Data Protection Declaration

Responsible Person:
Tobias Glawe
Loensweg 17
30938 Burgwedel, Germany

Phone Number: +49 152 27313075
E-mail: contact@tobiasglawe.eu

Date: 2018/05/25

1. Basic information on data processing and legal bases

1.1 This data protection declaration informs you about the type, scope and purpose of the processing of personal data within this online offer and the websites, functions and contents connected with it (hereinafter jointly referred to as “online offer” or “website”). This privacy policy applies regardless of the domains, systems, platforms and devices (e.g. desktop or mobile) on which the online offer is executed.

1.2 The terms used, such as “personal data” or their “processing”, I refer to the definitions in Art. 4 of the Basic Data Protection Ordinance (GDPR).

The personal data of users processed within the scope of this online offer include usage data (e.g., the websites I have visited, interest in my products) and content data (e.g., entries in the contact form).

1.3 The term “user” covers all categories of data subjects. Among them are my business partners, customers, interested parties and other visitors of this online offer. The terms used, such as “user”, are to be understood as gender-neutral.

1.4 I process personal data of users only in compliance with the relevant data protection regulations. This means that user data will only be processed if a legal permission has been obtained. I.e., especially if the data processing is necessary for the provision of my contractual services (e.g. processing of orders) as well as online services or is required by law, a consent of the user is available, and also because of my legitimate interests (i.e. interest in the analysis, optimization and economic operation and security of this online offer within the meaning of Art. 6 Para. 1 letter f. GDPR, in particular for range measurement, creation of profiles for advertising and marketing purposes, collection of access data and use of third-party services.

1.5 I would like to point out that the legal basis of the consents Art. 6 para. 1 lit. a. and Art. 7 GDPR, the legal basis for the processing for the fulfilment of my services and the implementation of contractual measures Art. 6 para. 1 lit. b. GDPR, the legal basis for the processing for the fulfilment of my legal obligations Art. 6 para. 1 lit. c. GDPR, and the legal basis for the processing for the protection of my legitimate interests Art. 6 para. 1 lit. f. GDPR is.

2. Security measures

2.1 I take organisational, contractual and technical security measures in accordance with the state of the art in order to ensure that the provisions of the data protection laws are observed and thus to protect the data processed by me against accidental or intentional manipulation, loss, destruction or against access by unauthorised persons.

The security measures include in particular the encrypted transmission of data between your browser and my server.

3. Disclosure of data to third parties and third-party providers

3.1 Data will only be passed on to third parties within the framework of legal requirements. I only pass on user data to third parties if this is necessary, e.g. on the basis of Art. 6 para. 1 lit. b) GDPR for contractual purposes or on the basis of legitimate interests pursuant to Art. 6 para. 1 lit. f. GDPR to the economic and effective operation of my business.

3.2 If I use subcontractors to provide my services, I take appropriate legal precautions as well as appropriate technical and organizational measures to ensure the protection of personal data in accordance with the relevant legal regulations.

3.3 If content, tools or other means from other providers (hereinafter jointly referred to as “third party providers”) are used in the context of this data protection declaration and their named registered office is in a third country, it is to be assumed that data is transferred to the countries in which the third party providers have their registered office. Third countries are countries in which the GDPR is not directly applicable law, i.e. in principle countries outside the EU or the European Economic Area. The transfer of data to third countries takes place either if an appropriate level of data protection, user consent or other legal permission is available.

4. Performance of contractual services

4.1 I process inventory data (e.g., names and addresses as well as contact data of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling my contractual obligations and services pursuant to Art. 6 para. 1 lit b. GDPR.

Users can optionally create a user account, in particular by viewing their orders. During the registration process, the required information will be communicated to the users. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to its storage is necessary for commercial or tax reasons according to Art. 6 Para. 1 lit. c GDPR. It is incumbent on the users to save their data before the end of the contract in the event of termination. I am entitled to irretrievably delete all user data stored during the contract period.

Within the scope of registration and renewed registrations as well as use of my online services, the server stores the IP address and the time of the respective user action. The storage is based on my legitimate interests, as well as the user as protection against misuse and other unauthorized use. A passing on of these data to third parties does not take place in principle, unless it is necessary for the pursuit of my claims or there is a legal obligation in accordance with Art. 6 Abs. 1 lit. c GDPR.

5. Establishment of contact

5.1 When contacting me (via contact form or e-mail), the user’s details will be processed for processing the contact request and its handling in accordance with Art. 6 para. 1 lit. b) GDPR.

6. Comments and contributions

6.1 If users leave comments or other contributions, their IP addresses will be used on the basis of my legitimate interest within the meaning of Art. 6 para. 1 letter f. GDPR for 7 days.

6.2 This takes place for my safety, if someone leaves illegal contents in comments and contributions (insults, forbidden political propaganda, etc.). In this case I could be prosecuted for the comment or contribution myself and am therefore interested in the identity of the author.

