Privacy policy for social networks

(Status: Juli 20, 2023)

We maintain an online presence on various social networks and platforms. In the following, we would like to inform you about the data collected by them and by us, their purposes, the legal basis, recipients and your rights.

1. NOTE IN ADVANCE

We would like to point out that you use our content and the interactive functions provided (e.g. commenting, sharing, rating) on your own responsibility. Alternatively, you can also find the information/products etc. offered via our social networks on our website at www.allgaeubatterie.de. You are also welcome to contact us for more information at any time via e-mail at info@allgaeubatterie.de.

2. RESPONSIBLE AND DATA PROTECTION OFFICER

Jointly responsible persons within the meaning of Art. 26 of the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection regulations for our social platforms are

Allgäu Batterie GmbH & Co. KG
Hoyen 21
87490 Haldenwang
Phone: 0049 8374 24124-0
Email: info@allgaeubatterie.de
Web: www.allgaeubatterie.de/en

Data protecion officer ist Tobias Kinert, E-Mail tobias.kinert@allgaeubatterie.de.

as well as the company named below for the respective network

Facebook: Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. Supervisory authority is Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland, https://www.dataprotection.ie.

Instagram: Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. Supervisory authority is Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland, https://www.dataprotection.ie.

Xing: New Work SE, Dammtorstraße 30, 20457 Hamburg, Germany, Tel.: +49 40 419 131-0, e-mail: info@xing.com. The data protection officer is Felix Lasse, Am Strandkai 1, 20457 Hamburg, Germany, https://www.xing.com/support/contact/security/data_protection. The supervisory authority is the Hamburg Commissioner for Data Protection and Freedom of Information, Ludwig-Erhard-Str. 22, 20459 Hamburg, Germany, www.datenschutz-hamburg.de.

YouTube: Google Ireland Ltd, Gordon House, Barrow St, Dublin 4, Ireland. Supervisory authority is Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland, https://www.dataprotection.ie/.

LinkedIn: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2. The data protection officer can be reached at https://www.linkedin.com/help/linkedin/ask/TSO-DPO. The supervisory authority is the Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland, https://www.dataprotection.ie.

3. GENERALLY COLLECTED DATA

When you visit our website on the respective social network, your IP address and other information will be stored. The further information results from the data mentioned in section 4, which we process, as well as from the data processed by the respective network (for further information, see section 6). The data is partly stored on your terminal device by cookies. Cookies are small text files that, as soon as you visit a website, are sent to your browser by a web server and stored locally on your end device (PC, notebook, tablet, smartphone, etc.) and stored on your computer and provide the user (i.e. us) with certain information. Cookies do not cause any damage to the computer and do not contain viruses. Each cookie contains a characteristic character string (so-called cookie ID), which enables the browser to be uniquely identified when the website is called up again.

If you want to avoid data usage by the social network, you should log out of it or deactivate the “stay logged in” function, delete the cookies present on your end device and close and restart your browser. You will then be able to visit our fanpage page without revealing your own identifier. Please note, however, that you will then not be able to use any interactive functions, as you would have to log in again to do so.

Furthermore, you can deactivate or restrict the use of cookies by setting your browser software accordingly. However, in this case you may not be able to access our site on the social network.

4. DATA COLLECTED BY US IN THE SOCIAL NETWORKS

4.1 Facebook

4.1.1 Page Insights

We ourselves use the respective statistical evaluations (SeitenInsights) that the social network makes available to us. We are currently unable to turn this off or modify it. We collect the following data as a result:

Statistical data on the actions of individuals: including, but not limited to, views of our site, viewing posts, subscribing to pages, tagging, recommending, commenting, sharing, type of reactions, performance of posts, clicks, negative feedback, on conversations, on views of our store or interactions there, on our events (ticket sales, clicks, registrations, guest posts) or interactions there (link uses, tickets sold, people reached), on the use of the website, phone number, route plan buttons or other buttons on our site.
Statistical data on the actions themselves and on the persons who performed the actions and/or on their browsers/apps used: access times, location (estimated from IP address or, for logged-in users, from user profile), language code (from browser http header and/or language setting); age/gender data (from user profile; only for logged-in users); website previously visited (from browser http header); use of a computer or mobile device (from browser user agent or app attributes); Facebook user ID (only for logged-in users).
Insofar as we post events, live videos, stories or other, performance data is also evaluated here, i.e., among other things, the number of views or the duration of the views, the number of interactions, the demographic target group, etc.

We receive the evaluations of the data mentioned in this paragraph anonymized in each case, whereas Facebook receives the data without anonymization.

Whether someone is logged in to Facebook is determined with the help of cookies (see Cookie Policy at https://www.facebook.com/policies/cookies). Without login, most actions are not possible.

The legal basis for the collection of the above data by us for statistical purposes is Art. 89 DSGVO and, as far as sensitive data is concerned, § 27 BDSG in conjunction with. Art. 9 para. 1 in conjunction with. Art. 22 para. 2 p. 2 DSGVO. The data is processed by us only anonymously. Further legal basis for this is Art. 6 para. 1 lit. a) DSGVO; this applies in particular to the marketing purposes also pursued with the SeitenInsights. We also have a legitimate interest in this. By anonymizing the data, your rights are largely protected.

Purpose: We use the data to learn which posts visitors interact with (or not). With the help of the results, we can build and expand our audience and provide them with events, information, etc. that are of interest to their respective target groups and optimize our content. Through the reach and contribution statistics, we can see which posts have received the most attention; through the action and contribution statistics, we can see how we can motivate people to interact more; through the call statistics, we can target content to specific audiences.

Deletion: The statistical data is deleted after 90 days at the latest. As already communicated, the statistical data is collected without any opt-out option by us at this time. If you do not want this, you can configure this under settings, https://www.facebook.com/settings. For the rest, please contact the social network directly at the addresses mentioned in item 2.

4.1.2 Interactions/messages

We collect content, communications and other information that you provide when you visit our Fanpage and interact with us through it, see above. Based on this, we collect and process the content you communicate and how you interact. In each case, we process the content of the message as well as the time.

