Direkt zum Inhalt

Data protection and data security

The protection of personal data is an important concern for us. Therefore, we conduct our activities in accordance with the applicable legal provisions on the protection of personal data. Data protection at Ärzte ohne Grenzen e. V.complies with the German and European standard for data protection. The employees of Ärzte ohne Grenzen e. V. have been sworn to secrecy. 

1. Preamble 

With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as "data") we process for which purposes and in which scope. The privacy statement applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online services"). 

The terms used are not gender-specific. 

Last Update: 12. December 2022 

2. Controller 

The responsible entity is Ärzte ohne Grenzen e.V. 
 
Please always send any blocking and deletion requests, as well as questions regarding donation advertising, to [email protected].  
 
 
Your contact person for questions regarding the handling of your personal data by Ärzte ohne Grenzen e.V. is our external data protection officer (according to §38 BDSG): 
 
Roman Maczkowsky 
m-privacy GmbH, IT security and data protection 
 
For all other questions regarding data protection, please write to e-mail: 
[email protected] 
 
Postal address:  
Ärzte ohne Grenzen e.V. 
Roman Maczkowsky 
- Data Protection Officer - 
Schwedenstraße 9 
D-13359 Berlin 
 
Tel: +49 (30) 700 130 - 0 
Fax: +49 (30) 700 130 340 

Impressum

3. Overview of processing operations 

The following table summarises the types of data processed, the purposes for which they are processed and the concerned data subjects. 

Categories of Processed Data 

  • Event Data (Facebook) ("Event data" is data that may be transmitted by us to Facebook, e.g., via Facebook Pixel (via apps or other means)) and relates to individuals or their actions. The data includes, for example, information about visits to websites, interactions with content, functions, app installations, purchases of products, etc. Event data is processed for the purpose of creating target groups for content and advertising information (Custom Audiences). Event data does not include actual content (such as comments posted), login information, or contact information (i.e., names, email addresses, and phone numbers). Event data is deleted by Facebook after a maximum of two years, and the target groups formed from it are deleted when our Facebook account is deleted.. 
  • Inventory data (e.g. names, addresses). 
  • Job applicant details (e.g. personal details, postal and contact addresses, the documents belonging to the application and the information contained therein, e.g. cover letter, CV, certificates, as well as other information provided with regard to a specific position or voluntarily by applicants concerning their person or qualifications). 
  • Content data (e.g. entries in online forms). 
  • Contact data (e.g. e-mail, telephone numbers). 
  • Meta/communication data. (e.g. device information, IP addresses). 
  • Usage data (e.g., websites visited, interest in content, access times). 
  • Social data (data that is subject to social secrecy and is processed, for example, by social insurance agencies, social welfare agencies, or pension authorities). 
  • Location data (information about the geographical position of a device or person) 
  • Contract data (e.g. subject of the contract, term, donation category). 
  • Payment Data (e.g. bank details, invoices, payment history) 

Categories of Data Subjects 

  • Employees (e.g. employees, applicants, former employees) 
  • Customers. 
  • Job applicants. 
  • Business and contractual partners. 
  • Prospective customers. 
  • Communication partner. 
  • Donors. 
  • Members. 
  • Users. 

Purposes of Processing 

  • A/B Tests. 
  • Provision of our online services and usability. 
  • Conversion tracking. (Measurement of the effectiveness of marketing measures) 
  • Job Application Process. (Establishment and possible subsequent implementation as well as possible subsequent termination of the employment relationship) 
  • Office and organisational procedures. 
  • Clicktracking  
  • Direct marketing. (e.g. by e-mail or postal mail) 
  • Feedback (e.g. collecting feedback via online form) 
  • Heatmaps (mouse movements on the part of the users, which are combined to form an overall image). 
  • Interest-based and behavioral marketing  
  • Contact requests and communication. 
  • Profiles with user-related information . 
  • Remarketing. 
  • Reach measurement (e.g. access statistics, recognition of returning visitors) 
  • Security measures 
  • Tracking (e.g., interest/behavior-based profiling, use of cookies) 
  • Polls and Questionnaires (e.g. surveys with input options, multiple choice questions). 
  • Provision of contractual services and customer support. 
  • Managing and responding to inquiries  
  • Targeting (determination of target groups relevant for marketing purposes or other output of content) 

4. Legal Bases for the Processing 

In the following, you will find an overview of the legal basis of the GDPR on which we base the processing of personal data. Please note that in addition to the provisions of the GDPR, national data protection provisions of your or our country of residence or domicile may apply. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration. 

  • Consent (Article 6 (1) (a) GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes. 
  • Performance of a contract and prior requests (Article 6 (1) (b) GDPR) - 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. 
  • Legitimate Interests (Article 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. 
  • Job application process as a pre-contractual or contractual relationship (Article 6 (1)(b) GDPR) - If special categories of personal data within the meaning of Article 9 (1) GDPR (e.g. health data, such as severely handicapped status or ethnic origin) are requested from applicants within the framework of the application procedure, so that the responsible person or the person concerned can carry out the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law, their processing shall be carried out in accordance with Article 9 (2)(b) GDPR , in the case of the protection of vital interests of applicants or other persons on the basis of Article 9 (2)(c) GDPR  or for the purposes of preventive health care or occupational medicine, for the assessment of the employee's ability to work, for medical diagnostics, care or treatment in the health or social sector or for the administration of systems and services in the health or social sector in accordance with Article 9 (2)(d) GDPR. In the case of a communication of special categories of data based on voluntary consent, their processing is carried out on the basis of Article 9 (2)(a) GDPR. 

National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national regulations apply to data protection in Germany. This includes in particular the Law on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special provisions on the right to access, the right to erase, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated individual decision-making, including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, execution or termination of employment relationships as well as the consent of employees. Furthermore, data protection laws of the individual federal states may apply. 

5. Security Precautions 

We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk. 

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, transmission, securing and separation of the data. In addition, we have established procedures to ensure that data subjects' rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default. 

Masking of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not necessary, the IP address is shortened (also referred to as "IP masking"). In this process, the last two digits or the last part of the IP address after a full stop are removed or replaced by wildcards. The masking of the IP address is intended to prevent the identification of a person by means of their IP address or to make such identification significantly more difficult. 

