Privacy Policy
Data protection is a special concern for Salvia Hotels GmbH. Our efforts to meet the requirements of the European General Data Protection Regulation (GDPR) and the Federal Data Protection Act in its new version are primarily aimed at respecting your privacy and personal sphere.
For modern companies like Salvia Hotels GmbH, the use of electronic data processing systems (EDP) is essential. We ensure the highest level of compliance with legal regulations.
The use of the websites of Salvia Hotels GmbH is generally possible without providing any personal data. However, if a data subject wishes to use special services from our company through our website, it may be necessary to process personal data. If the processing of personal data is required and there is no legal basis for such processing, we will generally obtain consent from the data subject. We will not sell or rent your personal information to third parties for their marketing or other purposes under any circumstances. If you do not agree with the provisions of the privacy policy, please do not send us any personal data.
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General / Definitions
This privacy policy is based on terms from the GDPR and aims to be easily readable and understandable for everyone. Therefore, we would like to explain various terms in advance:
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Personal Data
Personal data is any information relating to an identified or identifiable natural person (hereinafter referred to as “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, identification number, location data, online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
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Data Subject
The data subject is any identified or identifiable natural person whose personal data is processed by the data controller.
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Processing
Processing is any operation or set of operations performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, deletion, or destruction.
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Restriction of Processing
Restriction of processing is the marking of stored personal data with the aim of limiting their future processing.
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Profiling
Profiling is any form of automated processing of personal data that involves using personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements of that natural person.
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Pseudonymization
Pseudonymization is the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures that ensure that the personal data is not assigned to an identified or identifiable natural person.
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Controller
The controller is the natural or legal person, authority, agency, or other body that alone or jointly with others determines the purposes and means of processing personal data. Where the purposes and means of such processing are determined by Union law or the law of the Member States, the controller or the specific criteria for its designation may be provided for by Union law or the law of the Member States.
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Processor
A processor is a natural or legal person, authority, agency, or other body that processes personal data on behalf of the controller.
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Recipient
A recipient is a natural or legal person, authority, agency, or other body to whom personal data are disclosed, regardless of whether they are a third party or not. However, authorities that may receive personal data in the course of a specific investigation under Union law or the law of the Member States are not considered recipients.
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Third Party
A third party is a natural or legal person, authority, agency, or other body other than the data subject, the controller, the processor, and the persons who, under the direct authority of the controller or the processor, are authorized to process the personal data.
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Consent
Consent is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes, by which they signify agreement to the processing of personal data relating to them, by means of a statement or a clear affirmative action.
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Information on the Collection of Personal Data
Below, we inform you about the collection of personal data when using our website. Personal data are all data that relate to you personally, such as your name, address, email addresses, user behavior, etc.
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The controller according to Article 4 (7) of the EU General Data Protection Regulation (GDPR) is
Salvia Hotels GmbH, represented by the managing director
Marc Reiner
Seewiesenstraße 18
73054 Eislingen
Tel: +49 7161 94500-200
E-Mail: m.reiner@salvia-hotels.de
Website: www.portofino-eislingen.de -
Our data protection officer is:
Mr. Attorney Sascha Weller, IDR – Institute for Data Protection Law
Ziegelbräustraße 7
85049 Ingolstadt
Tel.: +49 841 88516715
E-Mail: ra-weller@idr-datenschutz.de
Web: www.idr-datenschutz.de -
When you contact us by email or via a contact form, the data you provide (your email address, possibly your name, and your phone number) will be automatically stored by us to answer your inquiries. Such personal data transmitted voluntarily by a data subject to the controller will be stored exclusively for the purposes of processing or contacting the data subject. We will delete the data collected in this context once the storage is no longer necessary, or restrict the processing if there are legal retention obligations.
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If we use commissioned service providers for individual functions of our offering or would like to use your data for advertising purposes, we will inform you in detail about the respective processes below. We will also specify the criteria for the duration of storage.