We would like to point out that – insofar as you have a Facebook profile yourself – we are also able to track your networks (groups, connected pages) and connections as well as view the information you have posted there (photos, posts, information, etc.) due to your interaction. In doing so, you may also disclose sensitive data pursuant to Art. 9 DSGVO. If we collect this data, we will only collect and evaluate it anonymously without the possibility of drawing conclusions about a person. This serves to learn more about our customer target group and to better adjust our advertising/products to our customers. We use the data so that we can learn which posts and information you interact with (or not). With the help of the results, we can build and expand our target group and provide them with events, information, etc. that are of interest to their target group and optimize our content. Furthermore, we recognize which posts have received the most attention. In addition, we would like to know which visitors view our profile and how it came about. This also helps us to learn more about our target customer group and to better tailor our advertising/products to you.

We would like to point out that the data can be viewed not only by us and Facebook, but also by their affiliated partners/companies as well as by all subscribers, fans, contributors, commentators and other persons who click on our page or surf on pages of our subscribers, fans, contributors and commentators.

The legal basis for the collection of the aforementioned data is Art. 6 para. 1 lit. a) DSGVO. The subscribers, fans, contributors and commentators give their consent to the collection by voluntarily interacting with our fan page in connection with the acceptance of the terms of use of Facebook.

The data is usually removed when our site is deleted or temporarily removed when deactivated. Incidentally, you can delete your connections to us by deactivating the Like buttons again. If we receive a revocation and have the option to delete your data (for example, comments on our pinboard, etc.), we will implement the necessary steps for this. The revocation does not affect the legality of the processing of your data based on your consent until a possible revocation. Alternatively, we ask you to contact the social network directly at the addresses mentioned in item 2, as we cannot trace which data originates from you due to the extensive anonymization of the data. You can prevent the collection of your data by selecting appropriate privacy settings on Facebook, see https://www.facebook.com/settings.

Furthermore, you can send us messages via the social network. In this case, the personal data transmitted with the message (name/user name; profile picture) will be stored. In this case, you agree that we may also contact you via this communication channel in order to answer your request. In this context, the data will not be passed on to third parties. The data will be used exclusively for processing the conversation. The legal basis for the processing of data transmitted in the course of sending a message is Art. 6 (1) lit. f) DSGVO. The legitimate interest lies in the processing of your request. If the message/contact is aimed at the conclusion of a contract, the additional legal basis for the processing is Art. 6 (1) lit. b) DSGVO. The data from the message will be deleted when the respective conversation has ended. However, if the conversation aims at the conclusion of a contract, the data will be deleted according to the legal retention periods; this is usually 10 years. A revocation option exists insofar as the message does not serve the preparation or execution of a contract. Please note that in this case the request may not be processed.

4.1.3 Use of Facebook interfaces

Insofar as we use Facebook tools that create an interface to Facebook (e.g. use of the Like button, Facebook Connect, use of the Facebook API/-SDK/Pixel, etc. as part of the store), information is passed on to Facebook, such as your device, websites visited, purchases made, advertisements viewed and type of use of the services – regardless of whether you have a Facebook account or are logged in there.

Based on this, we collect and process

the way of interactions (likes),
Information about transactions, i.e. how process data, if you are redirected to our store via our fan page.
Information about log data, if you use our Facebook login.

This serves to learn more about our target customer group and to better tailor our advertising/products to our customers. Furthermore, this serves to measure the effectiveness and distribution of the advertisements as well as to promote products as effectively as possible on multiple channels.

When using the interface tools, the data is not only viewable by us and Facebook, but also, among others, by their affiliated partners/companies as well as, if applicable, by all subscribers, fans, contributors, commenters and other persons who click on our page (e.g., in the case of Like clicks).

The legal basis for the collection of data within the framework of the tools is in particular Art. 6 para. 1 lit. a) DSGVO. The use of the tools is voluntary. You give your consent to the collection by voluntarily activating the tools or contacting us via them in connection with the acceptance of the terms of use of Facebook.

You can prevent the collection of your data by, for example, either making purchases directly via our website, not activating any Like buttons, and not logging in or registering via Facebook Connect. You can delete your connections to us by, for example, deactivating the Like button again. If we receive a revocation and have the option to delete your data, we will implement the necessary steps for this. The revocation does not affect the legality of the processing of your data based on your consent until a possible revocation. Alternatively, we ask you to contact the social network directly at the addresses listed in section 2.

4.1.4 Events

We also use the “Events” tool on Facebook. Provided that you have liked our fan page, we can invite you to events. You can like, share, comment or be interested in or participate in the events. For the rest, you can ask us questions about the event at any time. In the context of our events, you can post contributions, provided that we grant this permission. We statistically collect the number of participants and related interactions.

The data processing serves to learn more about our participants and interested parties and to better tailor our events to you. Furthermore, Facebook makes it easier for us to plan the event as well as to track the attendees.

The information can be seen by the host of the event, i.e. us, as well as possibly by anyone on and off Facebook. Incidentally, the data will only be passed on to any co-organizers.

Insofar as you book participation in the event (free of charge or for a fee), the legal basis for the processing is Art. 6 (1) lit. b) DSGVO. As far as you interact with us in the context of or due to the events (esp. liking, commenting, recommending, posts, etc.), the legal basis is Art. 6 para. 1 lit. a) DSGVO, whereby you impliedly give your consent with the respective interaction. Insofar as you show interest in our event or ask questions in the context of this, the legal basis for the processing of the data processed through this is Art. 6 para. 1 lit. f) DSGVO, as this allows us to better plan the event or evaluate the interest in the topic of the event, etc., in order to align our event marketing with this in the future. In addition, it is only through your queries that this event receives added value for you. This is also our legitimate interest at the same time.

The data is stored by Facebook and then automatically deleted. Insofar as the legal basis is your consent, you can revoke this at any time. If we receive a revocation and have the option to delete your data (for example, comments on our wall, etc.), we will implement the necessary steps for this. The revocation does not affect the legality of the processing of your data based on your consent until a possible revocation.

