Privacy policy

Introduction

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

The terms used are not gender-specific.

Status: 15 February 2020

Table of contents

  • Introduction
  • Responsible
  • Overview of the processing operations
  • Relevant legal bases
  • Security measures
  • Transmission and disclosure of personal data
  • Data processing in third countries
  • Use of cookies
  • Commercial and business services
  • Provision of the online offer and web hosting
  • Web analysis and optimization
  • Amendment and update of the privacy policy
  • Rights of data subjects
  • Definitions of terms

Responsible

Daily Innovators UG (haftungsbeschränkt)
Bonner Str. 33D
53721 Siegburg

Authorized representatives: Dominique Böcker (CEO)

e-mail address: [email protected]

Imprint: https://dailyinnovators.com/imprint/

Overview of the processing operations

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

  • inventory data (e.g. names, addresses).
  • Content data (e.g. text entries, photographs, videos).
  • Contact details (e.g. e-mail, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Contract data (e.g. subject matter of the contract, duration, customer category).
  • Payment data (for example, bank details, invoices, payment history).

Categories of data subjects

  • Business and contractual partners.
  • Users (e.g. website visitors, users of online services).

Purposes of the processing

  • Office and organisational procedures.
  • Content Delivery Network (CDN).
  • Interest based and behavioral marketing.
  • Contact requests and communication.
  • Profiling (creation of user profiles).
  • Range measurement (e.g. access statistics, recognition of returning visitors).
  • Tracking (e.g. interest/behavioural profiling, use of cookies).
  • Contractual performance and service.
  • Management and response to requests.

Relevant legal bases

In the following, we provide the legal basis of the basic data protection regulation (DSGVO), on the basis of which we process personal data. Please note that in addition to the provisions of the DSGVO, national data protection regulations may apply in your or our country of residence and domicile. Furthermore, if more specific legal bases should be decisive in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 para. 1 sentence 1 lit. a DPA)– The data subject has given his or her consent to the processing of personal data concerning him or her for one or more specific purposes.
  • Fulfilment of contracts and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DPA)– The processing is necessary for the performance of a contract to which the data subject is party or for carrying out pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c. DPA)– The processing is necessary to fulfil a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DPA)– The processing is necessary to protect the legitimate interests of the controller or of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

National data protection regulations in Germany: In addition to the data protection regulations of the Basic Data Protection Regulation, national regulations on data protection apply in Germany. This includes in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special provisions on the right to information, the right to deletion, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as 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 and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

Security measures

We take appropriate technical and organisational measures 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, in order to ensure a level of protection commensurate with the risk.

These measures shall include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, assurance of availability and segregation of data relating to them. Furthermore, we have established procedures to ensure that data subjects’ rights are exercised, data is deleted, and responses are made to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly presettings.

Shortening the IP address: If it is possible for us or if it is not necessary to save the IP address, we will shorten or have your IP address shortened. In the case of IP address shortening, also known as “IP masking”, the last octet, i.e. the last two digits of an IP address, are deleted (the IP address in this context is an identifier individually assigned to an Internet connection by the online access provider). The purpose of shortening the IP address is to prevent or make it considerably more difficult to identify a person on the basis of their IP address.

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

Transmission and disclosure of personal data

Within the scope of our processing of personal data, it happens that the data is transferred to other bodies, companies, legally independent organisational units or persons or that it is disclosed to them. The recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such a case we observe the legal requirements and in particular conclude appropriate contracts or agreements with the recipients of your data, which serve to protect your data.

Data processing in third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of the use of services provided by third parties or the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with the legal requirements.

Subject to express consent or to contractual or legally required transfer, we process or allow the data to be processed only in third countries with a recognised level of data protection, including the US processors certified under the Privacy Shield, or on the basis of special guarantees, such as contractual obligations under so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

Use of cookies

Cookies are text files that contain data from websites or domains visited and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after his visit within an online offer. The stored information can include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was watched. The term “cookies” also includes other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”)

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user leaves an online offer and closes his browser.
  • Permanent cookies: Permanent cookies remain stored even after closing the browser. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users used for reach measurement or marketing purposes may be stored in such a cookie.
  • First Party Cookies: First Party Cookies are set by ourselves.
  • Third party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or absolutely necessary) cookies: Cookies can be absolutely necessary for the operation of a website (e.g. to store logins or other user entries or for security reasons).
  • Statistical, marketing and personalisation cookies: Furthermore, cookies are generally also used in the context of measuring reach and when the interests of a user or his behaviour (e.g. viewing certain content, using functions etc.) on individual web pages are stored in a user profile. Such profiles are used to show users, for example, content that matches their potential interests. This process is also known as “tracking”, i.e., following up the potential interests of users. . If we use cookies or “tracking” technologies, we will inform you separately in our data protection declaration or within the scope of obtaining consent.

