TrueCommerce Group Privacy Notice Service Details
TrueCommerce Group Privacy Notice Service Details
This supplemental notice to the TrueCommerce Group Privacy Notice describes how certain services that TrueCommerce uses process your data more specifically then as described in the general notice.
Cloudflare
We use the “Cloudflare” service provided by Cloudflare Inc. Cloudflare offers a content delivery network with DNS that is available worldwide. As a result, the information transfer that occurs between your browser and our website is technically routed via Cloudflare’s network. This enables Cloudflare to analyze data transactions between your browser and our website and to work as a filter between our servers and potentially malicious data traffic from the Internet. In this context, Cloudflare may also use cookies or other technologies deployed to recognize Internet users, which shall, however, only be used for the herein described purpose.
The use of Cloudflare is based on our legitimate interest in a provision of our website offerings that is as error free and secure as possible (Art. 6(1)(f) GDPR).
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.cloudflare.com/privacypolicy/. For more information on Cloudflare’s security precautions and data privacy policies, please follow this link: https://www.cloudflare.com/privacypolicy/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF) and for more information, please contact the provider:
https://www.dataprivacyframework.gov/s/participant-search/participant- detail?contact=true&id=a2zt0000000GnZKAA0&status=Active
We have integrated elements of the social network Facebook on this website. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Facebook’s statement the collected data will be transferred to the USA and other third-party countries. An overview of the Facebook social media elements is available under the following link: https://developers.facebook.com/docs/plugins/.
If the social media element has been activated, a direct connection between your device and the Facebook
server will be established. As a result, Facebook will receive information confirming your visit to this website with your IP address. If you click on the Facebook Like button while you are logged into your Facebook account, you can link content of this website to your Facebook profile. Consequently, Facebook will be able to allocate your visit to this website to your user account. We have to emphasize that we as the provider of the website do not receive any information on the content of the transferred data and its use by Facebook. For more information, please consult the Data Privacy Policy of Facebook at: https://de-de.facebook.com/privacy/explanation.
If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis of Art. 6 Sect. 1 lit. a GDPR and § 25 TTDSG (German Telecommunications Act). Such consent may be revoked at any time. If your consent was not obtained, the use of the service will occur on the basis of our legitimate interest in making our information as comprehensively visible as possible on social media.
Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook. The processing by Facebook that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found under: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook tool and for the privacy-secure implementation of the tool on our website. Facebook is responsible for the data security of Facebook products. You can assert data subject rights (e.g., requests for information) regarding data processed by Facebook directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum,
https://de-de.facebook.com/help/566994660333381 and https://www.facebook.com/policy.php.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). For more information, please contact the provider under the following link:
https://www.dataprivacyframework.gov/s/participant-search/participant- detail?contact=true&id=a2zt0000000GnywAAC&status=Active
X (formerly Twitter)
We have integrated functions of the social media platform X (formerly Twitter) into this website. These functions are provided by Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland.
If the social media element has been activated, a direct connection between your device and X’s server will be established. As a result, X will receive information on your visit to this website. While you use X and the “Re-Tweet” or “Repost” function, websites you visit are linked to your X account and disclosed to other users. We must point out, that we, the providers of the website and its pages do not know anything about the content of the data transferred and the use of this information by X. For more details, please consult X’s Data Privacy Declaration at: https://twitter.com/en/privacy.
If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis of Art. 6(1)(a) GDPR and § 25 TTDSG (German Telecommunications Act). Such consent may be revoked at
any time. If your consent was not obtained, the use of the service will occur on the basis of our legitimate interest in making our information as comprehensively visible as possible on social media.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://gdpr.twitter.com/en/controller-to-controller-transfers.html.
You have the option to reset your data protection settings on X under the account settings at https://twitter.com/account/settings.
We have integrated functions of the public media platform Instagram into this website. These functions are being offered by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. If the social media element has been activated, a direct connection between your device and Instagram’s server will be established. As a result, Instagram will receive information on your visit to this website.
If you are logged into your Instagram account, you may click the Instagram button to link contents from this website to your Instagram profile. This enables Instagram to allocate your visit to this website to your user account. We have to point out that we as the provider of the website and its pages do not have any knowledge of the content of the data transferred and its use by Instagram.
If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis of Art. 6(1)(a) GDPR and § 25 TTDSG (German Telecommunications Act). Such consent may be revoked at any time. If your consent was not obtained, the use of the service will occur on the basis of our legitimate interest in making our information as comprehensively visible as possible on social media.
Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook or Instagram, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook or Instagram. The processing by Facebook or Instagram that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found under:
https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook or Instagram tool and for the privacy-secure implementation of the tool on our website. Facebook is responsible for the data security of Facebook or Instagram products. You can assert data subject rights (e.g., requests for information) regarding data processed by Facebook or Instagram directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum, https://privacycenter.instagram.com/policy/ and https://de-de.facebook.com/help/566994660333381.