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

6. Transmission and Disclosure of Personal Data 

In the context of our processing of personal data, it may happen that the data is transferred to other places, companies or persons or that it is disclosed to them. Recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are embedded in a website. In such a case, the legal requirements will be respected and in particular corresponding contracts or agreements, which serve the protection of your data, will be concluded with the recipients of your data. 

Data Transfer within the Organization: We may transfer or otherwise provide access to personal information to other locations within our organization. Insofar as this disclosure is for administrative purposes, the disclosure of the data is based on our legitimate business and economic interests or otherwise, if it is necessary to fulfill our contractual obligations or if the consent of those concerned or otherwise a legal permission is present. 

7. 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 the processing takes place in the context of the use of third party services or disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements.  

Subject to express consent or transfer required by contract or law, we process or have processed the data only in third countries with a recognised level of data protection, on the basis of special guarantees, such as a contractual obligation through so-called standard protection clauses of the EU Commission or if certifications or binding internal data protection regulations justify the processing (Article 44 to 49 GDPR, information page of the EU Commission: Informationsseite der EU-Kommission). 

8. Use of Cookies 

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user's computer. The primary purpose of a cookie is to store information about a user during or after his visit within an online offer. Stored information may include, for example, language settings on a website, login status, a shopping cart, or where a video was watched. We also include in the term cookies other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also known as "user IDs"). 

You can consent to the use of cookies that are not necessary by clicking on the "Accept All" button or decide otherwise by clicking on "Decline". The consent includes all cookies preselected or selected by you. You can access these settings at any time and also subsequently deselect cookies at any time (in the privacy notices and in the footer of our website) 

In detail, the following cookie types and functions are distinguished: 

  • Temporary cookies (also known as "session cookies"): Temporary cookies are deleted at the latest after a user has left an online service and closed his or her end device (i.e. browser or mobile application).  
  • Permanent cookies: Permanent cookies remain stored even after the terminal device is closed. For example, the login status can be saved, or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., as part of obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years. 
  • First-party cookies: First-party cookies are set by us. 
  • Third-party cookies (also third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information. 
  • Necessary (also essential or absolutely necessary) cookies: Cookies may be absolutely necessary for the operation of a website (e.g. to store logins or other user input or for security reasons). 
  • Statistical, marketing and personalization cookies: Furthermore, cookies are generally also used in the context of range measurement and when a user's interests or behavior (e.g. viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This procedure is also referred to as "tracking", i.e. tracking the potential interests of users. Insofar as we use cookies or "tracking" technologies, we will inform you separately in our data protection declaration or in the context of obtaining consent. 

Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations. 

Storage period: If we do not provide you with explicit information about the storage period of permanent cookies (e.g. in the context of a so-called cookie opt-in), please assume that the storage period can be up to two years. 

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent given or to object to the processing of your data by cookie technologies (collectively referred to as "opt-out"). You can initially declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (whereby this may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info  and https://www.youronlinechoices.com/ . In addition, you can obtain further instructions on how to object in the context of the information on the service providers and cookies used. 

Processing Cookie Data on the Basis of Consent: We use a cookie management solution in which users' consent to the use of cookies, or the procedures and providers mentioned in the cookie management solution, can be obtained, managed and revoked by the users. The declaration of consent is stored so that it does not have to be retrieved again and the consent can be proven in accordance with the legal obligation. Storage can take place server-sided and/or in a cookie (so-called opt-out cookie or with the aid of comparable technologies) in order to be able to assign the consent to a user or and/or his/her device. Subject to individual details of the providers of cookie management services, the following information applies: The duration of the storage of the consent can be up to two years. In this case, a pseudonymous user identifier is formed and stored with the date/time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and used end device. 

  • Types of data processed: Usage data (e.g. web pages visited, 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). 
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f DSGVO). 

Services used and service providers: 

9. Performing tasks in accordance with statutes or rules of procedure 

We process the data of our members, donors, prospects, business partners or other persons (collectively, " data subjects ") when we have a membership or other business relationship with them and perform our functions and are recipients of benefits and benefits. Otherwise, we process the data of data subjects on the basis of our legitimate interests, e.g. when it concerns administrative tasks or public relations. 

The data processed, the type, scope and purpose and the necessity of their processing, are determined by the underlying membership or contractual relationship, from which the necessity of any data information arises (otherwise we refer to necessary data). 

We delete data that is no longer required for the performance of our statutory and business purposes. This is determined according to the respective tasks and contractual relationships. We retain the data for as long as it may be relevant for the purpose of conducting business and with regard to any warranty or liability obligations on the basis of our legitimate interest in their regulation. The necessity of storing the data is checked regularly; otherwise the statutory storage obligations apply. 

  • Processed data types: Inventory data (e.g. names, addresses); Payment Data (e.g. bank details, invoices, payment history); Contact data (e.g. e-mail, telephone numbers); Contract data (e.g. contract object, duration, customer category). 
  • Data subjects: Users (e.g. website visitors, users of online services); Members; Business and contractual partners. 
  • Purposes of Processing: Provision of contractual services and customer support; Contact requests and communication; Managing and responding to inquiries. 
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR). 

10. Payment Service Providers 

Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other service providers for this purpose in addition to banks and credit institutions (collectively referred to as "payment service providers"). 

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e. we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the terms and conditions and data protection information of the payment service providers. 

The terms and conditions and data protection information of the respective payment service providers apply to the payment transactions and can be accessed within the respective websites or transaction applications. We also refer to these for further information and the assertion of revocation, information and other data subject rights. 

  • Processed data types: Inventory data (e.g. names, addresses); Payment Data (e.g. bank details, invoices, payment history); Contract data (e.g. contract object, duration, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses). 
  • Data subjects: Customers; Prospective customers. 
  • Purposes of Processing: Provision of contractual services and customer support. 
  • Legal Basis: Performance of a contract and prior requests (Article 6 (1) (b) GDPR). 

Further information on processing methods, procedures and services used: 

11. Provision of online services and web hosting 

In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services. 

The data processed as part of the provision of the hosting offer may include all information relating to the users of our online offer, which is generated as part of the use and communication. This regularly includes the IP address, which is necessary to be able to deliver the content of online offers to browsers and all entries made within our online offer or from websites. 