4.1.5 Facebook Stories

We also use the “Stories” tool on Facebook. You can like, share and comment on them and otherwise interact with us and others via this. Based on this, we collect and process the content you communicate (hashtags, messages, etc.) and the nature of the interactions. In each case, we process the content of any message as well as the time. The collection serves us to learn more about our fans and to better adjust our advertising/products to them.

Only we, as the author, see your comments and reactions to the stories. But we would like to point out that the data is also processed by Facebook.

If we receive a revocation and have the option to delete your data (e.g. messages), we will implement the necessary steps for this. The revocation does not affect the legality of the processing of your data based on your consent until a possible revocation. Incidentally, you can delete your connections to us by deactivating the interaction buttons again.

4.1.6 Call-to-Action buttons

You can use the button to contact us directly, obtain further information or conclude a contract. The legal basis for the processing of data transmitted in the course of sending a message is Art. 6 para. 1 lit. f) DSGVO. The legitimate interest lies in the processing of your request. If this is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) lit. b) DSGVO. The personal data collected will be stored until the expiry of the statutory retention obligation for merchants (6, 8 or 10 years after the end of the calendar year in which the contractual relationship was terminated) and then deleted. This does not apply exceptionally if we are obliged to store data for a longer period of time due to tax or commercial law retention obligations (according to HGB, StGB or AO) or if you have consented to storage beyond this period. If the legal basis is your consent, you can also revoke it. The revocation does not affect the legality of the processing of your data based on your consent until a possible revocation.

4.1.7 Meta Business Suite

Wir nutzen die Meta Business Suite, um hierüber Auswertungen zu Werbestrategien zu erstellen, unsere Werbung zu planen, unseren Shop zu erstellen und zu pflegen, Werbeanzeigen zu platzieren und auszuwerten, Anzeigenberichte zu stellen, unsere Medienbibliothek und Seiteneinstellungen zu verwalten, Beiträge zu planen und Werbekonten abzurechnen, Events zu managen, Formulare zu verwalten. Hierbei können wir auch unsere Zielgruppen festlegen.

Rechtsgrundlage hierfür ist Art. 6 Abs. 1 lit. f) DSGVO, da wir nur hierdurch in der Lage sind, das Soziale Netzwerk unternehmerisch sinnvoll zu nutzen, Budgets sinnvoll zu planen und unsere Kundenstrategie festzulegen. Die etwaige Nutzung der Zielgruppeneinstellungen erfolgt auf Basis des Art. 6 Abs. 1 lit. f) DSGVO, da wir so nur die Interessenten auswählen, für die wir potentiell interessant sind und andere Personen hierüber erst gar nicht behelligt werden. Dies liegt in unserem Interesse sowie im Interesse aller Personen. Im Übrigen gilt das zu Ziff. 4.1.1 und 4.1.2 Gesagte.

4.1.8 Facebook monetization features

We use Facebook’s monetization features to tag business partners. We may receive compensation for this (e.g., for branded content). We point out that in the case of interaction with monetized content, all data we receive is also transmitted to our business partners. We are contractually obligated to do so. Our respective business partner can be seen from the advertisement. The legal basis for this is Art. 6 para. 1 lit. b) DSGVO. In all other respects, the same applies as stated in sections 4.1.1 and 4.1.2.

4.3 Instagram

4.3.1 Page insights

We ourselves use the respective statistical evaluations (page insights) that the social network makes available to us. We are currently unable to turn this off or modify it. We collect the following data as a result:

Statistical figures on actions of people: Viewing our profile, website, post, clicks on our buttons or route planner, interactions with our posts, and the type of interaction/reaction.
Interactions are, depending on the type of post, tagging, commenting, sharing or saving our content, negative feedback such as reporting as spam or hiding, like clicks, leaving or clicks on next stories, clicks on links.
Statistical payments by the way: Reaching new subscribers through our posts, reach, average percentage of a video content viewed.

Furthermore, data on our target group is collected: Top locations, average age, gender, most active times, interests, etc.

According to Instagram, no insights are created in the EU in connection with messages.

As far as we post live videos, stories or other, the performance data is also evaluated according to the above-mentioned data.

We receive the evaluations of the data mentioned in this paragraph anonymized, whereas Instagram receives the data without anonymization. Whether someone is logged in to Instagram is determined with the help of cookies (see Cookie Policy at https://www.facebook.com/policies/cookies). Without a login, most actions are not possible. Only visiting a page or clicking on a photo/video to view it is possible.

The legal basis for the collection of the above-mentioned data by us for statistical purposes is Art. 89 DSGVO and, insofar as sensitive data is concerned, § 27 BDSG i.V.m. Art. 9 para. 1 in conjunction with. Art. 22 para. 2 p. 2 DSGVO. The data is only collected by us anonymously. Further legal basis for the collection of the aforementioned data is Art. 6 para. 1 lit. a) DSGVO. You give your consent to the collection by accepting the terms of use of the respective social network and the posts of these based on them.

Purpose: We use the data to learn which posts you interact with (or not). With the help of the results, we can build and expand our audience and provide them with events, information, etc. that are of interest to their respective target groups and optimize our content. Through the reach and contribution statistics, we can see which posts have received the most attention; through the action and contribution statistics, we can see how we can motivate people to interact more; through the call statistics, we can target content to specific audiences.

Deletion: this data is made available for up to 90 days at a time. As already communicated, the statistical data is collected without any opt-out option by us at this time. If you do not want this, you can configure this under settings, https://www.instagram.com/accounts/privacy_and_security/. For the rest, please contact the social network directly at the addresses given in item 2.

4.2.2 Interactions/Messages

We collect content, communications and other information that you provide when you visit our Fanpage and interact with us through this, see above. Based on this, we collect and process the content you communicate (hashtags, messages, etc.) and the manner of the interactions. In each case, we process the content of the message as well as the time. We would like to point out that – insofar as you yourself have an Instagram profile – we are also able to track your networks (subscriptions) and connections as well as view the information (posts, etc.) you have posted there based on your interaction. In doing so, you may also disclose sensitive data pursuant to Art. 9 DSGVO.

If we do this, it will help us to learn more about our target customer group and to better tailor our advertising/products to you. We may mention and show your name, posts and interactions in a post (story, etc.), e.g. because your post or interaction serves as a review for us.

