Privacy Policy

preamble

With the following data protection declaration we would like to inform you about which types of your personal data (hereinafter also referred to as “data”) we process, for what purposes and to what extent. The data protection declaration 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 offering”).

The terms used are not gender specific.

As of: October 6, 2023

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Table of contents


Responsible person

BB Wertmetall GmbH
Arno-Nitzsche-Straße 45A
04277 Leipzig

Persons authorized to represent:
Managing Director Werner J. Ullmann
Authorized officers René Schulze and Frank Brandenberg

E-mail address: contact@bb-wertmetall.com
Telephone: +49 (0)341 / 99 17 00 0
Fax: +49 (0)341 / 99 17 00 99

Imprint: https://bb-wertmetall.de/impressum/


Relevant legal bases

Relevant legal bases according to the GDPR: Below you will find an overview of the legal basis of the GDPR on the basis of which we process personal data. Please note that in addition to the regulations of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If more specific legal bases apply in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR) – The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
  • Fulfillment of the contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps prior to entering into a contract at the request of the data subject.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR) – Processing is necessary to fulfill a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR) – Processing is necessary to safeguard the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data outweigh them.
  • Application process as a pre-contractual or contractual relationship (Art. 6 Para. 1 Sentence 1 Letter b) GDPR) – If, as part of the application process, special categories of personal data within the meaning of Art. 9 Para. 1 GDPR (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants so that the person responsible or the data subject can exercise the rights arising from labor law and social security and social protection law and fulfill his or her obligations in this regard, their processing takes place in accordance with Art. 9 Para. 2 lit. b. GDPR, in the case of protecting the vital interests of applicants or other persons in accordance with Art. 9 Para. 2 lit. c. GDPR or for the purposes of health care or occupational medicine, for assessing 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 Para. 2 lit. h. GDPR. In the case of communication of special categories of data based on voluntary consent, their processing takes place on the basis of Article 9 Paragraph 2 Letter a. GDPR.

National data protection regulations in Germany: In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. This includes in particular the law to protect against misuse of personal data during data processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes and transmission and automated decision-making in individual cases, including profiling. Furthermore, state data protection laws of the individual federal states may apply.

Note on the validity of the GDPR and Swiss GDPR: This data protection notice serves to provide information in accordance with the Swiss Federal Data Protection Act (Swiss Data Protection Act) and the General Data Protection Regulation (GDPR). For this reason, we ask you to note that due to the broader spatial application and comprehensibility, the terms of the GDPR have been replaced by Swiss terms. In particular, instead of the terms “processing” of “personal data” (or “data” for short) and “legitimate interest” used in the GDPR, the terms “processing” of “personal data” and “overriding interest” used in the Swiss Data Protection Act are used. However, the legal meaning of the terms will continue to be determined according to the Swiss Data Protection Act within the scope of the Swiss Data Protection Act.


Overview of processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.


Types of data processed

  • Inventory data.
  • Payment details.
  • Contact details.
  • Content data.
  • Contract data.
  • Usage Data.
  • Meta, communication and procedural data.
  • Applicant data.


Categories of data subjects

  • Customers.
  • interested parties.
  • Communication partner.
  • User.
  • Applicant.
  • Competition and competition participants.
  • Business and contractual partners.
  • People depicted.


Purposes of processing

  • Provision of contractual services and customer service.
  • Contact inquiries and communication.
  • Security measures.
  • Direct marketing.
  • Range measurement.
  • Office and organizational procedures.
  • Managing and responding to inquiries.
  • Application process.
  • Carrying out competitions and competitions.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.


Security measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, ensuring availability and its separation. We have also set up procedures to ensure that the rights of those affected are exercised, data are deleted and responses are made to data threats. We also take the protection of personal data into account when developing or selecting hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a full IP address is not necessary, the IP address is shortened (also referred to as “IP masking”). Here, the last two digits or the last part of the IP address after a period are removed or replaced with placeholders. Shortening the IP address is intended to prevent or make it significantly more difficult to identify a person based on their IP address.

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


Transfer of personal data

As part of our processing of personal data, the data may be transmitted to or disclosed to other bodies, companies, legally independent organizational units or persons. The recipients of this data may include, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

Data transmission to service providers and sales partners: When carrying out the communication, the communication service providers used, in particular email providers, receive your data.

As part of the conclusion of a contract, the sales partner you may have contacted, the precious metal producer and warehouseman, the respective payment service provider, the service provider of the online portal and the respective logistics partner will receive your data.