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As the controller, we have implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. Nevertheless, internet-based data transmissions can generally have security vulnerabilities, so absolute protection cannot be guaranteed. For this reason, it is at the discretion of each data subject to transmit personal data to us via alternative means, such as by telephone.
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As a responsible company, we refrain from automated decision-making or profiling.
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Your Rights
You have the following rights regarding your personal data:
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Right to Access
Any person affected by the processing of personal data has the right, granted by the GDPR, to obtain from the controller free information about the personal data concerning them and a copy of this information at any time. Furthermore, the European legislator has granted the data subject the right to be informed about the following information:
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the purposes of the processing
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the categories of personal data that are being processed
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the recipients or categories of recipients to whom the personal data have been or will be disclosed, especially recipients in third countries or international organizations
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if possible, the planned duration for which the personal data will be stored, or, if that is not possible, the criteria used to determine that duration
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the existence of the right to rectification or deletion of the personal data concerning them or to the restriction of processing by the controller or a right to object to such processing
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the existence of a right to lodge a complaint with a supervisory authority
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if the personal data is not collected from the data subject: all available information about the source of the data
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The existence of automated decision-making, including profiling, in accordance with Article 22(1) and (4) GDPR, and—at least in these cases—meaningful information about the logic involved as well as the significance and the intended consequences of such processing for the data subject. In addition, the data subject has the right to know whether personal data has been transferred to a third country or to an international organization. If this is the case, the data subject also has the right to obtain information about the appropriate safeguards relating to the transfer.
If a data subject wishes to exercise this right to access, they may contact any employee of the controller at any time. -
Right to Withdraw Consent:
Any person affected by the processing of personal data has the right to withdraw their consent to the processing of personal data at any time. If a data subject wishes to exercise this right to withdraw consent, they may contact any employee of the controller at any time and through any means of communication. -
Right to Rectification:
The data subject has the right to request from the controller the rectification of inaccurate personal data concerning them without undue delay. Taking into account the purposes of the processing, the data subject has the right to request the completion of incomplete personal data—also by means of a supplementary statement. If a data subject wishes to exercise this right, they may contact any employee of the controller at any time.
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Right to Deletion / Right to Be Forgotten:
The data subject has the right to request from the controller the immediate deletion of personal data concerning them, and the controller is obliged to delete personal data immediately if one of the following reasons applies:
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The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
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The data subject withdraws their consent on which the processing is based according to Article 6(1)(a) or Article 9(2)(a), and there is no other legal basis for the processing.
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The data subject objects to the processing according to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing according to Article 21(2).
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The personal data have been unlawfully processed.
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The deletion of personal data is necessary to fulfill a legal obligation under Union law or the law of the Member States to which the controller is subject.
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The personal data were collected in relation to services offered by the information society according to Article 8(1). If a data subject wishes to exercise this right to deletion / right to be forgotten, they may contact any employee of the controller at any time. If we have made the personal data public and are obliged to delete it under Article 17(1) GDPR, we will take reasonable measures, including technical measures, to inform controllers that process the personal data that a data subject has requested the deletion of all links to this personal data or copies or replications of this personal data. Our employees will take the necessary steps.
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Right to Restriction of Processing:
The data subject has the right to request the restriction of processing from the controller if one of the following conditions is met:
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The accuracy of the personal data is contested by the data subject for a duration that allows the controller to verify the accuracy of the personal data.
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The processing is unlawful, and the data subject refuses the deletion of the personal data and instead requests the restriction of the use of the personal data.
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The controller no longer needs the personal data for the purposes of processing.
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The data subject needs the personal data for the establishment, exercise, or defense of legal claims, or the data subject has objected to the processing according to Article 21(1) while it is still unclear whether the legitimate grounds of the controller override those of the data subject. If a data subject wishes to exercise this right to restrict processing, they may contact any employee of the controller at any time.