We use the option of a QR code provided by Instagram. This is a QR code. When you scan this, you are following our Instagram profile. When you scan this QR code, you submit the same data as when you follow our profile.

We would like to point out that the data can be viewed not only by us and Instagram, but also by their affiliated partners/companies as well as by all subscribers, contributors, commentators and other persons who click on our page or surf on pages of our subscribers, contributors and commentators.

The legal basis for the collection of the aforementioned data is Art. 6 para. 1 lit. a) DSGVO. The subscribers, contributors and commentators give their consent to the collection by voluntarily interacting with our fan page in connection with the acceptance of the terms of use of Instagram.

The data is usually removed when our site is deleted or temporarily removed when deactivated. Incidentally, you can delete your connections to us by deactivating the Like buttons again. Provided that we receive a revocation and we have the possibility to delete your data, we will implement the necessary steps for this. The revocation does not affect the lawfulness of the processing of your data based on your consent up to any revocation. The data will be stored in our Instagram statistics for a period of sometimes up to 24 months and then automatically deleted. This also applies in the following, unless we inform you otherwise in this regard. You can prevent the collection of your data by selecting appropriate privacy settings on Instagram, see https://www.instagram.com/accounts/privacy_and_security/.

Furthermore, you can send us messages via the social network. In this case, the personal data transmitted with the message (name/username; profile picture) will be stored; if you send us videos, voice messages or pictures, the information transmitted through this will also be processed by Instagram and possibly us (picture, voice, etc.). In this case, you agree that we may also contact you via this communication channel in order to answer your request. In this context, the data will not be passed on to third parties. The data will be used exclusively for processing the conversation. The legal basis for the processing of data transmitted in the course of sending a message is Art. 6 (1) lit. f) DSGVO. The legitimate interest lies in the processing of your request. If the message/contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) lit. b) DSGVO. The data from the message will be deleted when the respective conversation has ended. However, if the conversation aims at the conclusion of a contract, the data will be deleted according to the legal retention periods; this is usually 10 years. A revocation possibility exists, as far as the message does not serve the preparation or execution of a contract. Please note that in this case the request may not be processed.

4.2.3 Instagram-articles, stories, reels and guides

We also use Stories, Reels and Guides on Instagram. You can like, share, and comment on these and otherwise interact with us and others through them. Based on this, we collect and process the content you communicate (hashtags, messages, etc.) and the nature of the interactions. In each case, we process the content of any message as well as the time. The collection serves us to learn more about our fans and to better adjust our advertising/products to them.

Instagram Stories with Swipe Up feature: If you have a certain number of followers, we can add a swipe up link to Stories and post it. When you use this link, this is statistically recorded (reach, number of link clicks). The collection serves us to learn more about our fans and to better adjust our advertising/products to them.

Only we, as the creator, see your comments and reactions to the Stories. But we point out that the data is also processed by Instagram. We can also connect our Stories with various functions. Provided you use the features, we can see your details, opinions, etc.

We can integrate call-to-action buttons on our profile and in posts (call as well as SMS or email button). If you click on this, you can contact us via the selected media or perform other actions (e.g. reservations, etc.).

The legal basis for the collection of the aforementioned data is Art. 6 para. 1 lit. a) DSGVO. You give your consent to the collection by voluntarily interacting within the scope of our Story in connection with the acceptance of the terms of use of Instagram. The legal basis for the processing of data transmitted in the course of sending a contact is Art. 6 para. 1 lit. f) DSGVO. The legitimate interest lies in the processing of your request. If the contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b) DSGVO.

If we receive a revocation and have the option to delete your data (e.g. messages), we will implement the necessary steps for this. The revocation does not affect the lawfulness of the processing of your data based on your consent until a possible revocation. The data from a message will be deleted when the respective conversation has ended. However, if the conversation aims at the conclusion of a contract, the data will be deleted according to the statutory retention periods; this is usually 10 years. A revocation option exists insofar as the message does not serve the preparation or execution of a contract. Please note that in this case the request may not be processed.

4.3.4 Use of Instagram interfaces

If we use Instagram tools that interface with Instagram (e.g. use of the “Like” button, use of the Instagram API/pixel, etc. in the context of the store), information is passed on to Instagram, such as websites visited, purchases made and type of use of the services – regardless of whether you have an Instagram account or are logged in there.

Based on this, we collect and process

the way of interactions (likes),
information about transactions, i.e. how process data if you are redirected to our store via our fan page.

This serves to learn more about our target customer group and to better tailor our advertising/products to our customers. Furthermore, this serves to measure effectiveness and distribution of the ads as well as to promote products as effectively as possible on multiple channels.

When using the interface tools, the data is not only viewable by us and Instagram, but also, among others, by their affiliated partners/companies as well as, if applicable, by all subscribers, contributors, commenters and other persons who click on our page (e.g., in case of Like clicks).

You can prevent the collection of your data by, for example, making purchases directly via our website and not activating any Like buttons. You can delete your connections to us by, for example, deactivating the Like button again. If we receive a revocation and have the option to delete your data, we will implement the necessary steps for this. The revocation does not affect the legality of the processing of your data based on your consent until a possible revocation. For the rest, please contact the social network directly at the addresses listed in section 2.

4.3.5 Meta business suite

We use Meta Business Suite to create evaluations of advertising strategies, plan our advertising, create and maintain our store, place and evaluate ads, provide ad reports, manage our media library and page settings, schedule posts and bill advertising accounts, manage events, manage forms. In doing so, we may also define our target groups.

The legal basis for this is Art. 6 para. 1 lit. f) DSGVO, as this is the only way we are able to use the social network in an entrepreneurial way, plan budgets sensibly and define our customer strategy. The possible use of target group settings is based on Art. 6 para. 1 lit. f) DSGVO, as this allows us to select only those interested parties for whom we are potentially interesting and other persons are not even bothered about this in the first place. This is in our interest as well as in the interest of all persons. In all other respects, the same applies as described in sections 4.2.1 and 4.2.2.