For more information on this subject, please consult Instagram’s Data Privacy Declaration at: https://privacycenter.instagram.com/policy/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). For more information, please contact the provider under the following link:
https://www.dataprivacyframework.gov/s/participant-search/participant- detail?contact=true&id=a2zt0000000GnywAAC&status=Active
This website uses elements of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
Any time you access a page of this website that contains elements of LinkedIn, a connection to LinkedIn’s servers is established. LinkedIn is notified that you have visited this website with your IP address. If you click on LinkedIn’s “Recommend” button and are logged into your LinkedIn account at the time, LinkedIn will be in a position to allocate your visit to this website to your user account. We have to point out that we as the provider of the websites do not have any knowledge of the content of the transferred data and its use by LinkedIn.
If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis of Art. 6 (1)(a) GDPR and § 25 TTDSG (German Telecommunications Act). Such consent may be revoked at any time. If your consent was not obtained, the use of the service will occur on the basis of our legitimate interest in making our information as comprehensively visible as possible on social media.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.linkedin.com/help/linkedin/answer/62538/datenubertragung-aus-der-eu-dem-ewr-und-der- schweiz?lang=en.
For further information on this subject, please consult LinkedIn’s Data Privacy Declaration at: https://www.linkedin.com/legal/privacy-policy.
This website uses elements of the XING network. The provider is the New Work SE, Dammtorstraße 30, 20354 Hamburg, Germany.
Any time one of our sites/pages that contains elements of XING is accessed, a connection with XING’s servers is established. As far as we know, this does not result in the archiving of any personal data. In particular, the service does not store any IP addresses or analyze user patterns.
If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis of Art. 6 (1)(a) GDPR and § 25 TTDSG (German Telecommunications Act). Such consent may be revoked at any time. If your consent was not obtained, the use of the service will occur on the basis of our legitimate interest in making our information as comprehensively visible as possible on social media.
For more information on data protection and the XING share button please consult the Data Protection Declaration of Xing at: https://www.xing.com/app/share?op=data_protection.
Analysis tools and advertising
Google Analytics
This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. This data is assigned to the respective end device of the user. An assignment to a user-ID does not take place.
Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the user behavior patterns (e.g., cookies or device fingerprinting). The website use information recorded by Google is, as a rule transferred to a Google server in the United States, where it is stored.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). For more information, please contact the provider under the following link:
https://www.dataprivacyframework.gov/s/participant-search/participant- detail?contact=true&id=a2zt000000001L5AAI&status=Active
Browser plug-in
You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.
Contract data processing
We have executed a contract data processing agreement with Google and are implementing the stringent provisions of the German data protection agencies to the fullest when using Google Analytics.
Hotjar
This website utilizes Hotjar. The provider is Hotjar Ltd., Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Europe (website: https://www.hotjar.com).
Hotjar is a tool used to analyze your user patterns on this website. Hotjar allows us to for instance record your mouse and scroll movements as well as your click. During this process, Hotjar also has the capability to determine how long your cursor remained in a certain position. Based on this information, Hotjar compiles so-called Heatmaps, that make possible to determine which parts of the website the website visitor reviews with preference.
We are also able to determine how long you have stayed on a page of this website and when you left. We can also determine at which point you suspended making entries into a contact form (so-called conversion funnels).
Furthermore, Hotjar can be deployed to obtain direct feedback from website visitors. This function aims at the improvement of the website offerings of the website operator.
Hotjar uses technologies that make it possible to recognize the user for the purpose of analyzing the user patterns (e.g., cookies or the deployment of device fingerprinting).
If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis of Art. 6(1)(a) GDPR and § 25 TTDSG (German Telecommunications Act). Such consent may be revoked at any time. If your consent was not obtained, the use of the service will occur on the basis of Art. 6(1)(f) GDPR; the website operator has a legitimate interest in the analysis of user patterns to optimize both, the web presentation and the operator’s advertising activities.
Deactivation of Hotjar
If you would like to deactivate the recording of data by Hotjar, please click on the link below and follow the instructions provided under the link: https://www.hotjar.com/policies/do-not-track/.
Please keep in mind that you will have to separately deactivate Hotjar for every browser and every device.
For more detailed information about Hotjar and the data to be recorded, please consult the Data Privacy Declaration of Hotjar under the following link: https://www.hotjar.com/privacy.
Data processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.