  • E-mail Sending and Hosting: The web hosting services we use also include sending, receiving and storing e-mails. For these purposes, the addresses of the recipients and senders, as well as other information relating to the sending of e-mails (e.g. the providers involved) and the contents of the respective e-mails are processed. The above data may also be processed for SPAM detection purposes. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted during transport, but not on the servers from which they are sent and received (unless a so-called end-to-end encryption method is used). We can therefore accept no responsibility for the transmission path of e-mails between the sender and reception on our server 
  • Collection of Access Data and Log Files: The access to our online services is logged in the form of so-called "server log files". Server log files may include the address and name of the web pages and files accessed, the date and time of access, data volumes transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a general rule, IP addresses and the requesting provider. 

The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the stability and optimal load balancing of the servers 

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Content data (e.g. text input, photographs, videos). 
  • Data subjects: Users (e.g. website visitors, users of online services). 
  • Purposes of Processing: Provision of our online services and usability; Information technology infrastructure (Operation and provision of information systems and technical devices, such as computers, servers, etc.).); Security measures. 
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). 

12. Contact  

When contacting us (e.g. via contact form, e-mail, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures. 

  • Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses). 
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.). 
  • Purposes of Processing: Contact requests and communication; Managing and responding to inquiries; Feedback (e.g. collecting feedback via online form); Provision of our online services and usability. 
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). 

13. Video Conferences, Online Meetings, Webinars and Screen-Sharing 

We use platforms and applications of other providers (hereinafter referred to as "Conference Platforms") for the purpose of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter collectively referred to as "Conference"). When using the Conference Platforms and their services, we comply with the legal requirements.  

In this context, data of the communication participants is processed and stored on the servers of the third-party providers, insofar as these are part of communication processes with us. This data may include, in particular, registration and contact data, visual and vocal contributions as well as entries in chats and shared screen contents. 

If users are referred to the third-party providers or their software or platforms in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata for security, service optimization or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers. 

Notes on legal bases: Insofar as, in addition to the Conference Platforms, we also process users' data and ask users for their consent to use contents from the Conferences or certain functions (e.g. consent to a recording of Conferences), the legal basis of the processing is this consent.  Furthermore, our processing may be necessary for the fulfillment of our contractual obligations (e.g. in participant lists, in the case of reprocessing of Conference results, etc.). Otherwise, user data is processed on the basis of our legitimate interests in efficient and secure communication with our communication partners. 

  • Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses). 
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.); Users (e.g. website visitors, users of online services); Persons depicted. 
  • Purposes of Processing: Provision of contractual services and customer support; Contact requests and communication; Office and organisational procedures. 
  • Legal Basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f DSGVO) 

Further information on processing methods, procedures and services used: 

14. Music and Podcasts 

We use  hosting and analysis services of service providers to offer our audio content for listening to or downloading and to obtain statistical information on the request of the audio content. 

  • Processed data types: Usage data (e.g. websites visited, 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: Web Analytics (e.g. access statistics, recognition of returning visitors); Conversion tracking (Measurement of the effectiveness of marketing activities); Profiles with user-related information (Creating user profiles); Provision of our online services and usability. 

Further information on processing methods, procedures and services used: 

15. Job Application Process 

The protection and confidential handling of your personal data during the application process is a high priority for us. In the following, we explain what data we collect during the application process and how it is further processed.  

Designation of the processing activity 

Collection and processing of personal data in connection with application and personnel selection procedures. 

Purpose and legal basis of the processing of personal data  

Your data is required for the personnel selection procedure. Applicant management software is used to support this, but decisions are not based exclusively on automated bases. Specifically, we first store the data provided to us. On the basis of this information, we check whether the further steps of the selection process are worth considering. Depending on the position, the application steps look different. If you are fundamentally suitable, we collect further personal data that is essential for the selection decision. If you are considered for employment, we will inform you of this further information to be collected.  

Your personal data will be processed on the following legal basis:   

  • Art. 88 (1) of the General Data Protection Regulation in conjunction with. § Section 26 of the Federal Data Protection Act (data processing for purposes of the employment relationship).  
  • Art. 6 para. 1 lit. a) General Data Protection Regulation (voluntary consent for optional inclusion in the application pool).  

Categories of data collected 

We collect different categories of data depending on the job advertisement. In all cases, we collect the following personal data that is processed:  

  • Salutation  
  • First and last name 
  • Contact data (postal as well as registration address, phone no., e-mail address)  
  • Current professional status  

In addition, further personal data is collected for the various job advertisements within the application process. These vary depending on the area of the job posting, i.e. divided into applications as a face-to-face fundraiser, as an employee in the German headquarters or in international projects: 

Face-to-Face Fundraiser*in:  

  • Desired call name (optional) 
  • Driver's license status 
  • Date and place of birth 
  • Address of residence and postal address (if different from general) 
  • Nationality 
  • If applicable, additional long-term residences in the last 5 years 
  • Food allergies / intolerances / preferences 
  • Clothing size T-shirt / jacket for face-to-face wear 
  • If applicable, bank account details (if entitled to work shop allowance) 

German headquarters:  

  • School and professional background incl. qualifications and work references, extra-company training and further education, studies  
  • Letter of motivation 
  • Level of language skills 
  • Technical knowledge relevant to the position 
  • If applicable, matriculation certificates and expected duration of studies  
  • If applicable, proof of mandatory internship  
  • If applicable, work permit in Germany  
  • Equality status / severely disabled status (optional) 
  • Nationality (optional) 
  • Date of birth (optional) 

International projects:  

  • School and professional career incl. qualifications and work references, external training and further education, studies  
  • Technical skills (skill list) 
  • Details of three reference contacts (who agree to the data being passed on by you)  
  • Level of language skills 
  • Letter of motivation 
  • Time availability for cooperation 
  • Nationality (optional) 
  • Date of birth (optional) 

Your data will be passed on to the extent necessary to carry out the personnel selection procedure to:  

  • Internal departments or persons, insofar as they are to be involved in the recruitment process 
  • Staff representatives (works council), insofar as corresponding co-determination rights exist. 
  • The company BITE GmbH, which has been commissioned with the operation and maintenance of the application management software within the framework of order processing in accordance with Art. 28 DSGVO. 
  • In addition, for applications as face-to-face fundraisers, the following applies: external consultant as trainer for the face-to-face workshop. 
  • Additionally for applications in international projects: applications that have been positively assessed in the first screening will be forwarded to colleagues from other European MSF sections for further assessment of professional qualifications. 
  • Additionally for applications in international projects: If necessary, the service provider Pipplet SAS will be used for a language test. For this purpose, we obtain the consent for the transfer of data from the individual applicant* separately in advance. 