4.3.6 Instagram monetization features

We use Instagram’s monetization features to tag business partners. We may receive compensation for this (e.g., for branded content). We point out that in the case of interaction with monetized content, all data we receive is also transmitted to our business partners. We are contractually obligated to do so. Our respective business partner can be seen from the advertisement. The legal basis for this is Art. 6 para. 1 lit. b) DSGVO. In all other respects, the same applies as described in sections 4.2.1 and 4.2.2.

4.3.7 Instagram ads

We use the opportunity for promotion (Instagram Ads) with the goal of getting more profile views, more website visitors, or more messages. The ads are targeted to specific audiences in terms of location, interests, age and gender. Instagram automatically selects the target group based on people who are similar to our subscribers; we can (also) set the target group. The legal basis for the collection of the aforementioned data is Art. 6 (1) a) DSGVO. You give your consent to the collection by accepting the terms of use of the respective social network and the posts of these based on them. We point out that the data can be viewed not only by us and Instagram, but also by their affiliated partners/companies. You can prevent the collection of your data by, for example, not going to our website via Instagram and not following any links. The data is usually removed when our account is deleted or temporarily removed when deactivated. If we receive a revocation and have the option to delete your data (e.g. comments, etc.), we will implement the necessary steps for this. The revocation does not affect the lawfulness of the processing of your data based on your consent up to any revocation. Alternatively, we ask you to contact the social network directly at the addresses mentioned in section 2. You can also partially prevent the collection of your data by selecting appropriate privacy settings, see https://www.instagram.com/accounts/privacy_and_security/.

4.2 Xing

4.2.1 Interactions, statistics, news

We ourselves use functions that the social network makes available to us as well as other information that you provide when you visit our fan page or interact with us via this. We collect and process the following data, among others, as a result: Publicly viewable contact data of other users; Reactions of other users to posts and/or comments posted/shared/annotated by us ; Notifications from Xing about birthdays, etc.; Anonymized statistical information about visitors; Messages (especially about who read them and when); Contact paths through which you may be connected.

Insofar as we create surveys and you participate in them, we also learn your response results.

We would like to point out that – insofar as you yourself have a Xing profile – we are also able, based on your interaction, to track your networks and connections as well as to view the information you have posted there (photos, posts, information about you personally, etc.). In doing so, you may also disclose sensitive data pursuant to Art. 9 DSGVO. If we collect this data, we will only collect and evaluate it anonymously without the possibility of drawing conclusions about a person.

We use the data to find out which articles and information our visitors interact with (or not). With the help of the results, we can build up and expand our target group and provide them with interesting events, information, etc. that are appropriate for their target group and optimize our content. Furthermore, we recognize which posts have received the most attention. In addition, we would like to know which visitors view our profile and how it came about. This also serves us to learn more about our target customer group and to better tailor our advertising/products to our customers.

You can prevent the collection of your data by selecting appropriate privacy settings, see https://www.xing.com/settings.

We would like to point out that the data can be viewed not only by us and Xing, but also by their affiliated partners/companies as well as by all subscribers, contributors, commentators and other persons who click on our site or surf on pages of our subscribers, contributors and commentators.

Insofar as this is purely statistical and thus anonymous data, the legal basis is Art. 89 DSGVO. Further legal basis for the collection of the aforementioned data is Art. 6 para. 1 lit. a) DSGVO. You give your consent to the collection by accepting the terms of use of the respective social network and the posts of these based on them.

Deletion: The statistical data is deleted after 90 days (information about visitors). The remaining data is usually removed when our site is deleted or temporarily removed when deactivated. Incidentally, you can delete your connections to us by deactivating the Like buttons again. Provided that we receive a revocation and we have the possibility to delete your data, we will implement the necessary steps for this. The revocation does not affect the legality of the processing of your data carried out on the basis of your consent up to any revocation. In addition, for some details, the user can set the extent to which they should be visible to others.

Furthermore, you can send us messages via the social network. In this case, the personal data transmitted with the message (name/username; profile picture, message) will be stored. In this case, you agree that we may also contact you via this communication channel in order to answer your request. In this context, the data will not be passed on to third parties. The data will be used exclusively for processing the conversation. The legal basis for the processing of data transmitted in the course of sending a message is Art. 6 para. 1 p.1 lit. f) DSGVO. The legitimate interest lies in the processing of your request. If the message/contact is aimed at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 p. 1lit. b) DSGVO. The data from the message will be deleted when the respective conversation has ended. However, if the conversation aims at the conclusion of a contract, the data will be deleted according to the legal retention periods; this is usually 10 years. A revocation option exists insofar as the message does not serve the preparation or execution of a contract. Please note that in this case the request may not be processed.

4.3.2 Onlyfy by Xing

We use Onlyfy by Xing for recruiting. Xing provides us with various tools for this purpose:

EmployerBranding profile (company presence on 2 portals with statistics tool)

The advertisements we place there are suggested by Xing as appropriate for the members and linked to contacts. We have no influence on this. The ads are analyzed automatically by Xing. This provides us with information about click numbers, demographic visitor information and the interested parties who best match the job requirements. If you visit a job ad, this is recorded statistically.

We would like to point out that due to the linking of OnlyFy with Xing and kununu, the data is processed both at New Work Austria kununu onlyfy GmbH and at New Work SE.

If you apply to us, we process the information that we receive from you as part of the application process, i.e. information from the documents sent along, your mail address, Xing data and the information contained therein.

If you send us a photo of yourself, we may be able to deduce information about your racial or ethnic origin from it. We would like to point out that we do not explicitly examine the photos for such information, nor for biometric data, nor for health data, but that sometimes indications arise merely from looking at the picture. If you do not wish to provide us with such information, please do not send us a photograph.