Information on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask you for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in a business operation of our online offer and its improvement) or if the use of cookies is necessary to fulfil our contractual obligations.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the possibility at any time to revoke a given consent or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection by means of the settings of your browser, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can receive further notices of objection in the context of the information on the service providers and cookies used.

Processing of cookie data based on consent: Before we process data within the scope of the use of cookies or have them processed, we ask the users for their consent, which can be revoked at any time. Before consent has not been given, cookies are used if necessary, which are necessary for the operation of our online offer. Their use is based on our interest and the interest of the users in the expected functionality of our online offer.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Commercial and business services

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

We process these data in order to fulfil our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with these data and for the purposes of business organisation. Within the framework of the applicable law, we only pass on the data of the contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations or with the consent of the contractual partners (e.g. to involved telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about other forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.

We inform our contractual partners which data is required for the above-mentioned purposes before or during the data collection, e.g. in online forms, by special marking (e.g. colours) or symbols (e.g. asterisks or similar), or personally.

We delete the data after expiry of legal warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be kept for legal archiving reasons (e.g., for tax purposes usually 10 years). We delete data that has been disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, generally after the end of the order.

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

Economic analyses and market research: For economic reasons and in order to be able to identify market trends, wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., whereby the group of persons concerned may include contractual partners, interested parties, customers, visitors and users of our online offer.

The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we can, if available, take into account the profiles of registered users including their details, e.g. regarding services used. The analyses serve solely to serve us and are not disclosed externally, unless they are anonymous analyses with summarized, i.e. anonymized values. Furthermore, we respect the privacy of the users and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarized data).

Agency services: We process the data of our customers within the scope of our contractual services, which may include, for example, conceptual and strategic consulting, campaign planning, software and design development/consultancy or maintenance, implementation of campaigns and processes, handling, server administration, data analysis/consultancy services and training services.

Project and development services: We process the data of our customers and clients (hereinafter referred to as “customers”) in order to enable them to select, purchase or commission the selected services or works and related activities, as well as to pay for and make them available or carry out or provide them.

The required information is identified as such in the context of the conclusion of the order, purchase order or comparable contract and includes the information required for the provision of services and invoicing as well as contact information in order to be able to make any necessary arrangements. Insofar as we gain access to information from end customers, employees or other persons, we process this information in accordance with legal and contractual requirements.

  • Processed data types: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Interested parties, business and contractual partners, customers.
  • Purposes of the processing: contractual services and support, contact requests and communication, office and organisational procedures, management and response to requests, visit evaluation, interest based and behaviour based marketing, profiling (creation of user profiles).
  • Legal bases: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), Legal obligation (Art. 6 para. 1 sentence 1 lit. c. DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Provision of the online offer and web hosting

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

The data processed within the framework of the provision of the hosting offer may include all data concerning the users of our online offer, which are generated within the framework of the use and communication. This regularly includes the IP address, which is necessary to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

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 called up, date and time of the call-up, transferred data volumes, notification of successful call-up, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the load of the servers and their stability.

Content Delivery Network: We use a “Content Delivery Network” (CDN). A CDN is a service with the help of which contents of an online offer, especially large media files such as graphics or program scripts, can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet.

  • Processed data types: Content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purpose of the processing: Content Delivery Network (CDN).
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Web analysis and optimization

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

In addition to web analysis, we can also use test procedures, e.g. to test and optimise different versions of our online offer or its components.

For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar procedures with the same purpose can be used. This information may include, for example, content viewed, web pages visited and elements used there, and technical information such as the browser used, the computer system used and information on times of use. If users have consented to the collection of their location data, this data may also be processed, depending on the provider.