Transfer of personal data to a third country   
(outside the European Union or the European Economic Area)  

Your information will not be transferred to a third country or any other international organization.   

Duration of storage of personal data   

The following regulations apply to the duration of storage: 

  • We store your personal data obtained during the personnel selection process for at least six months.  
  • In the event of an unsuccessful application or its withdrawal, we will likewise destroy or delete the data you have submitted after six months following rejection. The retention or storage of data within the aforementioned periods is necessary in the event of any legal action.  
  • If you are hired, you will be informed separately about the regulations that will then apply to the handling of your personnel data.  

In addition, there is the possibility of inclusion in an application pool both for work in the international projects and at the German headquarters. For this purpose, we obtain separate consent for inclusion.  Applicants are informed that their consent to inclusion in the application pool is voluntary, has no influence on the current application process and that they can revoke their consent at any time for the future. 

Processing of special categories of data  

Insofar as special categories of personal data within the meaning of Art. 9 (1) DSGVO (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants in the course of the application procedure in order for the controller or the data subject to exercise the rights accruing to him or her under labor law and social security and social protection law and to comply with his or her obligations in this regard, their processing is carried out in accordance with Art. 9(2)(b) of the GDPR, in case of protection of vital interests of the applicants or other persons pursuant to Art. 9(2)(c) of the GDPR, or for the purposes of preventive health care or occupational medicine, for the assessment of the employee's fitness for work, for medical diagnostics, for health or social care or treatment, or for the management of health or social care systems and services pursuant to Art. 9(2)(h) of the GDPR. In case of notification of the special categories of data based on voluntary consent, their processing is based on Art. 9 (2) lit. a DSGVO. 

16. Newsletter and Electronic Communications 

We send newsletters, e-mails and other electronic communications (hereinafter referred to as "newsletters") only with the consent of the recipient or a legal permission. Insofar as the contents of the newsletter are specifically described within the framework of registration, they are decisive for the consent of the user. Otherwise, our newsletters contain information about our services and us. 

In order to subscribe to our newsletters, it is generally sufficient to enter your e-mail address. We may, however, ask you to provide a name for the purpose of contacting you personally in the newsletter or to provide further information if this is required for the purposes of the newsletter. 

Double opt-in procedure: The registration to our newsletter takes place in general 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 no one can register with external e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes storing the login and confirmation times as well as the IP address. Likewise the changes of your data stored with the dispatch service provider are logged. 

Deletion and restriction of processing: We may store the unsubscribed email addresses for up to three years based on our legitimate interests before deleting them to provide evidence of prior consent. The processing of these data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of a consent is confirmed at the same time. In the case of an obligation to permanently observe an objection, we reserve the right to store the e-mail address solely for this purpose in a blocklist. 

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system. 

Notes on legal basis: The newsletter is sent on the basis of the recipients' consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of stock donor advertising. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to prove that it was carried out in accordance with the law. 

Contents: I Information about our work in MSF project countries and contexts worldwide. 

Measurement of opening rates and click rates: The newsletters contain a so-called "web-beacon", i.e. a pixel-sized file, which is retrieved from our server when the newsletter is opened or, if we use a mailing service provider, from its server. Within the scope of this retrieval, technical information such as information about the browser and your system, as well as your IP address and time of retrieval are first collected. This information is used for the technical improvement of our newsletter on the basis of technical data or target groups and their reading behaviour on the basis of their retrieval points (which can be determined with the help of the IP address) or access times.  

This analysis also includes determining whether newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until the profiles are deleted. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.The measurement of opening rates and click rates as well as the storage of the measurement results in the profiles of the users and their further processing are based on the consent of the users. A separate objection to the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled or objected to. In this case, the stored profile information will be deleted;  

  • Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Meta/communication data (e.g. device information, IP addresses); Usage data (e.g. websites visited, interest in content, access times). 
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.). 
  • Purposes of Processing: Direct marketing (e.g. by e-mail or postal). 
  • Legal Basis: Consent (Article 6 (1) (a) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR). 
  • Opt-Out: You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the contact options listed above, preferably e-mail.  

Services used and service providers: 

17. Commercial communication by E-Mail, Postal Mail, Fax or Telephone 

We process personal data for the purposes of promotional communication, which may be carried out via various channels, such as e-mail, telephone, post or fax, in accordance with the legal requirements. 

The recipients have the right to withdraw their consent at any time or to object to the advertising communication at any time. 

After revocation or objection, we store the data required to prove the past authorization to contact or send up to three years from the end of the year of revocation or objection on the basis of our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Based on the legitimate interest to permanently observe the revocation, respectively objection of the users, we further store the data necessary to avoid a renewed contact (e.g. depending on the communication channel, the e-mail address, telephone number, name). 

  • Processed data types: Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers). 
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.). 
  • Purposes of Processing: Direct marketing (e.g. by e-mail or postal). 
  • Legal Basis: Consent (Article 6 (1) (a) GDPR); Legitimate Interests (Article 6 (1) (f) GDPR). 

I have never donated to Ärzte ohne Grenzen and yet I have been contacted? Why? 

We depend on donations for our work. For this purpose, we also write to people who have never donated to us before in order to draw attention to our work. For this purpose we rent addresses for one-time writing from address agencies. If you would like to know from which address agency your address originates, please contact our donation service. By email: [email protected] or by phone: 030/ 700 130 - 130. 