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Right to Object to Processing:
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Every person affected by the processing of personal data has the right granted by the GDPR to object at any time to the processing of personal data concerning them, based on grounds relating to their particular situation, which is carried out pursuant to Article 6(1)(e) or (f) of the GDPR. This also applies to profiling based on these provisions.
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We will no longer process personal data in the event of an objection unless we can demonstrate compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the data subject, or the processing serves the establishment, exercise, or defense of legal claims.
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If we process personal data for the purpose of direct marketing, the data subject has the right to object at any time to the processing of personal data for the purposes of such advertising. This also applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the processing for direct marketing purposes, we will no longer process the personal data for these purposes.
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Furthermore, the data subject has the right to object, on grounds relating to their particular situation, to the processing of personal data concerning them that is carried out for scientific or historical research purposes or for statistical purposes in accordance with Article 89(1) of the GDPR, unless such processing is necessary for the performance of a task carried out in the public interest.
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To exercise the right to object, the data subject may contact any employee directly. The data subject is also free to exercise their right to object in connection with the use of information society services, regardless of Directive 2002/58/EC, through automated means that use technical specifications.
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Right to Data Portability: The data subject has the right to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used, and machine-readable format, and they have the right to transmit those data to another controller without hindrance from the controller to whom the personal data has been provided, provided that
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the processing is based on consent according to Article 6(1)(a) or Article 9(2)(a) or on a contract according to Article 6(1)(b) and
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the processing is carried out by automated means. In exercising their right to data portability according to Article 20(1) of the GDPR, the data subject has the right to obtain the direct transfer of personal data from one controller to another, where technically feasible and without adversely affecting the rights and freedoms of other persons. If a data subject wishes to exercise their right to data portability, they can contact an employee of the controller at any time.
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Automated Decision-Making in Individual Cases Including Profiling: Every data subject has the right granted by the GDPR not to be subjected to a decision based solely on automated processing—including profiling—that produces legal effects concerning them or similarly significantly affects them, unless the decision
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is necessary for entering into or performance of a contract between the data subject and the controller, or
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is authorized by Union or Member State law to which the controller is subject and that law provides for suitable measures to safeguard the rights and freedoms as well as the legitimate interests of the data subject, or
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is based on the explicit consent of the data subject.
If the decision is necessary for entering into or performance of a contract between the data subject and the controller or is based on the explicit consent of the data subject, we will implement appropriate measures to safeguard the rights and freedoms as well as the legitimate interests of the data subject, which include at least the right to obtain human intervention on the part of the controller, to express their own point of view, and to contest the decision.
If a data subject wishes to assert rights regarding automated decisions, they can contact an employee of the controller at any time.
They also have the right to lodge a complaint with a supervisory authority regarding the processing of their personal data by us. The supervisory authority responsible for our company is:
Bavarian State Office for Data Protection Supervision
Promenade 27
91522 Ansbach
Tel.: +49 981 531300
E-Mail: poststelle@lda.bayern.de -
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Collection of Personal Data When Visiting Our Website / Cookies
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When you use our website merely for informational purposes, meaning that you do not register or otherwise transmit information to us, we only collect the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data, which is technically necessary for us to display our website and ensure stability and security (the legal basis is Article 6(1)(1)(f) GDPR):
- IP address
- Date and time of the request
- Time zone difference to Greenwich Mean Time (GMT)
- Internet service provider of the accessing system
- Content of the request (specific page)
- Access status/HTTP status code
- Volume of data transmitted
- Website from which the request originates (referrer)
- Browser
- Operating system and its interface
- Language and version of the browser software.
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In addition to the data mentioned above, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard drive and associated with the browser you are using, through which certain information flows to the entity that sets the cookie (in this case, us). Cookies cannot execute programs or transmit viruses to your computer. They serve to make the overall internet offering more user-friendly and effective.