Rights of data subjects

Rights of the data subjects under the GDPR: As a 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, for reasons arising from your particular situation, to object at any time to the processing of your personal data, which is carried out on the basis of Article 6 (1) (e) or (f) of the GDPR; This also applies to profiling based on these provisions. If your personal data is processed for the purpose of direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; This also applies to profiling insofar as it is connected to such direct advertising.
  • Right to withdraw consent: You have the right to revoke your consent at any time.
  • Right to information: You have the right to request confirmation as to whether the data in question is being processed and to receive information about this data as well as further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: In accordance with legal requirements, you have the right to request that the data concerning you be completed or that incorrect data concerning you be corrected.
  • Right to deletion and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted immediately, or alternatively, in accordance with the legal requirements, to request a restriction on the processing of the data.
  • Right to data portability: You have the right to receive data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with legal requirements or to request that it be transmitted to another person responsible.
  • Complaint to supervisory authority: In accordance with legal requirements and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you usually reside, the supervisory authority of your place of work or the place of the alleged violation, if you believe that the processing of personal data relating to you violates the GDPR.

Rights of the data subjects according to the Swiss Data Protection Act:

As a data subject, you are entitled to the following rights in accordance with the provisions of the Swiss Data Protection Act:

  • Right to information: You have the right to request confirmation as to whether data concerning you is being processed and to receive the information necessary to enable you to assert your rights under this law and to ensure transparent data processing (Articles 25 to 27 Swiss Data Protection Act).
  • Right to data release or transfer: You have the right to request that the personal data you have provided to us be released in a common electronic format (Articles 28 to 29 Swiss Data Protection Act).
  • Right of action: You have the right to sue to protect your personality (Art. 32 Para. 2 to Para. 4 Swiss Data Protection Act).
  • Right to rectification: In accordance with Article 32 of the Swiss Data Protection Act, you have the right to request that incorrect data concerning you be corrected. If neither the accuracy nor the inaccuracy of the data can be determined, you have the right to have a dispute notice attached (Art. 32 Para. 1 and 3 Swiss Data Protection Act).
  • Right to prohibit processing: You have the right to request a ban on the processing or a restriction on the processing of the data (Art. 32 Para. 2 lit a. Swiss Data Protection Act).
  • Right to prohibit disclosure to third parties: You have the right to request that specific disclosure of your data to third parties be prohibited (Art. 32 Para. 2 lit b. Swiss Data Protection Act).
  • Right to deletion, destruction: You have the right to demand that data concerning you be deleted and destroyed immediately or alternatively (Art. 32 Para. 2 lit c. Swiss Data Protection Act).
  • Right to withdraw consent: You have the right to revoke your consent with effect for the future.


Use of cookies

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

Notes on consent: We use cookies in accordance with legal regulations. We therefore obtain prior consent from users, unless this is not required by law. In particular, consent is not necessary if the storage and reading of the information, including cookies, is absolutely necessary in order to provide users with a telemedia service they have expressly requested (i.e. our online offering). Strictly necessary cookies generally include cookies with functions that serve the display and operability of the online offering, load balancing, security, storing users' preferences and choices or similar purposes related to the provision of the main and secondary functions of the online offering requested by users. The revocable consent is clearly communicated to the users and contains information on the respective cookie use.

Information on data protection legal bases: The data protection legal basis on which we process users' personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for processing your data is their declared consent. Otherwise, the data processed using cookies will be processed on the basis of our legitimate interests (e.g. in operating our online offering and improving its usability) or, if this is within the scope of fulfilling our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We will explain the purposes for which we process cookies in the course of this data protection declaration or as part of our consent and processing processes.

Storage period: With regard to the storage period, the following types of cookies are distinguished:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. User data collected using cookies can also be used to measure reach. Unless we provide users with explicit information about the type and storage period 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.

General information on revocation and objection (so-called “opt-out”): Users can revoke the consent they have given at any time and object to the processing in accordance with legal requirements. To do this, users can, among other things, restrict the use of cookies in their browser settings (which may also limit the functionality of our online offering). You can also object to the use of cookies for online marketing purposes via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ be explained.

  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Consent (Art. 6 Para. 1 Sentence 1 Letter a) GDPR).