If you do not wish to receive any more advertising letters, you have the option of entering your address in the so-called Robinson list: https://www.ichhabediewahl.de

Important: This entry must be renewed by you every five years, otherwise the data would become outdated due to relocations or deaths. Only you can initiate this entry yourself. Persons who wish to be entered in the Robinson list can also request the documents free of charge by telephone or postcard from: 

DDV Deutscher Dialogmarketing Verband e. V. 
Hahnstr. 70 
60528 Frankfurt (M) 
Telephone: 069 - 401 276 500 
Fax: 069 - 401 276 599 
[email protected] 
https://www.ddv.de 

18. Communication via Messenger  

We use messengers for communication purposes and therefore ask you to observe the following information on the functionality of the messengers, on encryption, on the use of the metadata of the communication and on your objection options. 

You can also contact us by alternative means, e.g. via telephone or e-mail. Please use the contact options provided to you or the contact options provided within our online offer. 

In the case of end-to-end encryption of content (i.e., the content of your message and attachments), we point out that the communication content (i.e., the content of the message and attached images) is encrypted from end to end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messenger with encryption enabled to ensure that the message content is encrypted 

However, we additionally point out to our communication partners that the messenger providers cannot view the content, but they can find out that and when communication partners communicate with us as well as technical information about the device used by the communication partners and, depending on the settings of your device, also location information (so-called metadata) is processed. 

Notes on legal basis: If we ask communication partners for permission before communicating with you via Messenger, the legal basis of our processing of your data is their consent. Otherwise, if we do not ask for consent and you contact us on your own initiative, for example, we use Messenger in relation to our contractual partners as well as in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and meeting the needs of our communication partners in communication via Messenger. Furthermore, we would like to point out that we do not transmit the contact data communicated to us to the messengers for the first time without your consent. 

Revocation, objection and deletion: You can revoke any consent given at any time and object to communication with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (i.e., e.g., as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise as soon as we can assume to have answered any information provided by the communication partners, if no reference back to a previous conversation is to be expected and the deletion does not conflict with any legal retention obligations. 

Reservation of reference to other communication channels: Finally, we would like to point out that, for reasons of your security, we reserve the right not to answer inquiries via Messenger. This is the case if, for example, contractual internals require special confidentiality or an answer via Messenger does not meet formal requirements. In such cases, we will refer you to more adequate communication channels. 

  • Types of data processed: contact data (e.g. e-mail, telephone numbers), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), content data (e.g. entries in online forms). 
  • Data subjects: Communication partners. 
  • Purposes of processing: contact requests and communication, direct marketing (e.g. by e-mail or post). 
  • Legal basis: consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO). 

Services used and service providers: 

  • Signal: Signal Messenger with end-to-end encryption; Service provider: Privacy Signal Messenger, LLC 650 Castro Street, Suite 120-223 Mountain View, CA 94041, USA; website: https://signal.org/de; privacy policy: https://signal.org/legal/. 

     

19. Petition

We use third-party providers to carry out petitions. To participate in a petition, it is generally sufficient for you to provide your e-mail address and your name. However, we may ask you to provide further information with your consent or if this is necessary for the purposes of the petition.

Participation takes place with your consent by entering your data (name, e-mail address). After signing the petition electronically, you will receive a one-off confirmation by e-mail.

Storage of the data: Participation in a petition is logged in order to be able to prove the registration process in accordance with the requirements for a petition. Furthermore, meta-information such as the time of registration and confirmation as well as the IP address are logged in accordance with the use of our other online services (see section 11 of this privacy policy).

Deletion and restriction of processing:

Your personal data will be deleted three months after the petition is closed with our petition service provider.

We may store unsubscribed email addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for erasure is possible at any time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a block list solely for this purpose.

The registration process is logged on the basis of our legitimate interests for the purpose of proving that it has been carried out properly. If we commission a service provider to send emails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Third-party cookies: Our petition service providers use cookies to personalize content, provide social media features and analyze website traffic. They also share information about your website usage with our marketing and analytics partners, and this sharing may be considered a "sale" or "sharing/processing" of personal data for targeted online advertising under applicable laws. By selecting "Accept all cookies" on the petition page, you consent to the use of cookies. To refuse the use of cookies or to change your cookie settings, please select the appropriate button in the cookie banner on our petition service provider page. For more information about the cookies used by our third-party service providers, please visit their cookie statement page.

  • Processed data types: Inventory data (e.g. names), Contact data (e.g. e-mail), Meta/communication data (e.g. device information, IP addresses), Usage data (e.g. websites visited, interest in content, access times)

  • Data subjects: Communication partner

  • Purposes of processing: Electronic signing of a petition

  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR)

Possibility of objection (opt-out): You can cancel your participation in a petition at any time with effect for the future, i.e. revoke your consent in this regard. You will find a link to revoke your consent in the confirmation email you received after signing or use one of the contact options listed above, preferably email. Please note that it may not be possible to withdraw your consent for data that has already been transmitted to the recipient of the petition as a result of your signature. 

Services used and service providers:

NationBuilder: Content management and customer relationship management software; Service provider: NationBuilder, 1-213-992-4809 -PO Box 811428, Los Angeles, CA 90081, USA; Website: https://nationbuilder.com; Privacy Policy: https://nationbuilder.com/privacy, Cookie Policy: https://nationbuilder.com/cookie_declaration

 

20. Surveys and Questionnaires 

We conduct surveys and interviews to gather information for the survey purpose communicated in each case. The surveys and questionnaires ("surveys") carried out by us are evaluated anonymously. Personal data is only processed insofar as this is necessary for the provision and technical execution of the survey (e.g. processing the IP address to display the survey in the user's browser or to enable a resumption of the survey with the aid of a cookie). 

Notes on legal bases: If we ask participants for consent to process their data, this is the legal basis for the processing; otherwise, the processing of participants' data is based on our legitimate interests in conducting an objective survey. 

  • Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses). 
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.); Participants. 
  • Purposes of Processing: Feedback (e.g. collecting feedback via online form). 
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). 

Further information on processing methods, procedures and services used: 

21. Web Analysis, Monitoring and Optimization 

Web analysis is used to evaluate the visitor traffic on our website and may include the behaviour, interests or demographic information of users, such as age or gender, as pseudonymous values. With the help of web analysis we can e.g. recognize, at which time our online services or their functions or contents are most frequently used or requested for repeatedly, as well as which areas require optimization. 

In addition to web analysis, we can also use test procedures, e.g. to test and optimize different versions of our online services or their components. 