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Use of Cookies:
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This website uses the following types of cookies, which are explained in detail below:
- Transient Cookies (see b)
- Persistent Cookies (see c)
- Flash Cookies (see f)
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Transient cookies are automatically deleted when you close your browser. This particularly includes session cookies. These store a so-called session ID, with which various requests from your browser can be assigned to the same session. This allows your computer to be recognized when you return to our website. The session cookies are deleted when you log out or close the browser.
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Persistent cookies are automatically deleted after a predefined period, which may vary depending on the cookie. You can delete the cookies at any time in the security settings of your browser.
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You can configure your browser settings according to your preferences and, for example, reject the acceptance of third-party cookies or all cookies. We would like to point out that you may not be able to use all the features of this website.
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We use cookies to identify you for subsequent visits if you have an account with us. Otherwise, you would have to log in again for each visit.
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The Flash cookies used are not captured by your browser but by your Flash plug-in.
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Additional Functions and Services of Our Website
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In addition to the purely informational use of our website, we offer various services that you can use if you are interested. In this case, you will generally need to provide further personal data, which we use to deliver the respective service, and to which the previously mentioned principles of data processing apply.
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We sometimes rely on external service providers for processing your data. These have been carefully selected and commissioned by us, are bound by our instructions, and are regularly monitored.
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The hosting services we utilize serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, security services, and technical maintenance services, which we use for the operation of this online offering. In this context, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta, and communication data from customers, interested parties, and visitors to this online offering based on our legitimate interests in the efficient and secure provision of this online offering in accordance with Art. 6 (1) lit. f GDPR in conjunction with Art. 28 GDPR.
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Furthermore, we may pass on your personal data to third parties when participation in actions, contests, contract conclusions, or similar services are offered by us together with partners. You will receive further information on this when you provide your personal data or below in the description of the offer.
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As far as our service providers or partners are located in a country outside the European Economic Area (EEA), we will inform you about the consequences of this circumstance in the description of the offer.
Data Protection in Applications
The controller collects and processes the personal data of applicants for the purpose of conducting the application process. The processing may also occur electronically. This is particularly the case when an applicant submits corresponding application documents electronically, for example, via email or through a contact form available on the website. If the controller concludes an employment contract with an applicant, the transmitted data will be stored for the purpose of processing the employment contract in compliance with legal regulations. If no employment contract is concluded with the applicant, the application documents will be automatically deleted unless there are other legitimate interests of the controller opposing deletion. Other legitimate interests in this sense may include a duty of proof in proceedings under the General Equal Treatment Act (AGG). The processing of applicant data takes place to fulfill our (pre-) contractual obligations in the context of the application process within the meaning of Art. 6 (1) lit. b GDPR and Art. 6 (1) lit. f GDPR if the data processing becomes necessary for us, for example, in legal proceedings (in Germany, § 26 BDSG also applies).
Objection or Withdrawal of Consent Against the Processing of Your Data
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If you have given consent to the processing of your data, you can withdraw this consent at any time and through any communication method. Such a withdrawal affects the legality of the processing of your personal data after you have expressed it to us.
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As far as we base the processing of your personal data on a balancing of interests, you may object to the processing. This is the case if the processing is not necessary for the fulfillment of a contract with you, as will be presented by us in the subsequent description of the functions. When exercising such an objection, we ask you to state the reasons why we should not process your personal data as conducted. In the case of a justified objection, we will examine the situation and either cease or adjust the data processing or show you our compelling legitimate grounds for continuing the processing.
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Of course, you can object to the processing of your personal data for advertising and data analysis purposes at any time. You can contact us regarding your advertising objection at the address provided in section 2.
Legal or Contractual Regulations for Providing Personal Data / Necessity for Contract Conclusion / Consequences of Non-Disclosure / Deletion
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We would like to inform you that the provision of personal data is partially required by law. However, it may also be possible that a data subject must provide us with personal data in order to execute a contract. A failure to provide such data would mean that the contract could not be concluded. Our employees are happy to assist with case-specific questions.