Further information on processing processes, procedures and services:

  • Processing of cookie data based on consent: We use a cookie consent management process, within which the users' consent to the use of cookies, or the processing and providers mentioned as part of the cookie consent management process, can be obtained and managed and revoked by the users. The declaration of consent is saved so that it does not have to be asked again and to be able to prove consent in accordance with the legal obligation. The storage can take place on the server side and/or in a cookie (so-called opt-in cookie, or using comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information about the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. Here, a pseudonymous user identifier is created and stored with the time of consent, information about the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and device used; Legal basis: Consent (Art. 6 Para. 1 Sentence 1 Letter a) GDPR).
  • BorlabsCookie: cookie consent management; Service provider: Hosted locally on our server, no data passed on to third parties; Website: https://de.borlabs.io/borlabs-cookie/; Further information: An individual user ID, language as well as types of consent and the time of their submission are stored on the server and in the cookie on the user's device.


Business benefits

We process data from our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) within the framework of contractual and comparable legal relationships as well as associated measures and as part of communication with the contractual partners (or pre-contractual), e.g. to answer inquiries.

We process this data to fulfill our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any update obligations and remedies in the event of warranty and other service disruptions. In addition, we process the data to protect our rights and for the purposes of the administrative tasks associated with these obligations and the company organization. In addition, we process the data on the basis of our legitimate interests in proper and business management as well as security measures to protect our contractual partners and our business operations from misuse and jeopardy of their data, secrets, information and rights (e.g. the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the scope of applicable law, we only pass on the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, as part of this data protection declaration.

We inform the contractual partners which data is required for the aforementioned purposes before or as part of the data collection, e.g. in online forms, through special marking (e.g. colors) or symbols (e.g. asterisks, etc.), or in person.

We delete the data after the expiry of statutory warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal archiving reasons. The statutory retention period is ten years for documents relevant to tax law as well as for commercial books, inventories, opening balance sheets, annual financial statements, the work instructions required to understand these documents and other organizational documents and accounting documents, and six years for commercial and business letters received and copies of the commercial and business letters sent. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report were prepared, the commercial or business letter was received or sent or the accounting document was created, the recording was also made or the other documents were created.

To the extent that we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms apply in the relationship between the users and the providers.

  • Types of data processed: Inventory data (e.g. names, addresses); Payment data (e.g. bank details, invoices, payment history); Contact details (e.g. email, telephone numbers); Contract data (e.g. subject matter of the contract, term, customer category).
  • Affected people: interested parties; Business and contractual partners.
  • Purposes of processing: Provision of contractual services and customer service; Contact inquiries and communication; office and organizational procedures; Managing and responding to inquiries.
  • Legal basis: Fulfillment of the contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legal obligation (Art. 6 para. 1 sentence 1 lit. c) GDPR); Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR).


Provision of online offerings and web hosting

We process users' data in order to be able to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or device.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status); Content data (e.g. entries in online forms).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.); Security measures.
  • Legal basis: Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR).

Further information on processing processes, procedures and services:

  • Provision of online offers on rented storage space: To provide our online offering, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called a “web host”); Legal basis: Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR).
  • Collection of access data and log files: Access to our online offering is logged in the form of so-called “server log files”. The server log files may include the address and name of the websites and files accessed, date and time of access, amounts of data transferred, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

    The server log files can be used on the one hand for security purposes, e.g. to avoid overloading the servers (particularly in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the utilization of the servers and their stability; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is necessary for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.

  • Email sending and hosting: The web hosting services we use also include sending, receiving and storing emails. For these purposes, the addresses of the recipients and senders as well as other information regarding the sending of emails (e.g. the providers involved) as well as the contents of the respective emails are processed. The aforementioned data may also be processed for SPAM detection purposes. We ask you to note that emails on the Internet are generally not sent encrypted. As a rule, emails are encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore assume no responsibility for the transmission path of emails between the sender and receipt on our server; Legal basis: Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR).
  • Host point: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: Hostpoint AG, Neue Jonastrasse 60, 8640 Rapperswil-Jona, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://support.hostpoint.ch/de/; Data protection declaration: https://www.hostpoint.ch/hostpoint/kontakt-agb.html#datenschutz.


Special notes on applications (apps)

We process the data of the users of our application to the extent necessary to be able to provide the application and its functionalities to users, monitor its security and further develop it. We can also contact users in compliance with legal requirements if the communication is necessary for the purposes of administration or use of the application. Furthermore, with regard to the processing of user data, we refer to the data protection information in this data protection declaration.

