This data protection declaration explains to you the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) as part of the provision of our services and within our online offer and the websites, functions and contents connected with it as well as external online presences, e.g. our social media profile (hereinafter jointly referred to as “online offer”). With regard to the terms used, such as “processing” or “person responsible”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Person in charge
webdevtrust GmbH
Mauerstrasse 1a
40477 Düsseldorf
Germany
E-mail: info@webdevtrust.com
Managing Director: Christian Behrends
Legal Notice: https://webdevtrust.com/legal/
Types of data processed
- Inventory data (for example, personal master data, names or addresses).
- Contact details (e.g., e-mail, telephone numbers).
- Content data (e.g., text input, photographs, videos).
- Usage data (e.g., visited websites, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).
Categories of persons concerned
- Visitors and users of the online offer (hereinafter referred to as “users”).
Purpose of processing
- Provision of the online offer, its functions and contents.
- Response to contact requests and communication with users.
- Security measures.
- Range measurement/marketing.
Terms used
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more special features that express the physical, physiological, genetic, psychological, economic, cultural or social identity of that natural person.
“processing” means any operation or series of operations carried out with or without the aid of automated procedures in connection with personal data. The term goes a long way and covers practically every handling of data.
“pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
“Profiling” means any automated processing of personal data consisting in the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to the work performance, economic situation, health, personal preferences, interests, reliability, behaviour, location or relocation of that natural person.
Responsible” means the natural or legal person, authority, institution or other body that alone or together with others decides on the purposes and means of processing personal data.
“processor” means a natural or legal person, authority, institution or other body processing personal data on behalf of the controller.
Applicable legal bases
In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. For users from the scope of the General Data Protection Regulation (GDPR), i.e. from the EU and the EEC, the following applies, unless the legal basis is specified in the data protection declaration:
The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR;
The legal basis for the processing for the fulfilment of our services and the execution of contractual measures as well as the answering of inquiries is Art. 6 para. 1 lit. b GDPR;
The legal basis for the processing for the fulfilment of our legal obligations is Art. 6 para. 1 lit. c GDPR;
In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) GDPR serves as the legal basis.
The legal basis for the processing required to carry out a task in the public interest or in the exercise of official authority assigned to the person responsible is Art. 6 para. 1 lit. e GDPR.
The legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR.
The processing of data for purposes other than those for which they were collected shall be governed by the provisions of Art. 6 para. 4 GDPR.
The processing of special categories of data (in accordance with Art. 9 para. 1 GDPR) is governed by the provisions of Art. 9 para. 2 GDPR.
Safety precautions
We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, implementation costs and the nature, scope, circumstances and purposes of processing as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons.
Such measures shall in particular include ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, transmission, security of availability and its separation. Furthermore, we have established procedures to ensure the exercise of rights of data subjects, deletion of data and reaction to endangerment of data. Furthermore, we already consider the protection of personal data during the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly presettings.
Cooperation with contract processors, jointly responsible persons and third parties
If we disclose data to other persons and companies (contract processors, jointly responsible persons or third parties) within the scope of our processing, transfer them to them or otherwise grant them access to the data, this shall only take place on the basis of a legal permission (e.g. if a transfer of the data to third parties, such as to payment service providers, is necessary for contract fulfilment), if users have consented, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we disclose, transfer or otherwise grant access to data to other companies in our group of companies, this shall be done in particular for administrative purposes as a legitimate interest and in addition on a basis in accordance with legal requirements.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to other persons or companies, this only takes place if it occurs in order to fulfil our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or leave the data in a third country only if the legal requirements are met. This means, for example, that processing is carried out on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to the EU (e.g. for the USA by the “Privacy Shield”) or compliance with officially recognized special contractual obligations.
Rights of data subjects
You have the right to request confirmation as to whether the data concerned are being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements.ie also have the right to file a complaint with the competent supervisory authority in accordance with the legal requirements.
In accordance with legal requirements, you have the right to request the completion of the data concerning you or the correction of incorrect data concerning you.
In accordance with legal requirements, you have the right to demand that the relevant data be deleted immediately or, alternatively, to demand a restriction on the processing of the data in accordance with legal requirements.
You have the right to request that the data concerning you that you have provided to us be received in accordance with the legal requirements and to request its transmission to other persons responsible.
Furthermore, they have the right to file a complaint with the competent supervisory authority in accordance with legal requirements.