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

Unless otherwise stated below, profiles, that is data summarized for a usage process or user, may be created for these purposes and stored in a browser or terminal device (so-called "cookies") or similar processes may be used for the same purpose. The information collected includes, in particular, websites visited and elements used there as well as technical information such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data or profiles to us or to the providers of the services we use, these may also be processed, depending on the provider. 

The IP addresses of the users are also stored. However, we use any existing IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect the user. In general, within the framework of web analysis, A/B testing and optimisation, no user data (such as e-mail addresses or names) is stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes. 

Notes on legal bases: If we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy. 

  • Processed data types: Usage data (e.g. websites visited, 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: Remarketing; Custom Audiences (Selection of relevant target groups for marketing purposes or other output of content); Web Analytics (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (Creating user profiles); Targeting (e.g. profiling based on interests and behaviour, use of cookies); Provision of our online services and usability; Clicktracking; A/B Tests; Feedback (e.g. collecting feedback via online form); Heatmaps ("Heatmaps" are mouse movements of the users, which are combined to an overall picture.); Polls and Questionnaires (e.g. surveys with input options, multiple choice questions); Marketing. 
  • Security measures: IP Masking (Pseudonymization of the IP address). 
  • Legal Basis: Consent (Article 6 (1) (a) GDPR). 

Further information on processing methods, procedures and services used: 

  • Hotjar: Software for the analysis and optimization of online services based on feedback functions as well as pseudonymously performed measurements and analyses of user behavior, which may include in particular A/B tests (measurement of the popularity and user-friendliness of different content and functions), measurement of click paths and interaction with content and functions of the online service (as so-called heat maps and recordings); Service provider: Hotjar Ltd., 3 Lyons Range, 20 Bisazza Street, Sliema SLM 1640, Malta; Website: https://www.hotjar.com; Privacy Policy:  https://www.hotjar.com/legal/policies/privacy; Retention period: The cookies that Hotjar uses have a different "lifetime"; some last up to 365 days, some only last during the current visit; cookie policy: https://www.hotjar.com/legal/policies/cookie-information; Opt-Out: https://www.hotjar.com/legal/compliance/opt-out
  • Matomo Cloud: Hosting of the web analytics and reach measurement software Matomo; Service provider: InnoCraft Ltd, 7 Waterloo Quay PO625, 6140 Wellington, New Zealand; Website: https://matomo.org/matomo-cloud/; Privacy Policy: https://matomo.org/matomo-cloud-privacy-policy/; Data Processing Agreement: https://matomo.org/matomo-cloud-dpa/
  • Matomo: Matomo is software that is used for the purposes of web analysis and reach measurement. As part of the use of Matomo, cookies are generated and stored on the user's terminal device. User data collected through the use of Matomo is processed only by us and is not shared with third parties. The cookies are stored for a maximum period of 13 months: https://matomo.org/faq/general/faq_146/; Retention period: The cookies have a maximum storage period of 13 months.

22. Online Marketing 

We process personal data for the purposes of online marketing, which may include in particular the marketing of advertising space or the display of advertising and other content (collectively referred to as "Content") based on the potential interests of users and the measurement of their effectiveness.  

For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedure in which the relevant user information for the display of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, communication partners and technical information such as the browser used, computer system used and information on usage times and used functions. If users have consented to the collection of their sideline data, these can also be processed. 

The IP addresses of the users are also stored. However, we use provided IP masking procedures (i.e. pseudonymisation by shortening the IP address) to ensure the protection of the user's by using a pseudonym. In general, within the framework of the online marketing process, no clear user data (such as e-mail addresses or names) is secured, but pseudonyms. This means that we, as well as the providers of online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles. 

The information in the profiles is usually stored in the cookies or similar memorizing procedures. These cookies can later, generally also on other websites that use the same online marketing technology, be read and analyzed for purposes of content display, as well as supplemented with other data and stored on the server of the online marketing technology provider. 

Exceptionally, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing technology we use and the network links the profiles of the users in the aforementioned data. Please note that users may enter into additional agreements with the social network providers or other service providers, e.g. by consenting as part of a registration process. 

As a matter of principle, we only gain access to summarised information about the performance of our advertisements. However, within the framework of so-called conversion measurement, we can check which of our online marketing processes have led to a so-called conversion, i.e. to the conclusion of a contract with us. The conversion measurement is used alone for the performance analysis of our marketing activities. 

Unless otherwise stated, we kindly ask you to consider that cookies used will be stored for a period of two years. 

Notes on legal bases: If we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy. 

  • Processed data types: Usage data (e.g. websites visited, 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: Web Analytics (e.g. access statistics, recognition of returning visitors); Targeting (e.g. profiling based on interests and behaviour, use of cookies); Marketing; Profiles with user-related information (Creating user profiles); Conversion tracking (Measurement of the effectiveness of marketing activities). 
  • Security measures: IP Masking (Pseudonymization of the IP address). 
  • Legal Basis: Consent (Article 6 (1) (a) GDPR). 
  • Opt-Out: We refer to the privacy policies of the respective service providers and the possibilities for objection (so-called "opt-out"). If no explicit opt-out option has been specified, it is possible to deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered collectively for each area:
    a) Europe: https://www.youronlinechoices.eu.
    b) Canada: https://www.youradchoices.ca/choices.
    c) USA: https://www.aboutads.info/choices.
    d) Cross-regional: https://optout.aboutads.info. 

Further information on processing methods, procedures and services used: 

  • Google Ads and Conversion Tracking: We use the Google "Ads" online marketing method to place ads on the Google advertising network (e.g., in search results, videos, websites, etc.) so that they are displayed to users who have an alleged interest in the ads. We also measure the conversion of the ads (so called "Konversion"). However, we only know the anonymous total number of users who clicked on our ad and were redirected to a page tagged with a conversion tracking tag. However, we ourselves do not receive any information that can be used to identify users; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy 
  • Microsoft Advertising: Remarketing / Conversion measurement; Service provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland; Website: https://about.ads.microsoft.com/de-de; Privacy Policy: https://privacy.microsoft.com/de-de/privacystatement; Opt-Out: https://choice.microsoft.com/de-DE/opt-out 
  • Matomo Cloud: Hosting of the web analytics and reach measurement software Matomo; Service provider: InnoCraft Ltd, 7 Waterloo Quay PO625, 6140 Wellington, New Zealand; Website: https://matomo.org/matomo-cloud/; Privacy Policy: https://matomo.org/matomo-cloud-privacy-policy/; Data Processing Agreement: https://matomo.org/matomo-cloud-dpa/
  • Matomo: Matomo is software that is used for the purposes of web analysis and reach measurement. As part of the use of Matomo, cookies are generated and stored on the user's terminal device. User data collected through the use of Matomo is processed only by us and is not shared with third parties. The cookies are stored for a maximum period of 13 months: https://matomo.org/faq/general/faq_146/; Retention period: The cookies have a maximum storage period of 13 months. 