7. Collection of access data and log files

7.1 On the basis of my legitimate interest within the meaning of Art. 7 para. 1 lit. f. GDPR data on each access to the server on which this service is located (so-called server log files). Access data includes the name of the accessed website, file, date and time of access, transferred data volume, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

7.2 Log file information is stored for a maximum of thirty days for security reasons (e.g. to investigate misuse or fraud) and then deleted. Data whose further storage is required for evidentiary purposes are excluded from deletion until the respective incident has been finally clarified.

8. Cookies and range measurement

8.1 Cookies are information that is transferred from my web server or third party web servers to the user’s web browser and stored there for later retrieval. Cookies can be small files or other types of information storage.

8.2 I use “session cookies” that are only stored on this website for the duration of my current visit (e.g. to enable the storage of your login status or the shopping basket function and thus the use of my online offer at all). A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. A cookie also contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using my online offer and log out or close your browser, for example.

8.3 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.

8.4 You may opt-out of the use of cookies for range measurement and promotional purposes via the deactivation page of the Network Advertising Initiative (http://optout.networkadvertising.org/) and additionally the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).

9. Google Analytics

9.1 Based on my legitimate interest (i.e. interest in the analysis, optimization and economic operation of my online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) Google Analytics, a web analysis service of Google Inc. “(“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by users is generally transferred to a Google server in the USA and stored there.

9.2 Google is certified under the Privacy Shield Agreement and thereby offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

9.3 Google will use this information on my behalf to evaluate the use of this online offer by users, to compile reports on the activities within this online offer and to provide us with further services connected with the use of this online offer and the use of the Internet. Pseudonymous user profiles can be created from the processed data.

I use Google Analytics to display ads placed by Google and its partners within advertising services only to those users who have also shown an interest in this online offer or who have certain characteristics (e.g. interests in certain topics or products that are determined by the web pages visited) that I transmit to Google (so-called “remarketing” or “Google Analytics Audiences”). With the help of the remarketing audiences I would also like to ensure that my ads correspond to the potential interest of the users and are not annoying.

9.4 I use Google Analytics only with IP anonymization enabled. This means that Google will reduce the IP address of users within Member States of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.

9.5 The IP address transmitted by the user’s browser is not merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online offer and the processing of this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

9.6 Further information on data use by Google, possible settings and objections can be found on the Google websites: https://www.google.com/intl/de/policies/privacy/partners (“Data use by Google when using our partners’ websites or apps”), http://www.google.com/policies/technologies/ads (“Data use for advertising purposes”), http://www.google.de/settings/ads (“Manage information that Google uses to show you advertising”).

10. Google marketing services

10.1 Based on my legitimate interest (i.e. interest in the analysis, optimisation and economic operation of my online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) the marketing and remarketing services (“Google Marketing Services” for short) of Google Inc. 1600 Amphitheatre Parkway, Mountain View, CA 104043, USA, (“Google”).

10.2 Furthermore, I use the “Google Tag Manager” to integrate and manage Google Analytics services into this website.

10.3 I can also use the service “Google Optimizer”. Google Optimizer allows me to track the effects of various changes to a website (e.g. changes to input fields, design, etc.) within the framework of so-called “A/B testing”. Cookies are stored on the user’s devices for these test purposes. Only pseudonymous user data is processed.

10.4 Further information on Google’s use of data for marketing purposes can be found on the overview page: https://www.google.com/policies/technologies/ads, Google’s data protection declaration can be accessed at https://www.google.com/policies/privacy.

10.5 If you wish to object to interest-based advertising by Google marketing services, you can use the setting and opt-out options provided by Google: http://www.google.com/ads/preferences.

11. Facebook, custom audiences and Facebook marketing services

11.1 Due to my legitimate interest in the analysis, optimisation and economic operation of this online offer and for these purposes the so-called “Facebook pixel” of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), is used within this online offer.

11.2 Facebook 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=a2zt0000000GnywAAC&status=Active).

11.3 With the help of the Facebook pixel, Facebook is able to determine the visitors of this online offer as a target group for the presentation of advertisements (so-called “Facebook ads”). Accordingly, I use the Facebook pixel to display the Facebook ads I have posted only to Facebook users who have shown an interest in my online offer or who have certain features (e.g. interests in certain topics or products that are determined by the websites I visit) that I send to Facebook (so-called “custom audiences”). With the help of the Facebook pixel I also want to make sure that my Facebook ads correspond to the potential interest of the users and are not annoying. The Facebook pixel also helps me understand the effectiveness of Facebook ads for statistical and market research purposes by showing whether users have been redirected to this site after clicking on a Facebook ad (so-called “conversion”).

11.4 The Facebook pixel is directly integrated by Facebook when these websites are accessed and can store a so-called cookie, i.e. a small file, on your device. If you then log in to Facebook or visit Facebook when logged in, your visit to this online offer will be noted in your profile. The data collected about you is anonymous to me, so it does not give me any information about the identity of the users. However, Facebook stores and processes the data so that a connection to the respective user profile is possible and can be used by Facebook as well as for its own market research and advertising purposes. If I send data to Facebook for matching purposes, it is encrypted locally on the browser and only then sent to Facebook via a secure https connection. This is done solely with the purpose of creating a comparison with the data that is equally encrypted by Facebook.