Right of revocation
You have the right to revoke consents given with effect for the future.
Right of objection
You can object to the future processing of the data concerning you in accordance with the legal requirements at any time. The objection may be lodged in particular against processing for direct marketing purposes.
Cookies and right of objection in direct advertising
Cookies” are small files that are stored on the user’s computer. Different data can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his or her visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the content of a shopping basket in an online shop or a login status can be stored. Cookies are referred to as “permanent” or “persistent” and remain stored even after the browser is closed. For example, the login status can be saved when users visit it after several days. Likewise, the interests of users used for range measurement or marketing purposes may be stored in such a cookie. Third-party cookies” are cookies that are offered by providers other than the person responsible for operating the online offer (otherwise, if they are only its cookies, they are referred to as “first-party cookies”).
We may use temporary and permanent cookies and clarify this within the framework of our data protection declaration.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
A general objection to the use of cookies used for online marketing purposes can be declared for many of the services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/oder the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that in this case not all functions of this online offer can be used.
Deletion of data
The data processed by us will be deleted or its processing restricted in accordance with legal requirements. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory storage obligations.
If the data are not deleted because they are necessary for other and legally permissible purposes, their processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons.
Changes and Updates to this Privacy Policy
We ask you to inform yourself regularly about the contents of our data protection declaration. We will adapt the data protection declaration as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
Comments and contributions
If users leave comments or other contributions, their IP addresses may be used on the basis of our legitimate interests within the meaning of Art. 6 (1) (f). GDPR for 7 days. This takes place for our safety, if someone leaves illegal contents in comments and contributions (insults, forbidden political propaganda, etc.). In this case we can be prosecuted ourselves for the comment or contribution and are therefore interested in the identity of the author.
Furthermore, we reserve the right, on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. GDPR to process user information for spam detection.
On the same legal basis, we reserve the right, in the case of surveys, to store the IP addresses of users for their duration and to use cookies to avoid multiple votes.
The personal information provided in the context of the comments and contributions, any contact and website information as well as the content information, will be permanently stored by us until the user objects.
Comment subscriptions
Users may subscribe to the follow-up comments with their consent in accordance with Art. 6 para. 1 lit. a GDPR. Users will receive a confirmation email to verify that they are the owner of the email address they entered. Users can unsubscribe from ongoing comment subscriptions at any time. The confirmation email will contain information on the cancellation options. For the purpose of providing proof of user consent, we store the time of registration together with the IP address of the users and delete this information when users unsubscribe from the subscription.
You can cancel the receipt of our subscription at any time, i.e. revoke your consent. We may store the e-mail addresses we have unsubscribed for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of these data is limited to the purpose of a possible defence against claims. An individual application for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.
Retrieval of profile pictures from Gravatar
We use the service Gravatar of Automattic Inc. 60 29th Street #343, San Francisco, CA 94110, USA, within our online offer and especially in our blog.
Gravatar is a service where users can log in and store profile pictures and their e-mail addresses. If users leave contributions or comments with the respective e-mail address on other online presences (above all in blogs), their profile pictures can be displayed next to the contributions or comments. For this purpose, the e-mail address provided by the users is transmitted to Gravatar in encrypted form for the purpose of checking whether a profile has been saved for it. This is the sole purpose of the transmission of the e-mail address and it will not be used for other purposes, but will be deleted thereafter.
The use of Gravatar is based on our legitimate interests within the meaning of Art. 6 Para. 1 letter f) GDPR, as we offer the possibility of personalising their contributions with a profile picture with the help of Gravatar.
By displaying the images, Gravatar obtains the IP address of the users, as this is necessary for communication between a browser and an online service. For more information on Gravatar’s collection and use of the data, please refer to Automattic’s privacy policy: https://automattic.com/privacy/.
If users do not want an image associated with their email address to appear in Gravatar’s comments, you should use a non-Gravatar email address for commenting. We would also like to point out that it is also possible to use an anonymous or no e-mail address if users do not wish their own e-mail address to be sent to Gravatar. Users can completely prevent the transfer of data by not using our comment system.
Retrieval of emojis and smilies
Within our WordPress blog, graphical emojis (or smilies), i.e. small graphical files that express feelings, are used that are obtained from external servers. The providers of the servers collect the IP addresses of the users. This is necessary so that the emojie files can be transmitted to the users’ browsers. The Emojie service is offered by Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA. Automattic’s privacy policy: https://automattic.com/privacy/. The server domains used are s.w.org and twemoji.maxcdn.com, whereby to our knowledge these are so-called content-delivery networks, i.e. servers which serve only a fast and secure transmission of the files and the personal data of the users are deleted after the transmission.
