1. Introduction
We would like to use the information below to provide you “data subject” with an overview of our processing of your personal data and your rights under data protection law. It is generally possible to use our website without entering personal data. However, if you wish to make use of special services offered by our company through our website, it may be necessary to process personal data. If it is necessary to process personal data and there is no legal basis for such processing, we will generally obtain your consent.
Personal data, such as your name, address or email address, is always processed in accordance with the EU General Data Protection Regulation (GDPR) and in accordance with the country-specific data protection regulations applicable to the “Frameworx GmbH”. The aim of this Privacy Notice is to inform you about the scope and purpose of the personal data we collect, use and process.
Table of Contents
- Introduction
- Data controller
- Data protection officer
- Legal basis for processing
- Disclosure of data to third parties
- Technology
- Cookies
- Contents of our website
- Newsletters
- Our activities in social networks
- Web analytics
- Advertising
- Plugins and other services
- Your rights as a data subject
- Right to confirmation
- Right to information (Article 15 GDPR)
- Right to rectification (Article 16 GDPR)
- Erasure (Article 17 GDPR)
- Restriction to processing (Article 18 GDPR)
- Data transferability (Article 20 GDPR)
- Objection (Article 21 GDPR)
- Revocation of consent regarding data protection
- Lodging a complaint with a supervisory authority
- Version and amendments to the Privacy Notice
2. Data controller
The data controller, as defined by the GDPR, is:
Frameworx GmbH
Löffelstrasse 22-24
70597 Stuttgart (Germany)
E-mail: hallo@frameworx.de
Data controller’s representative: Dominik Schleicher
3. Data protection officer
We would like to point out that we are not required to appoint a data protection officer.
Contact person for data protection:
E-mail: datenschutz@frameworx.de
4. Legal basis for processing
Art. 6 (1) lit. a) GDPR (icw § 25 (1) Telecommunications Digital Services Data Protection Act (TDDDG) (formerly TTDSG)) serves our company as the legal basis for processing operations where we obtain consent for a specific processing purpose.
If the processing of personal data is necessary for the performance of a contract to which you are a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of another service or consideration, the processing is based on Art. 6 (1) lit. b) GDPR. The same applies to processing operations that are necessary for the implementation of pre-contractual measures, for example in the case of enquiries about our products or services.
If our company is subject to a legal obligation by which the processing of personal data becomes necessary, such as for the fulfilment of tax obligations, the processing is based on Art. 6 (1) lit. c) GDPR.
In rare cases, the processing of personal data might become necessary to protect vital interests of the data subject or another natural person. This would be the case, for example, if a visitor were to be injured on our premises and as a result their name, age, health insurance data or other vital information had to be passed on to a doctor, hospital or other third party. In this case, the processing would be based on Art. 6 (1) lit. d) GDPR.
Finally, processing operations could be based on Art. 6 (1) lit. f) GDPR. Processing operations which are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary for the protection of a legitimate interest of our company or a third party, provided that the interests, fundamental rights and freedoms of the data subject do not overweigh. We are permitted to carry out such processing operations in particular because they have been specifically mentioned by the European law. In this respect, the legislature took the view that a legitimate interest could be assumed if you are a customer of our company (Recital 47, Sentence 2 GDPR).
Our offer is inherently aimed at adults. Persons under 16 years of age may not transmit any personal data to us without the consent of their parents or legal guardians. We do not request personal data from children and adolescents, do not collect it and do not pass it on to third parties.
5. Disclosure of data to third parties
Your personal data will not be conveyed to third parties for purposes other than those listed below.
We will only share/convey your personal data with third parties if:
- you have given us your express consent to do so in accordance with Art. 6 (1) lit. a) GDPR,
- the disclosure is permissible in accordance with Art. 6 (1) lit. f) GDPR to protect our legitimate interests and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data,
- in the event that a legal obligation exists for the disclosure pursuant to Art. 6 (1) lit. c) GDPR, as well as
- this is legally permissible and necessary according to Art. 6 (1) lit. b) GDPR for the processing of contractual relationships with you.
