsletter
We send newsletters, e-mails and other electronic notifications containing promotional information (hereinafter “newsletters”) only with the consent of the recipients or with a legal permission. If, in the course of registering for the newsletter, its contents are specifically described, they are decisive for the consent of the users. In addition, our newsletters contain information on search engine optimization, search engine advertising, online tracking and other topics from the field of online marketing as well as on .kloos (this may include in particular references to blog posts, lectures or workshops, our services or online appearances).
Double-Opt-In and Logging
The registration to our newsletter is done in a so-called double opt-in procedure. This means that you will receive an e-mail after registration asking you to confirm your registration. This confirmation is necessary so that nobody can register with foreign e-mail addresses.
Newsletter registrations are logged in order to be able to prove the registration process in accordance with legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Changes to your data stored with MailChimp are also logged.
Use of the dispatch service provider MailChimp
The newsletters are sent via “MailChimp”, a newsletter dispatch platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA.
The e-mail addresses of our newsletter recipients, as well as their other data described in this notice, are stored on the servers of MailChimp in the USA. MailChimp uses this information to send and evaluate the newsletter on our behalf. Furthermore, MailChimp may use this data according to its own information to optimize or improve its own services, e.g. for technical optimization of sending and presentation of the newsletters or for economic purposes to determine from which countries the recipients come. However, MailChimp does not use the data of our newsletter recipients to write to them itself or pass them on to third parties.
We trust in the reliability and IT and data security of MailChimp.
MailChimp is Mailchimp is certified since November 2016 (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active) under the US-EU data protection agreement “Privacy Shield” and thus commits to comply with the EU data protection regulations.
Since MailChimp in the USA falls under 50U.S.Code §1881a, the transfer of the IP address and other data to the USA must be regarded as a transfer to an insecure third country and therefore only takes place with the explicit consent of the user.
Furthermore, we have concluded a “Data-Processing-Agreement” with MailChimp. This is a contract in which MailChimp commits itself to protect the data of our users, to process it on our behalf according to its data protection regulations and in particular not to pass it on to third parties. The privacy policy of MailChimp can be viewed here.
Registration data
To subscribe to the newsletter, all you have to do is enter your e-mail address. Optionally we ask you to enter your first and last name. This information is only used to personalize the newsletter. Furthermore, we also optionally ask you to enter your website. We use this information only to adapt the contents of the newsletter to the interests of our readers.
Statistical survey and analyses
The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file which is retrieved from the server of MailChimp when the newsletter is opened. In the context of this retrieval, technical information such as browser and system information, as well as your IP address and time of retrieval are collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined by means of the IP address) or the access times.
The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our nor MailChimp’s intention to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our contents to them or to send different contents according to the interests of our users.
Online access and data management
There are cases where we direct the newsletter recipients to the MailChimp web pages. E.g. our newsletters contain a link with which the newsletter recipients can retrieve the newsletters online (e.g. in case of display problems in the e-mail program). Furthermore, newsletter recipients can correct their data, e.g. the e-mail address, afterwards. Also the privacy policy of MailChimp is only available on their website.
In this context, we would like to point out that cookies are used on the websites of MailChimp and therefore personal data is processed by MailChimp, its partners and service providers (e.g. Google Analytics). We have no influence on this data collection. Further information can be found in the privacy policy of MailChimp. We would also like to point out that you have the right to object to the collection of data for advertising purposes on the websites http://www.aboutads.info/choices/ and http://www.youronlinechoices.com/(for the European area).
Termination/Revocation
You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. Your consent to receive the newsletter via MailChimp and the statistical analyses will expire at the same time. A separate cancellation of the dispatch via MailChimp or the statistical analysis is unfortunately not possible.
A link to cancel the newsletter can be found at the end of each newsletter.