Emojis is used on the basis of our legitimate interests, i.e. interest in an attractive design of our online offer in accordance with Art. 6 para. 1 lit. f. GDPR.
Contacting
When contacting us (e.g. via contact form, e-mail, telephone or social media), the user’s details for processing the contact enquiry and its processing pursuant to Art. 6 para. 1 letter b. (in the context of contractual/pre-contractual relationships), Art. 6 para. 1 lit. f. (other requests) GDPR. User information can be stored in a customer relationship management system (“CRM system”) or comparable request organization.
We delete the requests if they are no longer necessary. We review this requirement every two years; the statutory archiving obligations also apply.
Hosting and e-mail dispatch
The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail delivery, security services and technical maintenance services that we use for the purpose of operating this online offer.
We or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta- and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer according to Art. 6 Para. 1 lit. f GDPR in conjunction with. Art. 28 GDPR (conclusion of order processing contract).
Content-Delivery-Network Cloudflare
We use a Content Delivery Network (CDN), offered by Cloudflare, Inc. 101 Townsend St, San Francisco, CA 94107, USA. Cloudflare is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnZKAA0&status=Active).
A CDN is a service with the help of which contents of our online offer, in particular large media files, such as graphics or scripts, are delivered faster with the help of regionally distributed servers connected via the Internet. User data is processed solely for the aforementioned purposes and to maintain the security and functionality of the CDN.
The use is based on our legitimate interests, i.e. interest in a secure and efficient provision, analysis and optimisation of our online offer in accordance with Art. 6 para. 1 lit. f. GDPR.
For more information, please refer to Cloudflare’s privacy policy: https://www.cloudflare.com/security-policy.
Online presence on social media
We maintain online presences within social networks and platforms in order to communicate with active customers, interested parties and users and to inform them about our services.
We would like to point out that user data can be processed outside the European Union. This can pose risks for users because, for example, the enforcement of users’ rights could be made more difficult. With regard to US providers certified under the Privacy Shield, we would like to point out that they commit themselves to comply with EU data protection standards.
Furthermore, user data is usually processed for market research and advertising purposes. Thus, for example, user profiles can be created from the user behavior and the resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements inside and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer, in which the user’s usage behavior and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to these).
The processing of users’ personal data is carried out on the basis of our legitimate interests in effective user information and communication with users pursuant to Art. 6 para. 1 lit. f. GDPR. If the users are asked by the respective providers for consent to data processing (i.e. to give their consent e.g. by ticking a checkbox or confirming a button), the legal basis of processing is Art. 6 para. 1 lit. a., Art. 7 GDPR.
For a detailed description of the respective processing and the possibilities of objection (opt-out), we refer to the information provided by the providers linked below.
Also in the case of requests for information and the assertion of user rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, you can contact us.
Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) – Privacy Policy: https://www.facebook.com/about/privacy/, Opt-Out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.
Google/ YouTube (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – Privacy Policy: https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – Privacy Policy: http://instagram.com/about/legal/privacy/.
Snapchat (Snap Inc., Snap Inc. Headquarters, 2772 Donald Douglas Loop North, Santa Monica, CA 90405, USA) – Privacy Policy: https://www.snap.com/de-DE/privacy/privacy-policy/.
Integration of third-party services and content
Within our online offer, we make no representations or warranties of any kind based on our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) content or service offerings of third parties to incorporate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).
This always presupposes that the third party providers of this content perceive the IP address of the users, since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content. We make every effort to use only those contents whose respective providers use the IP address only for the delivery of the contents. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring websites, visiting time and other information about the use of our online offer, as well as be linked to such information from other sources.
Google Fonts
We integrate the fonts (“Google Fonts”) of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.
Shariff Sharing Features
We use the data protection safe “Shariff” buttons. “Shariff” was developed to provide more privacy on the net and to replace the usual “share” buttons of social networks. It is not the user’s browser, but the server on which this online offer is located, that establishes a connection to the server of the respective social media platforms and queries, for example, the number of likes. The user remains anonymous. More information about the Shariff project can be found from the developers of the magazine c’t: www.ct.de.