Legal basis: The processing of data that is necessary to provide the functionalities of the application serves to fulfill contractual obligations. This also applies if the provision of the functions requires user authorization (e.g. approval of device functions). If the processing of data is not necessary to provide the functionality of the application, but serves the security of the application or our business interests (e.g. collection of data for the purpose of optimizing the application or security purposes), it is carried out on the basis of our legitimate interests. If users are expressly asked to give their consent to the processing of their data, the data covered by the consent will be processed on the basis of the consent.

  • Types of data processed: Inventory data (e.g. names, addresses); Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status); Payment data (e.g. bank details, invoices, payment history); Contract data (e.g. subject matter of the contract, term, customer category).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal basis: Consent (Art. 6 Para. 1 Sentence 1 Letter a) GDPR); Fulfillment of the contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR); Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR).

Further information on processing processes, procedures and services:

  • Commercial use: We process the data of the users of our application, registered users and any test users (hereinafter referred to as “users”) in order to be able to provide them with our contractual services and on the basis of legitimate interests in order to ensure the security of our application and to be able to further develop it. The required information is identified as such in the context of the conclusion of the usage, contract, order or comparable contract and may include the information required for the provision of services and any billing as well as contact information in order to be able to hold any consultations; Legal basis: Fulfillment of the contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).
  • Storing a Universal and Unique Identifier (UUID): The application stores a so-called universally unique identifier (UUID) for the purposes of analyzing the use and functionality of the application as well as storing the user settings. This identifier is generated when this application is installed (but is not connected to the device, so not a device identifier in this sense), is stored between the start of the application and its updates and is deleted when users remove the application from their device.
  • Storage of a pseudonymous identifier: So that we can provide the application and ensure its functionality, we use a pseudonymous identifier. The identification is a mathematical value (i.e. no plain data such as names are used) that is assigned to a device and/or the application installation installed on it. This identifier is generated when this application is installed, is stored between the start of the application and its updates, and is deleted when users remove the application from the device.
  • Device permissions to access features and data: The use of our application or its functionalities may require users to have access to certain functions of the devices used or to the data stored on the devices or accessible using the devices. By default, these permissions must be granted by users and can be revoked at any time in the settings of the respective devices. The exact method for controlling app permissions may depend on the user's device and software. If you need clarification, users can contact us. We would like to point out that the denial or revocation of the respective authorizations can affect the functionality of our application.
  • No location history and no movement profiles: The location data is only used selectively and is not processed to create a location history or a movement profile of the devices used or their users.


Blogs and publication media

We use blogs or comparable means of online communication and publication (hereinafter “publication medium”). Readers' data will only be processed for the purposes of the publication medium to the extent necessary for its presentation and communication between authors and readers or for security reasons. Furthermore, we refer to the information on the processing of visitors to our publication medium within the scope of this data protection notice.

  • Types of data processed: Inventory data (e.g. names, addresses); Contact details (e.g. email, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and customer service; Feedback (e.g. collecting feedback via online form); Provision of our online offering and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR).


Contact and inquiry management

When you contact us (e.g. by post, contact form, email, telephone or via social media) as well as within the framework of existing user and business relationships, the information provided by the inquiring person is processed to the extent that this is necessary to answer the contact request and any requested measures.

  • Types of data processed: Contact details (e.g. email, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
  • Affected people: Communication partner.
  • Purposes of processing: Contact inquiries and communication; managing and responding to inquiries; Feedback (e.g. collecting feedback via online form); Provision of our online offering and user-friendliness; Direct marketing (e.g. via email or post).
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Fulfillment of the contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).

Further information on processing processes, procedures and services:

  • Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data provided to us in this context to process the request communicated; Legal basis: Fulfillment of the contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b) GDPR), legitimate interests (Art. 6 Para. 1 S. 1 lit. f) GDPR).
  • ActiveCampaign: email marketing platform; Service provider: ActiveCampaign, Inc., 1 N Dearborn, 5th Floor Chicago, Illinois 60602, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.activecampaign.com; Data protection declaration: https://www.activecampaign.com/privacy-policy/; Standard contractual clauses (guaranteeing the level of data protection when processing in third countries): https://www.activecampaign.com/legal/newscc.


Video conferences, online meetings, webinars and screen sharing

We use platforms and applications from other providers (hereinafter referred to as “conference platforms”) for the purposes of conducting video and audio conferences, webinars and other types of video and audio meetings (hereinafter referred to collectively as “conferences”). When selecting conference platforms and their services, we observe the legal requirements.