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The data we process will be deleted or its processing restricted in accordance with Articles 17 and 18 of the GDPR. Unless explicitly stated otherwise in this privacy policy, the data we store will be deleted as soon as it is no longer required for its intended purpose, and there are no legal retention obligations preventing deletion. If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted. This means 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. According to legal regulations, the retention period is generally 10 years in accordance with §§ 147 Abs. 1 AO, 257 Abs. 1 Nr. 1 and 4, Abs. 4 HGB (books, records, management reports, booking documents, commercial books, and documents relevant for taxation, etc.) and 6 years according to § 257 Abs. 1 Nr. 2 and 3, Abs. 4 HGB (business correspondence).
Web Analytics
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Use of Google Analytics
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This website uses Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google Analytics uses so-called "cookies," text files that are stored on your computer and allow for an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transmitted to and stored on a Google server in the USA. If IP anonymization is activated on this website, however, your IP address will be shortened by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity, and to provide other services related to website use and internet use to the website operator.
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The IP address transmitted by your browser within the framework of Google Analytics will not be merged with other data from Google.
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You can prevent the storage of cookies by adjusting your browser software accordingly; however, we would like to point out that in this case, you may not be able to use all features of this website to their full extent. Additionally, you can prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) by Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
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This website uses Google Analytics with the extension "_anonymizeIp()". This ensures that IP addresses are processed in a shortened form, which excludes the possibility of personal identification. If data collected about you can be linked to an individual, this link will be immediately excluded, and personal data will thus be deleted promptly. The data we send and link to cookies, user identifiers (e.g., user ID), or advertising IDs will be automatically deleted after 14 months. Data whose retention period has been reached will be deleted automatically once a month.
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We use Google Analytics to analyze and regularly improve the use of our website. The statistics obtained allow us to improve our offerings and make them more interesting for you as a user. In exceptional cases where personal data is transferred to the USA, Google has submitted to the EU-U.S. Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis for the use of Google Analytics is Art. 6 Abs. 1 S. 1 lit. f of the GDPR.
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Information from the third party: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Terms of Service: https://www.google.com/analytics/terms/en.html, Privacy Overview: https://www.google.com/intl/en/analytics/learn/privacy.html, and the Privacy Policy: https://www.google.com/intl/en/policies/privacy.
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This website also uses Google Analytics for cross-device analysis of visitor flows, which is conducted via a User ID. You can disable the cross-device analysis of your usage in your customer account under "My Data", "Personal Data." Opt-out cookies prevent the future collection of your data when visiting this website. To prevent collection by Universal Analytics across devices, you must perform the opt-out on all systems used. Clicking here will set the opt-out cookie: {kickgdpr_ga_optout}Disable Google Analytics{/kickgdpr_ga_optout}
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Social Media / Integration of Google Maps
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Use of Social Media Plugins
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We currently use the following social media plugins: Facebook, Xing, LinkedIn. We use the so-called two-click solution. This means that when you visit our site, no personal data is initially passed on to the providers of the plugins. You can identify the provider of the plugin by the marking on the box with its initial letter or logo. We give you the option to communicate directly with the provider of the plugin via the button. Only if you click the marked field and thus activate it will the plugin provider receive the information that you have accessed the relevant website of our online offering. Additionally, the data mentioned in section 4 of this statement will be transmitted. In the case of Facebook and Xing, according to the respective providers, the IP address is anonymized immediately after collection in Germany. Therefore, by activating the plugin, personal data will be transmitted to the respective plugin provider and stored there (for US providers, in the USA). Since the plugin provider collects data primarily via cookies, we recommend that you delete all cookies in your browser's security settings before clicking on the greyed-out box.
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We have no influence over the data collected and the data processing operations, nor do we know the full extent of data collection, the purposes of processing, or the retention periods. We also have no information regarding the deletion of the data collected by the plugin provider.