Your data will initially be processed exclusively for the purpose of carrying out the application procedure. If your application is successful, the data will become part of the personnel file and may be used to implement and terminate the employment relationship. If we are currently unable to offer you employment, we will process your data in order to defend ourselves against any legal claims, in particular due to an alleged disadvantage in the application process. Insofar as you receive reimbursements of costs, the corresponding accounting records are processed to fulfill the retention obligations under commercial and tax law. The legal basis for data processing is therefore Art. 6 para. 1 lit. b) DSGVO, insofar as the data processing serves to decide on the establishment of an employment relationship and insofar as the data are then included in the employment relationship. If the storage serves to secure claims, the legal basis is Art. 6 para. 1 lit. f) DSGVO. The legitimate interest here is the receipt of evidence documents for possible defense. We process information and documents that are not required for the aforementioned purposes on the basis of your implied consent pursuant to Art. 6 (1) a) DSGVO, which you have given us by sending us the information. Insofar as you receive reimbursements from us, the legal basis is Art. 6 para. 1 lit. c) DSGVO.

The evaluation data is made available to us for 30 days. We store the data required for the successful application and for the employment relationship until the end of the employment relationship and for up to 3 years thereafter. We continue to process the data relating to an application in respect of which we had to decide to reject the application for a period of 6 months after sending the rejection in order to safeguard our legitimate interests. If a claim is made against us in the context of a lawsuit, we store the data until its conclusion. This also applies accordingly to data received voluntarily. Insofar as you receive reimbursements of costs, the corresponding accounting documents will be stored for the purpose of fulfilling the retention obligations under commercial and tax law up to a maximum of March 31 of the eleventh calendar year after payment, and in the case of commercial and business letters and other tax-relevant documents, of the seventh calendar year after their creation.

The legal basis for the statistics is Art. 6 (1) lit. f) DSGVO, as this provides us with valuable information about people interested in our recruiting measures.

If you have given your consent to the processing of the data, you have the right to revoke this consent at any time. The revocation does not affect the lawfulness of the processing of your data carried out on the basis of your consent up to any revocation.

4.3 YouTube

We post videos on our YouTube channel. To evaluate these videos, we use the respective statistical evaluations that YouTube makes available to us. This we can currently not turn off or modify. We collect the following data, among others, as a result: Number of views and subscribers, access sources, interactions, target group information (number of viewers; times, age gender, countries, languages, etc.) We receive these evaluations anonymized in each case.

Furthermore, we collect data in the context of our fans, our non-fans or those people who have commented or shared something. For this purpose, we learn the name (or just the user name), (if available) the profile picture, the time and the rating and, in turn, the information provided publicly by the persons, especially about their own YouTube activities. Provided that you subscribe to our channel, you will receive a notification from YouTube about new videos posted by us and also see them in your subscription field. Only through the data we learn which measures are worthwhile on our part and whether our videos are received by the audience. This allows us to optimize our content.

The legal basis for the collection of the aforementioned data is Art. 6 para. 1 lit. a) DSGVO. You give your consent to the collection by accepting the terms of use of the respective social network and the posts of these based on them.

The statistical data as well as the comments are collected and processed by us. In addition, this data is processed by the social network and partners/companies etc. associated with them. The public comments and ratings of a video as well as the subscription to our channel/video are viewable not only by us and the social network and their associated partners/companies, but also by all subscribers, contributors, commenters and other people who click on our video.

We may further cause our videos to be played directly to our target audience based on audience selection. However, the allocation is made by YouTube. The legal basis for this is Art. 6 para. 1 lit. f) DSGVO, as this is the only way we can determine whether the effort involved in creating such a video is also worthwhile and in order to be able to design our videos in a more target-customer-oriented manner, if necessary.

The statistical, anonymized data is retrievable according to YouTube’s unchangeable settings for the duration specified by YouTube. The remaining interaction data is irrevocably removed with the deletion of our page.

As already communicated, the statistical data is collected without there being any opt-out option by us at the moment. For this reason, we are unable to honor your right of objection for technical reasons. We therefore ask you to contact the social network directly at the addresses given in item 2. Furthermore, there is an objection option with regard to the comments as follows: We can delete comments upon request, but also if we judge their content to be illegal. With regard to further interactions, we ask you to contact YouTube itself, as we also have no influence on this. Furthermore, if you do not wish your data to be collected, you can set your privacy accordingly at https://myaccount.google.com/privacycheckup?utm_source=pp&utm_medium=Promo-in-product&utm_campaign=pp_intro&hl=de.

4.5 LinkedIn

4.5.1 Statistics

We ourselves use the respective statistical evaluations that the social network makes available to us. We cannot turn this off or modify it at the moment. As a result, we collect the following data:

In the area of our personal page we collect statistics as follows: Number of profile visitors, companies and industries of visitors, job titles of people.
Regarding our company page, we collect statistics as follows:
Regarding visitors in general: page views, visitors, clicks on buttons, demographic data (areas of activity, location, career level, company size, industry) and their activities (requests, comments, mentions, posts, shares, reactions). The retention period is 30 days.
To Updates: Impressions, clicks, reactions, comments, shares, engagement rate (The number of interactions plus the number of clicks and followers gained, divided by the number of impressions), followers; for videos, still the minutes viewed and the number of viewers, if viewed for more than 3 seconds. The retention period is 1 year.
For followers: number; new ones added over a period of time; data on how followers were acquired via ads and sponsored content, list of current followers, demographic data statistically (location, field of activity, career level, industry, company size). The retention period is 1 year.

Data is regularly collected when you are logged in to LinkedIn when you visit our profile. Whether someone is logged in to LinkedIn is determined with the help of cookies. Without login, most actions are not possible.

Purpose: We use the data so that we can learn which posts you interact with (or not). With the help of the results, we can build up and expand our target group and provide them with interesting information, etc. that is appropriate to their target group, and optimize our content and gain more followers. Furthermore, we recognize which posts have received the most attention. In addition, we would like to know which visitors view our profile and how it came about. Also, this serves us to learn more about our target customer group and to better adjust our advertising/products to our customers. Through the statistics, we can see which posts have received the most attention and how we target the content.

The legal basis for the collection of the above data by us for statistical purposes is Art. 89 DSGVO. Further legal basis for the collection of the aforementioned data is Art. 6 para. 1 lit. a) DSGVO. You give your consent to the collection by accepting the terms of use of the respective social network and the posts of these based on them.