23. Profiles in Social Networks (Social Media) 

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

We would like to point out that user data may be processed outside the European Union. This may entail risks for users, e.g. by making it more difficult to enforce users' rights. 

In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the associated interests of users. The user profiles can then be used, for example, to place advertisements within and outside the networks which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user's computer, in which the user's usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective networks or will become members later on). 

For a detailed description of the respective processing operations and the opt-out options, please refer to the respective data protection declarations and information provided by the providers of the respective networks. 

Also in the case of requests for information and the exercise of rights of data subjects, we point out that these can be most effectively pursued with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us. 

Facebook: We are jointly responsible with Meta Platforms Ireland Limited for collecting (but not further processing) data from visitors to our Facebook page (known as a "Fan Page"). This data includes information about the types of content users view or interact with, or the actions they take (see under "Things You and Others Do and Provide" in the Facebook Data Policy Statement: https://www.facebook.com/policy ), as well as information about the devices users use (e.g., IP addresses, operating system, browser type, language settings, cookie data; see under "Device Information" in the Facebook Data Policy Statement: https://www.facebook.com/policy ). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services, called "Page Insights," to Page operators to provide them with insights into how people interact with their Pages and with content associated with them. We have entered into a special agreement with Facebook ("Page Insights Information," https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the data subject rights (i.e., users can, for example, direct information or deletion requests to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority), are not restricted by the agreements with Facebook. Further information can be found in the "Information on Page Insights"; https://www.facebook.com/legal/terms/information_about_page_insights_data

  • Processed data types: Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, 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 Basis: Legitimate Interests (Article 6 (1) (f) GDPR). 

Further information on processing methods, procedures and services used: 

24. Plugins and embedded functions and content 

Within our online services, we integrate functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may, for example, be graphics, videos or city maps (hereinafter uniformly referred to as "Content"). 

The integration always presupposes that the third-party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers use the IP address only for the distribution of the contents. Third parties may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include technical information about the browser and operating system, referring websites, visit times and other information about the use of our website, as well as may be linked to such information from other sources. 

Notes on legal bases: If we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, users' data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy. 

Integration of third-party software, scripts or frameworks (e.g. jQuery): We integrate software into our online offering that we retrieve from servers of other providers (e.g., function libraries that we use for the purpose of displaying or making our online offering user-friendly). In doing so, the respective providers collect the IP address of the user and may process this for the purpose of transmitting the software to the user's browser and for security purposes, as well as for the evaluation and optimization of their offer. 

Facebook plugins and content: We are jointly responsible with Meta Platforms Ireland Limited for collecting or receiving in the course of a transmission (but not further processing) "Event Data" that Facebook collects or receives in the course of a transmission by means of the Facebook social plugins (and content embedding features) running on our Online Offer for the purposes of: a) displaying content as well as advertising information that corresponds to users' presumed interests; b) delivering commercial and transactional messages (e.g. e.g., targeting users via Facebook Messenger); c) improving ad delivery and personalization of features and content (e.g., improving the detection of which content or advertising information presumably matches users' interests). We have entered into a special agreement with Facebook ("Addendum for Responsible Parties", https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill data subject rights (i.e., users can, for example, provide information or make deletion requests directly to Facebook). Note: When Facebook provides us with metrics, analytics and reports (which are aggregated, i.e., do not receive information about individual users and are anonymous to us), this processing is not carried out under shared responsibility, but rather on the basis of a contract processing agreement ("Data Processing Terms ", https://www.facebook.com/legal/terms/dataprocessing), the "Data Security Terms" (https://www.facebook.com/legal/terms/data_security_terms) and, with respect to processing in the U.S., on the basis of standard contractual clauses ("Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority), are not restricted by the agreements with Facebook. 

Instagram plugins and content: We are jointly responsible with Facebook Ireland Ltd. for the collection or receipt in the course of a transmission (but not the further processing) of "event data" that Facebook collects or receives in the course of a transmission by means of the Facebook social plugins (and content embedding features) running on our Online Offer for the following purposes: a) display of content as well as advertising information corresponding to the presumed interests of users; b) delivery of commercial and transactional messages (e.g. e.g., targeting users via Facebook Messenger); c) improving ad delivery and personalization of features and content (e.g., improving the detection of which content or advertising information presumably matches users' interests). We have entered into a special agreement with Facebook ("Addendum for Responsible Parties", https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill data subject rights (i.e., users can, for example, provide information or make deletion requests directly to Facebook). Note: When Facebook provides us with metrics, analytics and reports (which are aggregated, i.e., do not receive information about individual users and are anonymous to us), this processing is not carried out under shared responsibility, but rather on the basis of a contract processing agreement ("Data Processing Terms ", https://www.facebook.com/legal/terms/dataprocessing), the "Data Security Terms" (https://www.facebook.com/legal/terms/data_security_terms) and, with respect to processing in the U.S., on the basis of standard contractual clauses ("Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority), are not restricted by the agreements with Facebook. 

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. text input, photographs, videos); Event Data (Facebook) ("Event Data" is data that can be transmitted from us to Facebook, e.g. via Facebook pixels (via apps or other means) and relates to persons or their actions; the data includes, for example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; Event data is processed for the purpose of creating target groups for content and advertising information (Custom Audiences); Event Data does not include the actual content (such as written comments), login information, and Contact Information (such as names, email addresses, and phone numbers). Event Data is deleted by Facebook after a maximum of two years, the Custom Audiences created from them with the deletion of our Facebook account). 
  • Data subjects: Users (e.g. website visitors, users of online services). 
  • Purposes of Processing: Provision of our online services and usability; Profiles with user-related information (Creating user profiles); Marketing; Feedback (e.g. collecting feedback via online form); Provision of contractual services and customer support. 
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR); Consent (Article 6 (1) (a) GDPR). 