Data processed by conference platforms: As part of participation in a conference, the conference platforms process the following personal data of the participants. The scope of processing depends, on the one hand, on what data is required as part of a specific conference (e.g. providing access data or real names) and what optional information is provided by the participants. In addition to processing to carry out the conference, the participants' data can also be processed by the conference platforms for security purposes or service optimization. The data processed includes personal data (first name, last name), contact information (email address, telephone number), access data (access codes or passwords), profile pictures, information about professional status/function, the IP address of the Internet access, information about the participants' end devices, their operating system, the browser and its technical and linguistic settings, information about the content of communication processes, i.e. entries in chats as well as audio and video data, as well as the use of other available functions (e.g. surveys). The content of communications is encrypted to the extent technically provided by the conference provider. If the participants are registered as users on the conference platforms, then further data can be processed in accordance with the agreement with the respective conference provider.

Logging and recordings: If text entries, participation results (e.g. from surveys) as well as video or audio recordings are logged, this will be transparently communicated to the participants in advance and they will be asked for consent if necessary.

Participants’ data protection measures: Please note the details of the processing of your data by the conference platforms in their data protection information and select the security and data protection settings that are optimal for you within the settings of the conference platforms. Please also ensure data and privacy protection in the background of your recording for the duration of a video conference (e.g. by informing roommates, locking doors and using, where technically possible, the function to obscure the background). Links to the conference rooms and access data may not be passed on to unauthorized third parties.

Notes on legal bases: If, in addition to the conference platforms, we also process users' data and ask the users for their consent to the use of the conference platforms or certain functions (e.g. consent to a recording of conferences), the legal basis for the processing is this consent. Furthermore, our processing may be necessary to fulfill our contractual obligations (e.g. in participant lists, in the case of processing the results of discussions, etc.). Furthermore, user data is processed based on our legitimate interests in efficient and secure communication with our communication partners.

  • Types of data processed: Inventory data (e.g. names, addresses); Contact details (e.g. email, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
  • Affected people: communication partner; Users (e.g. website visitors, users of online services); People depicted.
  • Purposes of processing: Provision of contractual services and customer service; Contact inquiries and communication; Office and organizational procedures.
  • Legal basis: Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR).

Further information on processing processes, procedures and services:


Application process

The application process requires that applicants provide us with the data required for their assessment and selection. The information required can be found in the job description or, in the case of online forms, in the information provided there.

Basically, the required information includes personal information such as name, address, contact details and evidence of the qualifications required for a position. Upon request, we will also be happy to provide information about what information is required.

If provided, applicants can submit their applications to us using an online form. The data is transmitted to us in encrypted form in accordance with the state of the art. Applicants can also send us their applications via email. However, we ask you to note that emails on the Internet are generally not sent encrypted. As a rule, emails are encrypted in transit, but not on the servers from which they are sent and received. We can therefore assume no responsibility for the transmission path of the application between the sender and receipt on our server.

For the purposes of searching for applicants, submitting applications and selecting applicants, we may use applicant management and/or recruitment software and platforms and services from third-party providers in compliance with legal requirements.

Applicants are welcome to contact us about how to submit their application or send us the application by post.

Processing of special categories of data: If special categories of personal data (Art. 9 Para. 1 GDPR, e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants as part of the application process, their processing takes place so that the person responsible or the data subject can exercise the rights arising from labor law and the law on social security and social protection and can fulfill his or her obligations in this regard, in the case of protecting vital interests the applicant or other persons or for the purposes of health care or occupational medicine, for the assessment of the employee's ability to work, for medical diagnostics, for care or treatment in the health or social sector or for the administration of systems and services in the health or social sector (Art. 9 Para. 2 lit. b), c) and h) GDPR).

Deletion of data: If the application is successful, the data provided by the applicants can be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicant's data will be deleted. Applicants' data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time. The deletion will take place, subject to a justified revocation by the applicant, at the latest after a period of six months has elapsed, so that we can answer any follow-up questions about the application and fulfill our obligations to provide proof under the regulations on equal treatment of applicants. Invoices for any reimbursement of travel expenses are archived in accordance with tax law requirements.

Inclusion in an applicant pool: Inclusion in an applicant pool, if offered, is based on consent. Applicants are informed that their consent to be included in the talent pool is voluntary, has no influence on the ongoing application process and that they can revoke their consent at any time in the future.