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The plugin provider stores the data collected about you as usage profiles and uses them for advertising, market research, and/or needs-based design of its website. Such evaluation is carried out particularly (also for users who are not logged in) to display targeted advertising and to inform other users of the social network about your activities on our website. You have the right to object to the formation of these user profiles, and you must contact the respective plugin provider to exercise this right. Through the plugins, we offer you the opportunity to interact with social networks and other users, which allows us to improve our offerings and make them more interesting for you as a user. The legal basis for using the plugins is Art. 6 Abs. 1 S. 1 lit. f of the GDPR.
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The data transfer occurs regardless of whether you have an account with the plugin provider and are logged in there. If you are logged in to the plugin provider, the data collected by us will be directly associated with your account at the plugin provider. If you click the activated button, for example, to link the page, the plugin provider will also store this information in your user account and share it publicly with your contacts. We recommend that you regularly log out of social networks after using them, especially before activating the button, as this will help prevent linking to your profile at the plugin provider.
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Further information on the purpose and scope of data collection and its processing by the plugin provider can be found in the privacy policies of these providers listed below. There you will also find more information about your rights in this regard and settings options to protect your privacy.
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Addresses of the respective plugin providers and URLs with their privacy notices:
- Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA;
https://www.facebook.com/policy.php;
Further information on data collection:
https://www.facebook.com/help/186325668085084,
https://www.facebook.com/about/privacy/your-info-on-other#applications and
https://www.facebook.com/about/privacy/your-info#everyoneinfo.
Facebook has submitted to the EU-U.S. Privacy Shield,
https://www.privacyshield.gov/EU-US-Framework. - Xing AG, Gänsemarkt 43, 20354 Hamburg, DE;
https://www.xing.com/privacy. - LinkedIn Corporation, 2029 Stierlin Court, Mountain View, California 94043, USA;
https://www.linkedin.com/legal/privacy-policy.
LinkedIn has submitted to the EU-U.S. Privacy Shield,
https://www.privacyshield.gov/EU-US-Framework.
- Facebook Inc., 1601 S California Ave, Palo Alto, California 94304, USA;
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- Integration of Google Maps
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We use the Google Maps service on this website. This allows us to display interactive maps directly on the website and enables you to use the map feature conveniently.
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By visiting the website, Google receives the information that you have accessed the corresponding subpage of our website. Additionally, the data mentioned in section 4 of this statement will be transmitted. This occurs regardless of whether Google provides a user account through which you are logged in or whether there is no user account. If you are logged into Google, your data will be directly associated with your account. If you do not wish for this association with your Google profile, you must log out before activating the button. Google stores your data as usage profiles and uses them for advertising, market research, and/or needs-based design of its website. Such evaluation occurs particularly (even for users who are not logged in) to provide targeted advertising and to inform other users of the social network about your activities on our website. You have the right to object to the formation of these user profiles, and you must contact Google to exercise this right.
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Further information on the purpose and extent of data collection and its processing by the plugin provider can be found in the provider's privacy policy. There you will also find more information about your rights in this regard and settings options to protect your privacy: http://www.google.de/intl/de/policies/privacy. Google also processes your personal data in the USA and has submitted to the EU-U.S. Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.
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Plugins and Tools
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Google Web Fonts
This page uses so-called web fonts provided by Google for a uniform representation of fonts. When you access a page, your browser loads the required web fonts into its browser cache to correctly display texts and fonts. For this purpose, the browser you are using must establish a connection to Google’s servers. This allows Google to learn that our website has been accessed via your IP address. The use of Google Web Fonts is in the interest of a uniform and attractive presentation of our online offerings. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. If your browser does not support web fonts, a standard font from your computer will be used. For more information about Google Web Fonts, please visit https://developers.google.com/fonts/faq and Google’s privacy policy: https://www.google.com/policies/privacy/.