The IP addresses of users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect the users. In general, the data stored in the context of web analysis, A/B testing and optimization are not clear user data (such as e-mail addresses or names), 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 purposes of the respective procedures.

Notes on legal bases: If we ask users to give their consent to the use of third parties, the legal basis for processing data is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Persons concerned: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Range measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behaviour-related profiling, use of cookies), visitor action evaluation, profiling (creation of user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Services used and service providers:

  • Matomo: The information generated by the cookie about your use of this website is only stored on our server and will not be disclosed to third parties; service provider: Web analysis/range measurement in self-hosting; deletion of data: The cookies have a maximum storage period of 13 months; possibility of objection (Opt-Out): Users can object to the processing of their data by Matomo at any time with effect for the future. In this case a so-called opt-out cookie is stored in your browser, which means that Matomo does not collect any session data at all. However, if users delete their cookies, the opt-out cookie will also be deleted and therefore must be reactivated by users.

Amendment and update of the privacy policy

We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the privacy policy 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 an act of cooperation on your part (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.

Rights of data subjects

As data subjects, they are entitled to various rights under the DSGVO, which result in particular from Art. 15 to 18 and 21 DSGVO:

  • Right of objection: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6 paragraph 1 letter e or f of the DPA; this also applies to profiling based on these provisions. If the personal data concerning you are 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, including profiling, insofar as it is linked to such direct marketing.
  • Right of withdrawal in case of consent: You have the right to revoke any consent given at any time.
  • Right of access: You have the right to obtain confirmation as to whether or not data in question are being processed and to be given access to such data and to receive further information and copies of the data in accordance with the law.
  • Right of rectification: You have the right to request the completion of data concerning you or the rectification of incorrect data concerning you, in accordance with the law.
  • Right to erasure and restriction of processing: You have the right to request that data concerning you be erased immediately in accordance with the law or, alternatively, to request a restriction of processing of the data in accordance with the law.
  • Right to data transferability: 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 request that it be transferred to another responsible party.
  • Complaints to the supervisory authority: You also have the right, in accordance with the legal provisions, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you is in breach of the DPA.

Definitions of terms

This section provides 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 DSGVO. The legal definitions are binding. The following explanations, on the other hand, are intended primarily to aid understanding. The terms are sorted alphabetically.

  • Conversion tracking: Conversion tracking is a method of determining the effectiveness of marketing activities. For this purpose, a cookie is usually stored on the user’s devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, we can track whether the ads we placed on other websites were successful).
  • Content Delivery Network (CDN): A “Content Delivery Network” (CDN) is a service that allows the content of an online offer, especially large media files such as graphics or program scripts, to be delivered faster and more securely with the help of regionally distributed servers connected via the Internet.
  • IP Masking: IP Masking is a method in which the last octet, i.e. the last two numbers of an IP address, are deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymising processing procedures, especially in online marketing
  • Interest-based and behavioral marketing: Interest-based and/or behavioral marketing is when potential interests of users in advertisements and other content are predetermined as precisely as possible. This is done on the basis of information on their previous behaviour (e.g. visiting and staying on certain websites, purchasing behaviour or interaction with other users), which is stored in a so-called profile. As a rule, cookies are used for these purposes.
  • Personal data: “personal data” shall mean 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 reference to an identifier such as a name, an identification number, location data, an on-line identifier (e.g. a cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
  • Profiling: “profiling” is any automated processing of personal data consisting of the use of personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information on age, gender, location and movement data, interaction with websites and their content, shopping behaviour, social interactions with other people). 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 the behaviour or interests of visitors in certain information, such as the content of websites. With the help of the reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This allows them to better adapt the content of the website to the needs of their visitors, for example. Pseudonymous cookies and web beacons are often used for reach analysis purposes in order to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Tracking: One speaks of “tracking” when the behaviour of users can be traced across several online offers. As a rule, behavioral and interest information regarding the online offers used is stored in cookies or on servers of the providers of tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
  • Controller: ‘Controller’ shall mean the natural or legal person, public authority, agency or any 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 covers practically every handling of data, whether it be collection, evaluation, storage, transmission or deletion.