Duration of data storage in the applicant pool in months:

6 months, unless longer storage is explicitly agreed.

  • Types of data processed: Inventory data (e.g. names, addresses); Contact details (e.g. email, telephone numbers); Content data (e.g. entries in online forms); Applicant data (e.g. personal details, postal and contact addresses, the documents associated with the application and the information contained therein, such as cover letters, CVs, certificates and other information about their person or qualifications provided voluntarily by applicants with regard to a specific position).
  • Affected people: Applicant.
  • Purposes of processing: Application process (justification and possible subsequent implementation as well as possible later termination of the employment relationship).
  • Legal basis: Application process as a pre-contractual or contractual relationship (Art. 6 Para. 1 Sentence 1 Letter b) GDPR); Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR).

Further information on processing processes, procedures and services:

  • JOIN: Services related to employee acquisition/recruitment (search for employees, communication, application process, contract negotiations); Service provider: JOIN Solutions GmbH, Schönhauser Allee 36, 10435 Berlin, Germany; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://join.com/de/; Data protection declaration: https://join.com/de/datenschutz/.


Newsletters and electronic notifications

We only send newsletters, emails and other electronic notifications (hereinafter “newsletter”) with the consent of the recipient or legal permission. If the contents are specifically described when registering for the newsletter, they are decisive for the user's consent. Our newsletters also contain information about our services and us.

In order to register for our newsletters, it is generally sufficient to provide your email address. However, we may ask you to provide a name so that you can be addressed personally in the newsletter, or other information if this is necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter generally takes place in a so-called double opt-in process. This means that after registering you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can log in with someone else's email address. Registrations for the newsletter are logged in order to be able to provide evidence of the registration process in accordance with legal requirements. This includes storing the registration and confirmation times as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

Deletion and restriction of processing: We can store the unsubscribed email addresses for up to three years based on 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 possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time. In the event of obligations to permanently observe contradictions, we reserve the right to store the email address in a blacklist (so-called “blocklist”) solely for this purpose.

The registration process is recorded on the basis of our legitimate interests for the purpose of providing evidence of its proper execution. If we commission a service provider to send emails, this is based on our legitimate interests in an efficient and secure shipping system.

Contents:

Information about us, our products and services, promotions and offers, as well as market events primarily in relation to currencies and precious metals, as well as background information on silver, gold and mindset when investing in precious metals.

  • Types of data processed: Inventory data (e.g. names, addresses); Contact details (e.g. email, telephone numbers); Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status); Usage data (e.g. websites visited, interest in content, access times).
  • Affected people: Communication partner.
  • Purposes of processing: Direct marketing (e.g. via email or post).
  • Legal basis: Consent (Art. 6 Para. 1 Sentence 1 Letter a) GDPR); Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR).
  • Option to object (opt-out): You can cancel your 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 use one of the contact options listed above, preferably email.

Further information on processing processes, procedures and services:

  • Measuring open and click rates: The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from their server. As part of this retrieval, technical information is initially collected, such as information about the browser and your system, as well as your IP address and the time of retrieval.

    This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their access locations (which can be determined using the IP address) or access times. This analysis also includes determining whether the 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 it is deleted. The evaluations help us 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 the opening rates and click rates as well as the storage of the measurement results in the users' profiles and their further processing are based on the users' consent.

    Unfortunately, it is not possible to revoke the success measurement separately; in this case, the entire newsletter subscription must be canceled or objected to. In this case, the saved profile information will be deleted; Legal basis: Consent (Art. 6 Para. 1 Sentence 1 Letter a) GDPR).

  • Reminder emails about the ordering process: If users do not complete an ordering process, we can remind users of the ordering process by email and send them a link to continue it. This function can be useful, for example, if the purchasing process could not be continued due to a browser crash, oversight or forgetting. Shipping is based on consent, which users can revoke at any time; Legal basis: Consent (Art. 6 Para. 1 Sentence 1 Letter a) GDPR).
  • ActiveCampaign: email marketing platform; Service provider: ActiveCampaign, Inc., 1 N Dearborn, 5th Floor Chicago, Illinois 60602, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.activecampaign.com; Data protection declaration: https://www.activecampaign.com/privacy-policy/; Standard contractual clauses (guaranteeing the level of data protection when processing in third countries): https://www.activecampaign.com/legal/newscc.


Advertising communication via email, post, fax or telephone

We process personal data for the purposes of advertising communication, which can take place via various channels, such as email, telephone, post or fax, in accordance with legal requirements.