11.5 Facebook processes the data in accordance with Facebook’s Data Usage Policy. Accordingly, general information on the display of Facebook ads can be found in the Facebook Data Usage Policy: https://www.facebook.com/policy.php. For specific information and details about the Facebook pixel and how it works, please visit the Facebook Help section: https://www.facebook.com/business/help/651294705016616.

11.6 You may object to the collection by the Facebook Pixel and use of your data to display Facebook Ads. To set what types of ads you see within Facebook, you can visit the page set up by Facebook and follow the instructions on usage-based advertising settings: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.

11.7 To prevent your information from being collected via the Facebook pixel on this website, please click the following link: Facebook Opt-Out Note: When you click the link, an opt-out cookie is stored on your device. If you delete the cookies in this browser, you must click the link again. Furthermore, the opt-out only applies within the browser you use and only within my web domain on which the link was clicked.

11.8 You may also opt-out of the use of cookies for range measurement and promotional purposes via the deactivation page of the Network Advertising Initiative (http://optout.networkadvertising.org/) and additionally the US website (http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).

12. Instagram

12.1 This Website incorporates functions of the Instagram Service. These functions are provided by Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA. Once logged into your Instagram account, click on an Instagram post to view it in Instagram. This allows Instagram to associate your visit to this page with your user account.
For more information, please see Instagram’s privacy policy: http://instagram.com/about/legal/privacy/.

13. Integration of third-party services and content

13.1 I place within this online offer on the basis of my legitimate interest (i.e. interest in the analysis, optimisation and economic operation of this 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. I try 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 may be linked to such information from other sources.

13.2 The following presentation provides an overview of third-party providers and their contents, together with links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, possibilities of objection (so-called opt-out):

  • If my customers use the payment services of third parties (e.g. Stripe or Sofortüberweisung), the terms and conditions and the data protection information of the respective third party providers, which can be accessed within the respective websites or transaction applications, apply.
  • Maps of the “Google Maps” service provided by Google Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
  • Videos from the YouTube platform of third-party provider Google Inc. 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
  • External fonts from Google, Inc., www.google.com/fonts (“Google Fonts”). The integration of the Google Fonts takes place via a server call with Google (usually in the USA). Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
  • External code of the JavaScript framework “jQuery”, provided by the third-party provider jQuery Foundation, jquery.org.
  • Optimus” external image enhancement, provided by third-party provider proinity GmbH, Rümikerstrasse 60, 8409 Winterthur, Switzerland.
  • External and additional provision (Content Delivery Network) of static image, Javascript and CSS data via “KeyCDN”, provided by third-party provider proinity LLC, Rümikerstrasse 60, 8409 Winterthur, Switzerland. Privacy Policy: https://www.keycdn.com/legal.



14. iTheme Security

14.1 This website includes the iTheme Security extension. This is offered by Liquid Web, LLC, 2703 Ena Drive, Lansing, MI 48917, USA. The extension logs login attempts into the backend and accesses to non-existent pages (404 recognition) and blocks access to the website via IP blocking in the event of excessive access attempts. For this purpose, the IP address is stored encrypted in the server’s database on the basis of Art. 6 para. 1 letter f GDPR.

15. Rights of users

15.1 Users have the right, upon request and free of charge, to receive information about the personal data that I have stored about them.

15.2 In addition, users have the right to correct inaccurate data, to limit the processing and deletion of their personal data, if applicable, to assert their rights to data portability and, in the event of the assumption of unlawful data processing, to file a complaint with the competent supervisory authority.

15.3 Users may also revoke their consent, in principle with regard to the future.

16. Deletion of data

16.1 The data stored with me will be deleted as soon as it is no longer necessary for its intended purpose and the deletion does not conflict with any legal storage obligations. If the user’s 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 user data that must be retained for commercial or tax reasons.

16.2 In accordance with statutory requirements, the records shall be kept for 6 years in accordance with § 257 (1) HGB (trading books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting documents, etc.) and for 10 years in accordance with § 147 (1) AO (books, records, management reports, accounting documents, commercial and business letters, documents relevant to taxation, etc.).

17. Right of objection

17.1 Users can object to the future processing of their personal data in accordance with legal requirements at any time. The objection may be lodged in particular against processing for direct marketing purposes.

18. Changes to the data protection declaration

18.1 I reserve the right to change the data protection declaration in order to adapt it to changed legal situations or to changes in the service and data processing. However, this only applies with regard to declarations on data processing. If user consents are required or components of the data protection declaration contain provisions of the contractual relationship with the users, the changes will only be made with the users’ consent.

18.2 Users are asked to inform themselves regularly about the contents of the data protection declaration.