Legal bases – Basic data protection regulation
In accordance with the provisions of the Basic Data Protection Regulation (DSGVO), which will come into force on 25 May 2018, we hereby inform you that consent to the sending of e-mail addresses is given on the basis of Art. 6 Para. 1 lit. a, 7 DSGVO and § 7 Para. 2 No. 3, or Para. 3 UWG. The use of the mail service provider MailChimp, the execution of statistical surveys and analyses as well as the logging of the registration procedure are based on our legitimate interests according to art. 6 para. 1 lit. f GDPR. We are interested in the use of a user-friendly and secure newsletter system, which serves our business interests and meets the expectations of the users.
Integration of third party services and content
We use “Google Fonts” on this website, i.e. fonts that are loaded via the Content Delivery Network of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Only data on specific domains such as fonts.googleapis.com or fonts.gstatic.com that is necessary to retrieve the font used is transmitted. Google says that it does not combine this data with other data. More information can be found at: https://developers.google.com/fonts/faq. The general privacy policy of Google applies: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.
To protect our site – especially our contact forms – from spam attacks, we use the Google reCAPTCHA service. The reCAPTCHA API works by collecting hardware and software information, such as device and application data, and sending this data to Google for analysis. The information collected in connection with your use of the service is used to improve reCAPTCHA and for general security purposes. It will not be used by Google for personalized advertising. Google’s general privacy policy applies: https://www.google.com/policies/. In addition to certain standard Google cookies, reCAPTCHA sets a necessary cookie (_GRECAPTCHA), for the purpose of risk analysis is executed.
In accordance with the requirements of the General Data Protection Regulation (DSGVO), we inform you that we use the service on the basis of our legitimate interests pursuant to Art. 6 (1) lit. f DSGVO.
Some of our pages contain videos that are embedded via a service provided by YouTube, a service of Google Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”). These videos are embedded with Enhanced Privacy Mode enabled, which means that YouTube does not store any information about visitors to our site unless you watch the video.
If you are logged into your YouTube account during this session, YouTube may be able to associate your browsing behavior directly with your personal profile. If you want to prevent YouTube from transmitting and storing information about you and your behavior on our site, you must log out of YouTube before you view videos on our site. The general privacy policy of Google applies: https://www.google.com/policies/privacy/
Affiliate Links
On our website (especially in some blog articles) we use so-called affiliate links to the offers of third parties (hereinafter referred to as “affiliate links”). As soon as users click on one of these affiliate links, or as soon as a contract with a third party provider is concluded after a click, we can receive a commission from the third party provider (hereinafter referred to as “commission”).
In order to be able to track which users who enter into a contract with a third party provider have come through the affiliate links on our site, this information
must be disclosed to the third party provider. For this purpose, these affiliate links may be supplemented by certain values, which are either part of the link or may be stored in a cookie.
These values include in particular the initial website (referrer), the time, an online identification of the operator of the website on which the affiliate link was located, an online identification of the respective offer, the type of link used, the type of offer and an online identification of the user.
The assignment of the affiliate links to the respective contract conclusions or other actions serves the sole purpose of the commission settlement and is cancelled as soon as it is no longer necessary for the purpose.
Online presence in social media
WWe also maintain online presences within social networks and platforms, namely Facebook, LinkedIn, Google+, YoutTube and Twitter, in order to communicate with customers, prospects and users who are active there and to inform them about our services via these channels. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.
Unless otherwise stated in our privacy policy, we process the data of users if they communicate with us within the social networks and platforms, e.g. write articles on our online presences or send us messages.
Right of objection
We would also like to point out that you can object to the future processing of your personal data at any time in accordance with the legal requirements under Art. 21 DSGVO. The objection can be made in particular against processing for the purposes of direct advertising.
Source: Sample disclaimer from www.disclaimer.de, attorney at law for traffic law in Hamburg, as well as a sample for the fulfillment of the data protection information obligations for websites by the Vienna Chamber of Commerce. Information about the newsletter according to the sample provided by attorney Dr. Thomas Schwenke