Further information on processing methods, procedures and services used: 

25. Management, Organization and Utilities 

We use services, platforms and software from other providers (hereinafter referred to as " third-party providers") for the purposes of organizing, administering, planning and providing our services. When selecting third-party providers and their services, we comply with the legal requirements.  

Within this context, personal data may be processed and stored on the servers of third-party providers. This may include various data that we process in accordance with this privacy policy. This data may include in particular master data and contact data of users, data on processes, contracts, other processes and their contents. 

If users are referred to the third-party providers or their software or platforms in the context of communication, business or other relationships with us, the third-party provider processing may process usage data and metadata that can be processed by them for security purposes, service optimisation or marketing purposes. We therefore ask you to read the data protection notices of the respective third party providers. 

Notes on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Furthermore, their use may be a component of our (pre)contractual services, provided that the use of the third-party providers has been agreed within this framework. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy. 

  • Processed data types: Content data (e.g. text input, photographs, videos); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses); Contact data (e.g. e-mail, telephone numbers). 
  • Data subjects: Communication partner (Recipients of e-mails, letters, etc.); Users (e.g. website visitors, users of online services). 
  • Purposes of Processing: Contact requests and communication; Provision of contractual services and customer support; Office and organisational procedures; Managing and responding to inquiries; Feedback (e.g. collecting feedback via online form); Polls and Questionnaires (e.g. surveys with input options, multiple choice questions); Profiles with user-related information (Creating user profiles); Web Analytics (e.g. access statistics, recognition of returning visitors). 
  • Legal Basis: Legitimate Interests (Article 6 (1) (f) GDPR). 

Further information on processing methods, procedures and services used: 

26. Erasure of data 

The data processed by us will be erased in accordance with the statutory provisions as soon as their processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or they are not required for the purpose).  

If the data is not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data will be restricted and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or for which storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person. In the context of our information on data processing, we may provide users with further information on the deletion and retention of data that is specific to the respective processing operation. 

27. Changes and Updates to the Privacy Policy 

We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adjust the privacy policy as changes in our data processing practices make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification. 

If we provide addresses and contact information of companies and organizations in this privacy policy, we ask you to note that addresses may change over time and to verify the information before contacting us. 

28. Rights of Data Subjects 

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

  • Right to Object: You have the right, on grounds arising from your particular situation, to object at any time to the processing of your personal data which is based on letter (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. Where personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of the personal data concerning you for the purpose of such marketing, which includes profiling to the extent that it is related to such direct marketing. 
  • Right of withdrawal for consents: You have the right to revoke consents at any time. 
  • Right of access: You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law. 
  • Right to rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you. 
  • Right to Erasure and Right to Restriction of Processing: In accordance with the statutory provisions, you have the right to demand that the relevant data be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions. 
  • Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to request its transmission to another controller. 
  • Complaint to the supervisory authority: In accordance with the law and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State where you habitually reside, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR. 
  • Contact person for exercising the data subject rights: To exercise the aforementioned rights, please contact [email protected]  with the subject "Data subject rights".  

29. Terminology and Definitions 

This section provides an overview of the terms used in this privacy policy. Many of the terms are drawn from the law and defined mainly in Article 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended above all for the purpose of comprehension. The terms are sorted alphabetically. 

  • A/B Tests: A/B tests are designed to improve the usability and performance of online services. For example, users are presented with different versions of a website or its elements, such as input forms, on which the placement of the contents or labels of the navigation elements can differ. The behaviour of users, e.g. prolonged visits to the site or more frequent interaction with the elements, can then be used to determine which of these sites or elements are more responsive to users' needs.  
  • Clicktracking: Clicktracking allows users to keep track of their movements within an entire website. Since the results of these tests are more accurate if the interaction of the users can be followed over a certain period of time (e.g. if a user likes to return), cookies are usually stored on the computers of the users for these test purposes.  
  • Controller: "Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.  
  • Conversion tracking: Conversion tracking is a method used to evaluate the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the devices of the users within the websites on which the marketing measures take place and then called up again on the target website (e.g. we can thus trace whether the advertisements placed by us on other websites were successful).  
  • Custom Audiences: Target group formation (or "custom audiences") is the term used when target groups are determined for advertising purposes, e.g. display of advertisements. For example, a user's interest in certain products or topics on the Internet may be used to infer that that user is interested in advertisements for similar products or the online store in which they viewed the products. Lookalike Audiences" (or similar target groups) is the term used to describe content that is viewed as suitable by users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies are generally used for the purposes of creating custom audiences and lookalike audiences. Target groups can be created by processing visitors of an online service or can be uploaded to the provider of an online marketing technology by means of uploading (which is usually done pseudonymised).  
  • Heatmaps: "Heatmaps" are mouse movements of the users, which are combined to an overall picture, with the help of which it can be recognized, for example, which web page elements are preferred and which web page elements users prefer less.  
  • 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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.  
  • Processing: The term "processing" covers a wide range and practically every handling of data, be it collection, evaluation, storage, transmission or erasure.  
  • Profiles with user-related information: The processing of "profiles with user-related information", or "profiles" for short, includes any kind of automated processing of personal data that consists of using these personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.  
  • Remarketing: Remarketing" or "retargeting" is the term used, for example, to indicate for advertising purposes which products a user is interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.   
  • Targeting: "Tracking" is the term used when the behaviour of users can be traced across several websites. As a rule, behavior and interest information with regard to the websites used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users presumably corresponding to their interests.  
  • Web Analytics: Web Analytics serves the evaluation of visitor traffic of online services and can determine their behavior or interests in certain information, such as content of websites. With the help of web analytics, website owners, for example, can recognize at what time visitors visit their website and what content they are interested in. This allows them, for example, to optimize the content of the website to better meet the needs of their visitors. For purposes of web analytics, pseudonymous cookies and web beacons are frequently used in order to recognise returning visitors and thus obtain more precise analyses of the use of an online service.  

30. Cookie Settings