In the context of the processing operations described in this privacy statement, personal data may be transferred to the USA. Companies in the USA only have an adequate level of data protection if they have certified themselves under the EU-US Data Privacy Framework and thus the adequacy decision of the EU Commission pursuant to Art. 45 GDPR applies. We have explicitly mentioned this in the privacy policy for the service providers concerned. In order to protect your data in all other cases, we have concluded commissioned processing agreements based on the standard contractual clauses of the European Commission. If the standard contractual clauses are not sufficient to establish an adequate level of security, your consent pursuant to Article 49 (1) a) of the GDPR may serve as the legal basis for the transfer to third countries. This sometimes does not apply in the case of a data transfer to third countries for which the European Commission has issued an adequacy decision pursuant to Article 45 of the GDPR.
6. Technology
6.1 SSL/TLS-encryption
This site uses SSL or TLS encryption to guarantee the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact enquiries that you send to us as the operator. You can recognise an encrypted connection by the fact that the address bar of the browser contains a “https://” instead of a “http://” and by the lock symbol in your browser bar.
We use this technology to protect your transmitted data.
6.2 Data collection when visiting the website
If you only use our website for informational purposes, if you do not register or otherwise provide us with information or do not give your consent to processing that requires consent, we only collect data that is technically necessary for the provision of the service. This is regularly data that your browser transmits to our server (in so-called “server log files”). Our website collects a series of general data and information each time you or an automated system accesses a page. This general data and information is stored in the server log files. The following can be recorded:
- the browser types and versions used,
- the operating system used by the accessing system,
- the website from which an accessing system accesses our website (so-called referrer),
- the sub-pages accessed via an accessing system on our website,
- the date and time of access to the website,
- an internet Protocol (IP) address, and
- the internet service provider of the accessing system.
When using this general data and information, we do not draw any conclusions about your person. Rather, this information is required to
- deliver the contents of our website correctly,
- optimise the contents of our website as well as to advertise it,
- ensure the permanent operability of our IT systems and the technology of our website, and
- provide law enforcement authorities with the information necessary to prosecute in the event of a cyber-attack.
Therefore, the data and information collected will be used by us for statistical purposes only and for the purpose of increasing the data protection and data security of our enterprise to ensure an optimal level of protection for the personal data we process. The data of the server log files is stored separately from any personal data provided by a data subject.
The legal basis for data processing is Art. 6 (1) lit. f) GDPR. Our legitimate interest follows from the purposes for data collection listed above.
6.3 Hosting by All-Inkl
We host our website at ALL-INKL.COM – Neue Medien Münnich, Inh. René Münnich, Hauptstraße 68, 02742 Friedersdorf (All-Inkl).
When visiting our website, your personal data (e.g. IP addresses in log files) are processed on the servers of All-Inkl.
The use of All Inkl is based on Art. 6 (1) lit. f) GDPR. Our legitimate interest is the high-performance provision of our website.
We have concluded a corresponding agreement with All Inkl on the basis of GDPR for commissioned processing. This is a contract required by data protection law, which ensures that All-Inkl only processes the personal data of our website visitors according to our instructions and in compliance with the GDPR.
Additional information and All Inkl`s privacy policy can be found at: https://all-inkl.com/datenschutzinformationen/
7. Cookies
7.1 General information about cookies
We use cookies on our website. Cookies are small files that are automatically created by your browser and stored on your IT system (laptop, tablet, smartphone or similar) when you visit our website.
Information generated from the specific device used is stored in cookies. This does not mean, however, that we will gain immediate knowledge of your identity.
The use of cookies helps us make it more convenient for you to use our website. For example, we use session cookies to detect whether you have already visited individual pages on our website. These are erased automatically when you leave our website.
In addition, we also use temporary cookies to optimise user-friendliness, which are stored on your end device for a specific period of time. If you visit our site again to use our services, it is automatically recognised that you have already been with us and which entries and settings you have made so that you do not have to enter them again.