4.4.2 Interactions, messages, invitations

Furthermore, we collect data in the context of our followers or those persons who have interacted with our site (network, like, comment, share, etc.). For this purpose, we learn the name (if applicable, the user name of the account), the profile picture and, in turn, the information provided publicly by the persons. Through the comments, we furthermore learn something about the opinion or you yourself. We would like to point out that – insofar as you yourself have a LinkedIn profile – we are also able, based on your interaction, to track your networks (groups, connected pages) and connections, as well as to view the information you have posted there (photos, posts, information about you personally, etc.). In doing so, you may also disclose sensitive data pursuant to Art. 9 DSGVO. If we collect this data, we will only collect and evaluate it anonymously without the possibility of drawing conclusions about a person.

We use the data to find out which articles and information you interact with (or not). The results help us build and grow our audience, provide them with events, information, etc. that are relevant to their audience, and optimize our content. Furthermore, we recognize which posts have received the most attention. In addition, we would like to know which visitors view our profile and how it came about. Also, this serves us to learn more about our target customer group and better tailor our advertising/products to you.

LinkedIn Stories with Swipe Up feature: when we post stories, we may include them with a swipe up link. When you use this link, this is statistically collected (reach, number of link clicks). The collection helps us to learn more about our fans and to better adjust our advertising/products to them.

The data can be viewed not only by us and the social network and their associated partners/companies, but also by all subscribers, fans, contributors, commentators and other persons who click on our page or surf on pages of our subscribers, fans, contributors and commentators.

Furthermore, you can send us messages via the social network. In this case, the personal data transmitted with the message (name/user name; profile picture, time of the message) will be stored. In this case, you agree that we may also contact you via this communication channel in order to answer your request. In this context, the data will not be passed on to third parties. The data will be used exclusively for processing the conversation. The legal basis for the processing of data transmitted in the course of sending a message is Art. 6 para. 1 p.1 lit. f) DSGVO. The legitimate interest lies in the processing of your request. If the message/contact is aimed at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 p. 1 lit. b) DSGVO. The data from the message will be deleted when the respective conversation has ended. However, if the conversation aims at the conclusion of a contract, the data will be deleted according to the statutory retention periods; this is usually 10 years. A revocation option exists insofar as the message does not serve the preparation or execution of a contract. Please note that in this case the request may not be processed.

You can prevent the collection of your data by declining our invitations/messages and not interacting. The data is usually removed upon deletion of our account or temporarily removed upon deactivation. Incidentally, you can delete your connections to us by deactivating the interaction buttons again. If we receive a revocation and have the option to delete your data (for example, comments on our pinboard, etc.), we will implement the necessary steps for this. The revocation does not affect the legality of the processing of your data based on your consent until a possible revocation. Alternatively, we ask you to contact the social network directly at the addresses mentioned in item 2, as we cannot trace which data originates from you due to the extensive anonymization of the data. You can also partially prevent the collection of your data by selecting appropriate privacy settings on LinkedIn, see https://www.linkedin.com/psettings/.

5. DATA SUBJECT RIGHTS TOWARDS US

In the following, we would like to inform you of your rights. Please note that we can unfortunately only provide limited information, because the data collected by the social network is received anonymously, i.e. we only collect anonymized data. Therefore, we cannot assign a request to a person. However, we can assign your identity and guarantee your rights insofar as we collect your data directly, e.g. based on a request, a like, etc.

5.1 Rights towards us

You have the right to request information from us at any time about the personal data we have stored about you (Art. 15 DS-GVO). This also concerns the recipients or categories of recipients to whom this data is passed on and the purpose of the storage.

In addition, you have the right to demand the correction of incorrect or incomplete data under the conditions of Art. 16 DS-GVO and/or the deletion of stored data under the conditions of Art. 17 DS-GVO. The deletion is only possible insofar as the processing is not necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the assertion, exercise or defense of legal claims.

You have the right to demand the restriction of processing under the conditions of Art. 18 DS-GVO, insofar as you dispute the accuracy of your data, the processing is unlawful and we refuse to delete it, you need the data to assert legal claims or insofar as you have objected to the processing.

Furthermore, you may request data transfer at any time under the conditions of Art. 20 DS-GVO.

Insofar as the collection of data is based on consent, you may revoke your consent to us at any time. As a result, we may not further process this data for the future.

In case of processing of personal data for the performance of tasks in the public interest (Art. 6 para. 1 sentence 1 lit. e DS-GVO) or for the performance of legitimate interests (Art. 6 para. 1 sentence 1 lit. f DS-GVO), you may object to the processing of the personal data concerning you at any time with effect for the future. In the event of an objection, we must refrain from any further processing of your data for the aforementioned purposes, unless,

there are compelling legitimate grounds for processing which override your interests, rights and freedoms, or
processing is necessary for the assertion, exercise or defense of legal claims

For more detailed information, please refer to the full text of the GDPR.

Please direct all requests for information, information requests, revocations or objections to data processing by e-mail to our data protection officer as per item 2 or to the responsible person named under item 2. Furthermore, you have the option of complaining to the competent supervisory authority about matters relating to data protection law. The authority responsible for us is the Bavarian State Office for Data Protection Supervision, Promenade 27, 91522 Ansbach.

In addition, we refer below to the specifics of the respective social networks:

5.2 Facebook

In accordance with the agreement between Facebook Ireland and us regarding the processing of Insights data, Meta Platforms Ireland Ltd. is responsible for providing information on the processing of the aforementioned Page Insights in the event of an inquiry. We will therefore forward your request with name and e-mail address to Meta Platforms Ireland Ltd., which will assist us in answering or implementing the request.

Meta Platforms Ireland Ltd. has also assumed primary responsibility for the processing of the Insights data in accordance with § 2 Para. 1 and has assured to fulfill all obligations regarding the processing of the data, in particular the data subject rights. Accordingly, further data subject rights to rectification, portability, deletion and objection must also be asserted with Meta Platforms Ireland Ltd (see section 2). The Irish Data Protection Commission, cf. https://www.dataprotection.ie/, has been declared competent for complaints against Meta Platforms Ireland Ltd. and us regarding the processing of data for Site Insights. Insofar as the legal basis of the data processing is Art. 6 para. 1 lit. c) or e) DSGVO, the supervisory authority mentioned in section 5.1 is responsible for complaints.