The recipients have the right to revoke 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 previous authorization to contact or send you up to three years after 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 possible defense against claims. Based on the legitimate interest in permanently observing the user's revocation or objection, we also store the data necessary to avoid renewed contact (e.g., depending on the communication channel, the email address, telephone number, name).

  • Types of data processed: Inventory data (e.g. names, addresses); Contact details (e.g. email, telephone numbers).
  • Affected people: Communication partner.
  • Purposes of processing: Direct marketing (e.g. via email or post).
  • Legal basis: Consent (Art. 6 Para. 1 Sentence 1 Letter a) GDPR); Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR).


Sweepstakes and competitions

We only process personal data of participants in competitions and competitions in compliance with the relevant data protection regulations, provided that the processing is contractually necessary for the provision, implementation and processing of the competition, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the security of the competition or the protection of our interests against misuse through the possible collection of IP addresses when submitting competition entries).

If participants' contributions are published as part of the competitions (e.g. as part of a vote or presentation of the competition entries or the winners or the reporting on the competition), we would like to point out that the names of the participants can also be published in this context. Participants can object to this at any time.

If the competition takes place within an online platform or a social network (e.g. Facebook or Instagram, hereinafter referred to as “online platform”), the usage and data protection regulations of the respective platforms also apply. In these cases, we would like to point out that we are responsible for the information provided by participants as part of the competition and that inquiries regarding the competition should be directed to us.

The participants' data will be deleted as soon as the competition or competition has ended and the data is no longer required to inform the winners or because questions about the competition are expected. In principle, the participants' data will be deleted no later than 6 months after the end of the competition. Winners' data may be retained for a longer period of time, for example in order to be able to answer questions about the prizes or to fulfill the prize services; In this case, the retention period depends on the type of prize and is up to three years, for example for items or services, in order to be able to process warranty cases, for example. Furthermore, the participants' data can be stored for longer, e.g. in the form of reporting on the competition in online and offline media.

If data was collected for other purposes as part of the competition, its processing and retention period are based on the data protection information on this use (e.g. in the case of registration for the newsletter as part of a competition).

  • Types of data processed: Inventory data (e.g. names, addresses); Content data (e.g. entries in online forms); Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
  • Affected people: Competition and competition participants.
  • Purposes of processing: Carrying out competitions and competitions.
  • Legal basis: Fulfillment of the contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).


Web analysis, monitoring and optimization

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

In addition to web analysis, we can also use testing procedures, for example to test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles, i.e. data summarized into a usage process, can be created for these purposes and information can be stored in a browser or in a device and read out 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 about times of use. If users have agreed to the collection of their location data to us or to the providers of the services we use, location data can also be processed.

The users’ IP addresses are also stored. However, we use an IP masking process (i.e. pseudonymization by shortening the IP address) to protect users. In general, as part of web analysis, A/B testing and optimization, no clear user data (such as email addresses or names) is stored, but rather pseudonyms. This means that we and 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 procedures.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors); Profiles with user-related information (creating user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 Para. 1 Sentence 1 Letter a) GDPR).

Further information on processing processes, procedures and services:

  • Matomo: Matomo is software that is used for web analysis and reach measurement purposes. When using Matomo, cookies are generated and stored on the user's device. The user data collected when using Matomo is only processed 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/; Legal basis: Consent (Art. 6 Para. 1 Sentence 1 Letter a) GDPR); Deletion of data: The cookies have a storage period of a maximum of 13 months.


Customer reviews and rating process

We participate in review and rating processes to evaluate, optimize and promote our services. If users rate us via the evaluation platforms or procedures involved or otherwise give feedback, the general terms and conditions or terms of use and the data protection information of the providers also apply. As a rule, the evaluation also requires registration with the respective provider.

In order to ensure that the reviewers have actually used our services, we transmit, with the consent of the customer, the necessary data regarding the customer and the service used to the respective review platform (including name, email address and order number or item number). This data is used solely to verify the authenticity of the user.

  • Types of data processed: Contract data (e.g. subject matter of the contract, term, customer category); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
  • Affected people: Customers; Users (e.g. website visitors, users of online services).
  • Purposes of processing: Feedback (e.g. collecting feedback via online form); Marketing.
  • Legal basis: Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR).

