Privacy policy

Introduction

With the following data protection declaration, I would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that I process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by me, both in the context of the provision of my services and in particular on my websites, in mobile applications and within external online presences, such as my social media profiles (hereinafter collectively referred to as “online offer”).

The terms used are not gender-specific.

Status: 5 June 2022

Table of contents

Responsible

Leonhard Rank
Eintrachtstrasse 54
50668 Cologne
Germany

Authorised representatives: Leonhard Rank

Email address: info@leonhard-rank.de

Phone number: +49 176 31184829

Imprint: https://leonhard-rank.de/en/imprint/

Overview of processing

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

Types of data processed

  • Contact details
  • Content data
  • Usage data
  • Meta / Communication data

Categories of persons concerned

  • Communication partners
  • Users

Purposes of processing

  • Provision of contractual services and customer service
  • Contact requests and communication
  • Reach measurement
  • Managing and responding to enquiries
  • Feedback
  • Marketing
  • Profiles with user-related information
  • Provision of our online services and user experience
  • Information technology infrastructure

Relevant legal basis

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 provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO) – The data subject has given his/her consent to the processing of personal data relating to him/her for a specific purpose or purposes.
  • Performance of a contract and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures taken at the data subject’s request.
  • Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO) – Processing is necessary for the purposes of the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

In addition to the data protection regulations of the General Data Protection Regulation, national regulations on data protection apply in Germany. These include, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, the processing for other purposes and the transmission and automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships as well as the consent of employees. Furthermore, data protection laws of the individual federal states may apply.

Safety measures

We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, 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.

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 access to, input of, disclosure of, assurance of availability of and segregation of the data. We also have procedures in place to ensure the exercise of data subjects’ rights, the deletion of data and responses to data compromise. Furthermore, we already take the protection of personal data into account in the development or selection of hardware, software as well as 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 complete IP address is not necessary, the IP address is shortened (also referred to as “IP masking”). In this process, the last two digits or the last part of the IP address after a full stop are removed or replaced by wildcards. The shortening of the IP address is intended to prevent or make it considerably more difficult to identify a person by their IP address.

SSL encryption (https): In order to protect your data transmitted via our online offer, we use SSL encryption. You can recognise such encrypted connections by the prefix https:// in the address line of your browser.

Data deletion

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose).

If the data are not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.

Our data protection notices may also contain further details on the retention and deletion of data which have priority for the respective processing operations.

Use of cookies

Cookies are small text files or other memory 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 basket in an e-shop, the contents called up or the functions used in an online offer. Cookies can also be used for various purposes, e.g. for the purpose of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows.

Consent notices: We use cookies in accordance with the law. We therefore obtain prior consent from users, except where this is not required by law. In particular, consent is not required if the storage and reading of information, i.e. including cookies, is absolutely necessary in order to provide the user with a telemedia service (i.e. our online offer) expressly requested by the user. The revocable consent is clearly communicated to the users and contains the information on the respective cookie use.

Notes on legal bases under data protection law: The legal basis under data protection law on which we process users’ personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their declared consent. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and improvement of its usability) or, if this is done in the context of the performance of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We explain the purposes for which we process the cookies in the course of this data protection declaration or as part of our consent and processing procedures.

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

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed their end device (e.g. browser or mobile app).
  • Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user data collected with the help of cookies can be used to measure reach. Unless we provide users with explicit information about the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and that they can be stored for up to two years.

General information on revocation and objection (opt-out): Users can revoke the consent they have given at any time and also file an objection to processing in accordance with the legal requirements in Art. 21 DSGVO (further information on the objection is provided within the scope of this data protection declaration). Users can also declare their objection using the settings of their browser.

Cookie settings/ objection option:

Webtoffee GDPR Cookie Consent Plugin

https://www.webtoffee.com/terms-conditions/

https://www.webtoffee.com/privacy-policy/

Further guidance on processing operations, procedures and services:

  • Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users to the use of cookies, or to the processing and providers mentioned in the cookie consent management procedure, can be obtained and managed and revoked by users. The declaration of consent is stored in order not to have to repeat the request and to be able to prove the 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 with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) and the browser, system and end device used.

Provision of the online offer and web hosting

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

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

  • Types of data processed: Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta/communication data (e.g. device information, IP addresses)
  • Data subjects: Users (e.g. website visitors, users of online services)
  • Purposes of processing: provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.).)
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO)


Further guidance on processing operations, procedures and services:

  • E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of recognising SPAM. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption procedure is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
  • Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of the access, the amount of data transferred, notification of successful access, 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 may be used on the one hand for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the utilisation of the servers and their stability;
    Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO);
    Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the final clarification of the respective incident.
  • STRATO: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacities)Service provider: STRATO AG, Pascalstraße 10,10587 Berlin, Germany
    Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO)
    Website: https://www.strato.de
    Privacy policy: https://www.strato.de/datenschutz
    Order processing contract: concluded with provider

Contact and enquiry management

When contacting us (e.g. via contact form, email, telephone or via social media) as well as in the context of existing user and business relationships, the information of the inquiring persons is processed insofar as this is necessary to answer the contact enquiries and any requested measures.

The answering of contact requests as well as the administration of contact and request data in the context of contractual or pre-contractual relationships is carried out to fulfil our contractual obligations or to answer (pre-)contractual requests and otherwise on the basis of the legitimate interests in answering the requests and maintaining user or business relationships.

  • Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partners.
  • Purposes of processing: provision of contractual services and customer service; contact requests and communication; managing and responding to requests; feedback (e.g. collecting feedback via online form); providing our online offer and user experience.
  • Legal basis: Contractual performance and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Further guidance on processing operations, procedures and services:

  • Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context in order to process the communicated request. For this purpose, we process personal data in the context of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfilment and otherwise on the basis of our legitimate interests as well as the interests of the communication partners in responding to the concerns and our statutory retention obligations;
  • Legal bases: Contractual fulfilment and pre-contractual enquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Web analysis, monitoring and optimisation

Web analytics (also referred to as “reach measurement”) is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of the reach analysis, we can, for example, recognise at what time our online offer or its functions or contents are most frequently used or invite re-use. Likewise, we can understand which areas need optimisation.

In addition to web analysis, we may also use test procedures, for example, to test and optimise different versions of our online offer or its components.

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

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

  • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors); profiles with user-related information (creation of user profiles).
  • Security measures: IP masking (pseudonymisation of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO).

Further guidance on processing operations, procedures and services:

  • Google Analytics 4: We use Google Analytics to perform user analysis based on a pseudonymous user identification number. This identification number does not contain any unique data, such as names or email addresses. It is used to assign analysis information to an end device in order to recognise which content users have accessed within one or various usage processes, which search terms they have used, have accessed again or have interacted with our online offer. The time of use and its duration are also stored, as well as the sources of the users referring to our online offer and technical aspects of their end devices and browsers. In the process, pseudonymous profiles of users are created with information from the use of various devices, whereby cookies may be used. In Analytics, higher level geographic location data is provided by collecting the following metadata based on IP search: “city” (and the derived latitude and longitude of the city), “continent”, “country”, “region”, “subcontinent” (and the ID-based equivalents). To ensure the protection of user data in the EU, Google receives and processes all user data via domains and servers within the EU. Users’ IP addresses are not logged and are truncated by the last two digits by default. The shortening of the IP address takes place on EU servers for EU users. In addition, all sensitive data collected from users in the EU is deleted before it is collected via EU domains and servers.Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
    Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO)
    Website: https://marketingplatform.google.com/intl/de/about/analytics/
    Privacy Policy: https://policies.google.com/privacy
    Order processing contract: https://business.safety.google/adsprocessorterms/
    Standard contractual clauses (guaranteeing the level of data protection in the case of processing in third countries): https://business.safety.google/adsprocessorterms
    Possibility of objection (opt-out): https://tools.google.com/dlpage/gaoptout?hl=de
    Settings for the display of advertisements: https://adssettings.google.com/authenticated
    Further information: https://privacy.google.com/businesses/adsservices (types of processing and data processed).

Presence in social networks (social media)

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

We would like to point out that user data may be processed outside the European Union. This may result in risks for the users because, for example, it could make it more difficult to enforce the rights of the users.

Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behaviour and resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users’ computers, in which the usage behaviour and the interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).

For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users’ data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

  • Types of data processed: contact data (e.g. e-mail, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses)
  • Data subjects: Users (e.g. website visitors, users of online services)
  • Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form); marketing
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO)

Further guidance on processing operations, procedures and services:

  • Instagram:
    Social networkService provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA
    Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO)
    Website: https://www.instagram.com
    Privacy policy: https://instagram.com/about/legal/privacy
  • Facebook pages:
    Profiles within the Facebook social network – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (known as a “Fan Page”). This data includes information about the types of content users view or interact with, or the actions they take (see under “Things you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see under “Device Information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Privacy Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, called “Page Insights”, to Page operators to provide them with insights into how people interact with their Pages and the content associated with them. We have entered into a specific agreement with Facebook (“Page Insights Information”, https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular which security measures Facebook must observe and in which Facebook has agreed to fulfil the rights of data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). The rights of users (in particular to information, deletion, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information on Page Insights”. (https://www.facebook.com/legal/terms/information_about_page_insights_data)Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland
    Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO)
    Website: https://www.facebook.com
    Privacy Policy: https://www.facebook.com/about/privacy
    Standard contractual clauses (guaranteeing the level of data protection in the case of processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum
    Further information: Shared responsibility agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data

Amendment and update of the privacy policy

We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organisations in this data protection declaration, please note that the addresses may change over time and please check the information before contacting us.

Rights of the data subjects

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

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to revoke any consent given at any time.
  • Right to information: You have the right to request confirmation as to whether data in question is being processed and to information about this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: You have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified.
  • Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data concerning you be erased without delay or, alternatively, to request restriction of the processing of the data in accordance with the law.
  • Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to demand that it be transferred to another person responsible.
  • Complaint to the supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the requirements of the GDPR.

Definitions of terms

This section provides you with an overview of the terms used in this privacy policy. Many of the terms are taken from the law and defined above all in Art. 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to help you understand them. The terms are sorted alphabetically.

  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, 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 that consists of using such personal data to analyse, evaluate or to predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information concerning demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include visitors’ behaviour or interests in certain information, such as website content. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to recognise returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Controller: “Controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and encompasses virtually any handling of data, be it collection, analysis, storage, transmission or erasure. 

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