5.3 Other networks

In addition, the social networks have not taken any explicit implementation measures for the data protection rights of the data subjects, so that we can currently only advise you to assert the following rights against the social network. As far as it concerns data that you disclose to us, we will also implement this as far as this is technically possible for us.

6. PROCESSING OF DATA BY THE SOCIAL NETWORK AND FORWARDING DATA

The social network collects various information from you. Unfortunately, we cannot tell you for what purposes, to what extent, for how long, in what way and to which recipients the data is processed by the respective social network. We therefore refer you to the privacy policy of the respective network with regard to the data and the purposes for which the data is collected, as well as with regard to the recipients of this data.

The transfer of data thus also takes place to partners and companies in countries outside the European Union, in particular the USA.

The rights of the GDPR are also available to you vis-à-vis the social network:

You have the right to request information about the personal data stored about you (Art. 15 DS-GVO) at any time. This also concerns the recipients or categories of recipients to whom this data is passed on and the purpose of the storage.
In addition, you have the right to demand correction under the conditions of Art. 16 DS-GVO and/or deletion under the conditions of Art. 17 DS-GVO and/or restriction of processing under the conditions of Art. 18 DS-GVO.
Furthermore, you may request data transfer at any time under the conditions of Art. 20 DS-GVO.
For more detailed information, please refer to the full text of the DS-GVO.
In the case of processing of personal data for the performance of tasks in the public interest (Art. 6 para. 1 sentence 1 lit. e DS-GVO) or for the performance of legitimate interests (Art. 6 para. 1 sentence 1 lit. f DS-GVO), you may object to the processing of the personal data concerning you at any time with effect for the future. In the event of an objection, any further processing of your data for the aforementioned purposes shall be refrained from, unless there are compelling legitimate grounds for processing which override your interests, rights and freedoms, or the processing is necessary for the assertion, exercise or defense of legal claims.

Please send all requests for information, information requests, revocations or objections to data processing by e-mail to the address of the social network mentioned in Section 2. Furthermore, you have the option of complaining about data protection issues to the competent supervisory authority named there. These are also named – as far as known – under item 2.

Furthermore, you can revoke your consent to the processing of certain data or object to this in the social networks by making the appropriate settings. For this, however, we refer you to the providers:

6.1 Facebook

You can find more information on data protection at http://de-de.facebook.com/about/privacy and https://www.facebook.com/policies/cookies. However, since Facebook also stores information about the end devices of the users, Facebook is able to assign IP addresses to individual users. In addition, Facebook is able to track that you have visited our site and how you have used it.

Meta Platforms Ireland Ltd. has its headquarters in the USA. This means that data is also transmitted to the USA. The transmission there is currently critical due to the ruling of the European Court of Justice. We have made various agreements with Meta regarding Facebook for the protection of personal data,

Addendum for data controllers (joint responsibility agreement pursuant to Art. 26 (1) p. 3 of the GDPR), see https://www.facebook.com/legal/controller_addendum.
Information on Site Insights (shared responsibility agreement pursuant to Art. 26 (1) p. 3 of the GDPR regarding Insights data), see https://www.facebook.com/legal/terms/page_controller_addendum.
Data processing conditions (order processing agreement pursuant to Art. 28 DSGVO), available at https://www.facebook.com/legal/terms/dataprocessing/update.
https://www.facebook.com/legal/EU_data_transfer_addendum.

Settings and objections to the use of data for advertising purposes are possible within the profile settings at https://www.facebook.com/settings?tap=ads.

6.2 Instagram

You can find more detailed information on data protection at https://help.instagram.com/519522125107875 and https://help.instagram.com/1896641480634370?ref=ig. In addition, we would like to point out the following:

Instagram as part of Meta Platforms Ireland Ltd. has its registered office in the USA. Thus, the transmission of data also takes place in the USA. The transfer there is currently critical due to the ruling of the European Court of Justice. We have concluded a contract with Meta regarding Instagram in accordance with the standard contractual clauses of the European Commission.

Settings and objections to the use of data for advertising purposes are possible within the profile settings at https://www.instagram.com/accounts/privacy_and_security/.

6.3 Xing

You can find more information on data protection at https://privacy.xing.com/de/datenschutzerklaerung.

Settings and objections to the use of data for advertising purposes are possible within the profile settings at https://www.xing.com/settings.

6.3 YouTube

For more information on data protection, please visit https://policies.google.com/privacy?hl=de DSE and https://policies.google.com/technologies/product-privacy?hl=de.

Google is based in the USA. This means that data is also transmitted to the USA. The transfer there is currently critical due to the ruling of the European Court of Justice. We have entered into the following agreements with Google for the protection of personal data:

https://business.safety.google/adsprocessorterms/sccs/.

Settings and objections to the use of data for advertising purposes are possible within the profile settings at https://myaccount.google.com/privacycheckup?utm_source=pp&utm_medium=Promo-in-product&utm_campaign=pp_intro&hl=de.

You can find more information on data protection at https://policies.google.com/privacy?hl=de DSE and under https://policies.google.coYou can find more information on data protection at https://policies.google.com/privacy?hl=de DSE and at https://policies.google.com/?hl=de and https://policies.google.com/ technologies / product-privacy? hl = de.

6.4 LinkedIn

For more information on data protection, please visit https://de.linkedin.com/legal/privacy-policy and https://de.linkedin.com/legal/cookie-policy and https://de.linkedin.com/legal/l/dpa.

LinkedIn is based in the USA. This means that data is also transferred to the USA. The transfer there is currently critical due to the ruling of the European Court of Justice. We have reached the following agreements with LinkedIn for the protection of personal data: https://de.linkedin.com/legal/l/dpa

Settings and objections to data use for advertising purposes are possible within the profile settings at https://www.linkedin.com/psettings/.

7. CHANGES TO THE PRIVACY POLICY

We reserve the right to change our privacy practices and this policy to conform to changes in relevant laws, regulations, case law, or data protection authority guidance, or to better meet your needs. Possible changes to our data protection practices will be announced here. Please note the current version date of the privacy policy.