Further information on processing processes, procedures and services:

  • Rating widget: We include so-called “rating widgets” in our online offering. A widget is a functional and content element integrated into our online offering that displays changeable information. For example, it can be represented in the form of a seal or comparable element, sometimes also called a “badge”. Although the corresponding content of the widget is displayed within our online offering, it is currently being retrieved from the servers of the respective widget provider. This is the only way to always show the current content, especially the current rating. To do this, a data connection must be established from the website accessed within our online offering to the widget provider's server and the widget provider receives certain technical data (access data, including IP address) that is necessary so that the content of the widget can be delivered to the user's browser.

    Furthermore, the widget provider receives information that users have visited our online offering. This information can be stored in a cookie and used by the widget provider to recognize which online offers that take part in the evaluation process have been visited by the user. The information may be stored in a user profile and used for advertising or market research purposes; Legal basis: Legitimate interests (Art. 6 Para. 1 Sentence 1 Letter f) GDPR).

  • Google customer reviews: Service for collecting and/or presenting customer satisfaction and opinions; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Terms and Conditions: https://support.google.com/merchants/topic/7259129?hl=de&ref_topic=7257954; Data protection declaration: https://policies.google.com/privacy; Further information: As part of the collection of customer reviews, an identification number and time for the business transaction to be evaluated are processed; in the case of review requests sent directly to customers, the customer's email address and their country of residence as well as the review information itself are processed; Further information on the types of processing and the data processed: https://privacy.google.com/businesses/adsservices; Data processing conditions for Google advertising products: Information about the services Data processing conditions between controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.
  • Trustpilot: review platform; Service provider: Trustpilot A/S, Pilestræde 58, 5, 1112 Copenhagen, Denmark; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://de.trustpilot.com; Data protection declaration: https://de.legal.trustpilot.com/end-user-privacy-terms.


Plugins and embedded functions and content

We include functional and content elements in our online offering that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). This can be, for example, graphics, videos or city maps (hereinafter referred to as “content”).

The integration always requires that the third party providers of this content process the users' IP address, as without the IP address they would not be able to send the content to their browser. The IP address is therefore required to display this content or functions. We strive to only use content whose respective providers only use the IP address to deliver the content. 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 can also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offering, as well as being linked to such information from other sources.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); Meta, communication and procedural data (e.g. IP addresses, times, identification numbers, consent status).
  • Affected people: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offering and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR; Art. 31 Para. 1 and 2 Swiss DSG).

Further information on processing processes, procedures and services:

  • MyFonts: fonts; Data processed as part of the font retrieval includes the identification number of the web font project (anonymized), the URL of the licensed website, which is linked to a customer number to identify the licensee and the licensed web fonts, and the referrer URL; the anonymized webfont project identification number is stored in encrypted log files with such data for 30 days to determine the monthly number of page views; After such extraction and storage of the number of page views, the log files are deleted; Service provider: Monotype Imaging Holdings Inc., 600 Unicorn Park Drive, Woburn, Massachusetts 01801, USA; Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR; Art. 31 Para. 1 and 2 Swiss DSG); Website: https://www.myfonts.co; Data protection declaration: https://www.myfonts.com/info/legal/#Privacy.


Changes and updates to the data protection declaration

We ask you to regularly inform yourself about the content of our data protection declaration. We will adapt the data protection declaration as soon as changes to the data processing we carry out 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 for companies and organizations in this data protection declaration, please note that the addresses may change over time and ask you to check the information before contacting us.


Definitions of terms

This section provides an overview of the terms used in this data protection declaration. To the extent that the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are intended primarily to provide understanding.

  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); A natural person is considered to be identifiable if he or she can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more special characteristics that express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
  • Profiles with user-related information: The processing of “profiles with user-related information”, or “profiles” for short, includes any type of automated processing of personal data, which consists in using these personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profile creation, this may include different information regarding demographics, behavior and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, the clicking behavior on a website or the location). Cookies and web beacons are often used for profiling purposes.
  • Range measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behavior or interests of visitors in certain information, such as the content of websites. With the help of reach analysis, website owners can, for example, identify at what time visitors visit their website and what content they are interested in. This allows you, for example, to better adapt the content of the website to the needs of your visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyzes of the use of an online offering.
  • Responsible person: The “controller” is the natural or legal person, public authority, institution or other body that alone or jointly with others decides on the purposes and means of processing personal data.
  • Processing: “Processing” means any operation or series of operations relating to personal data, carried out with or without the aid of automated procedures. The term is wide-ranging and includes practically every handling of data, be it collecting, evaluating, storing, transmitting or deleting.
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