Google Ads
The website operator uses Google Ads. Google Ads is an online promotional program of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Ads enables us to display ads in the Google search engine or on third-party websites, if the user enters certain search terms into Google (keyword targeting). It is also possible to place targeted ads based on the user data Google has in its possession (e.g., location data and interests; target group targeting). As the website operator, we can analyze these data quantitatively, for instance by analyzing which search terms resulted in the display of our ads and how many ads led to respective clicks.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://policies.google.com/privacy/frameworks and https://privacy.google.com/businesses/controllerterms/mccs/.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt000000001L5AAI&status=Active
Google Ads Remarketing
This website uses the functions of Google Ads Remarketing. The provider of these solutions is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
With Google Ads Remarketing, we can assign people who interact with our online offering to specific target groups in order to subsequently display interest-based advertising to them in the Google advertising network (remarketing or retargeting).
Moreover, it is possible to link the advertising target groups generated with Google Ads Remarketing to device encompassing functions of Google. This makes it possible to display interest-based customized advertising messages, depending on your prior usage and browsing patterns on a device (e.g., cell phone) in a manner tailored to you as well as on any of your devices (e.g., tablet or PC).
If you have a Google account, you have the option to object to personalized advertising under the following link: https://www.google.com/settings/ads/onweb/.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time.
For further information and the pertinent data protection regulations, please consult the Data Privacy Policies of Google at: https://policies.google.com/technologies/ads?hl=en.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link:
https://www.dataprivacyframework.gov/s/participant-search/participant- detail?contact=true&id=a2zt000000001L5AAI&status=Active
Google Conversion-Tracking
This website uses Google Conversion Tracking. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
With the assistance of Google Conversion Tracking, we are in a position to recognize whether the user has completed certain actions. For instance, we can analyze the how frequently which buttons on our website have been clicked and which products are reviewed or purchased with particular frequency. The purpose of this information is to compile conversion statistics. We learn how many users have clicked on our ads and which actions they have completed. We do not receive any information that would allow us to personally identify the users. Google as such uses cookies or comparable recognition technologies for identification purposes.
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time.
For more information about Google Conversion Tracking, please review Google’s data protection policy at: https://policies.google.com/privacy?hl=en
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). For more information, please contact the provider under the following link:
https://www.dataprivacyframework.gov/s/participant-search/participant- detail?contact=true&id=a2zt000000001L5AAI&status=Active
Newsletter
Newsletter data
If you would like to subscribe to the newsletter offered on this website, we will need from you an e-mail address as well as information that allow us to verify that you are the owner of the e-mail address provided and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis. We shall use such data only for the sending of the requested information and shall not share such data with any third parties.
The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent (Art. 6(1)(a) GDPR). You may revoke the consent you have given to the archiving of data, the e-mail address, and the use of this information for the sending of the newsletter at any time, for instance by clicking on the “Unsubscribe” link in the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date.
The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter or after the purpose has ceased to apply. We reserve the right to delete or block e-mail addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest in accordance with Art. 6(1)(f) GDPR.
Data stored for other purposes with us remain unaffected.
After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist, if such action is necessary to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.
Plug-ins and Tools
YouTube with expanded data protection integration
Our website embeds videos of the website YouTube. The website operator is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
We use YouTube in the expanded data protection mode. According to YouTube, this mode ensures that YouTube does not store any information about visitors to this website before they watch the video.
Nevertheless, this does not necessarily mean that the sharing of data with YouTube partners can be ruled out as a result of the expanded data protection mode. For instance, regardless of whether you are watching a video, YouTube will always establish a connection with the Google Marketing Network.
As soon as you start to play a YouTube video on this website, a connection to YouTube’s servers will be established. As a result, the YouTube server will be notified, which of our pages you have visited. If you are logged into your YouTube account while you visit our site, you enable YouTube to directly allocate your browsing patterns to your personal profile. You have the option to prevent this by logging out of your YouTube account.
Furthermore, after you have started to play a video, YouTube will be able to place various cookies on your device or comparable technologies for recognition (e.g. device fingerprinting). In this way YouTube will be able to obtain information about this website’s visitors. Among other things, this information will be used to generate video statistics with the aim of improving the user friendliness of the site and to prevent attempts to commit fraud.
Under certain circumstances, additional data processing transactions may be triggered after you have started to play a YouTube video, which are beyond our control.
The use of YouTube is based on our interest in presenting our online content in an appealing manner. Pursuant to Art. 6(1)(f) GDPR, this is a legitimate interest. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time.
For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy under: https://policies.google.com/privacy?hl=en.
The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link:
https://www.dataprivacyframework.gov/s/participant-search/participant- detail?contact=true&id=a2zt000000001L5AAI&status=Active
Google Fonts (local embedding)
This website uses so-called Google Fonts provided by Google to ensure the uniform use of fonts on this site. These Google fonts are locally installed so that a connection to Google’s servers will not be established in conjunction with this application.
For more information on Google Fonts, please follow this link: https://developers.google.com/fonts/faq and consult Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en.