We also use cookies to statistically record the use of our website and to evaluate our offer for you for the purpose of optimisation. These cookies enable us to automatically recognise that you have already visited our website when you visit it again. The cookies set in this way are automatically deleted after a defined period of time. The respective storage period of the cookies can be found in the settings of the consent tool used.
7.2 Legal basis for the use of cookies
The data processed by the cookies, which are required for the proper functioning of the website, are thus necessary to protect our legitimate interests as well as those of third parties in accordance with Art. 6 (1) lit. f) GDPR.
For all other cookies, the following applies: You have given your consent to this within the meaning of Art. 6 (1) lit. a) GDPR via our opt-in cookie banner.
7.3 Cookiebot (Consent Management Tool)
We use the Consent Management Tool “Cookiebot” of Cybot A/S, Havnegade 39, 1058 Kopenhagen, Denmark. This service allows us to obtain and manage the consent of website useres for data processing.
Cookiebot collects data generated by end users who use our website. When an end user gives consent via the cookie consent tool, Cookiebot automatically logs the following
- The IP number of the end user in anonymised form (the last three digits are set to 0),
- Date and time of consent,
- User agent of the end user’s browser,
- The URL from which the consent was sent,
- An anonymous, random and encrypted key,
- The consent status of the end user, which serves as proof of consent.
The key and consent status are also stored in the end-user’s browser in the cookie “CookieConsent” so that the website can automatically read and follow the end-user’s consent in all subsequent page requests and future end-user sessions for up to 12 months. The key is used for proof of consent and for an option to check that the consent status stored in the end-user’s browser is unchanged from the original consent submitted to Cybot.
The functionality of the website is not guaranteed without the processing. The “CookieConsent” cookie set by Cookiebot is classified as necessary. There is no possibility for the user to object as long as there is a legal obligation to obtain the user’s consent to certain data processing operations (Art. 7 (1), 6 (1) lit. c) GDPR).
Cybot is a recipient of your personal data and acts as a processor for us.
Additional information on the service can be found at the following link: https://www.cookiebot.com/de/privacy-policy/
8. Contents of our website
8.1 Registration as a user
You have the option of registering on our website by providing personal data.
Which personal data is transmitted to us in this process can be seen from the respective input mask used for registration. The personal data you enter is collected and stored exclusively for internal use by us and for our own purposes. We may arrange for data to be passed on to one or more data processors, for example a parcel service provider, who will also use the personal data exclusively for an internal use attributable to us.
By registering on our website, the IP address assigned by your internet service provider (ISP), the date and the time of registration are also stored. This is done only for the purpose of preventing our services from being misused. If necessary, this data may be used to clarify the situation surrounding any crimes committed. In this respect, the storage of this data is necessary for our protection. As a matter of principle, this data is not disclosed to third parties. This does not apply if we are legally obliged to pass on the data or if the data is passed on for the purpose of criminal prosecution.
Your registration, including voluntary provision of personal data, also serves us to offer you content or services which, due to the nature of the matter, can only be offered to registered users. Registered persons are free to change the personal data provided during registration at any time or to have it completely erased from our database.
Upon request, we will provide you at any time with information about which personal data is stored about you. Furthermore, we will correct or delete personal data at your request, insofar as this does not conflict with any statutory retention obligations. A data protection officer named in this Privacy Policy and all other employees are available to the data subject as contact persons in this context.
The processing of your data is in the interest of a convenient and easy use of our website. This constitutes a legitimate interest within the meaning of Art. 6 (1) lit. f) GDPR.
8.2 Contact support / Contact form
Personal data is collected when contacting us (e.g. via contact form or e-mail). Which data is collected in the case of the use of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of answering your request or for contacting you and the associated technical administration. The legal basis for processing the data is our legitimate interest in responding to your request in accordance with Art. 6 (1) lit. f) GDPR. If your contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6 (1) lit. b) GDPR. Your data will be deleted after final processing of your request; this is the case if it can be inferred from the circumstances that the matter concerned has been conclusively clarified and the deletion does not conflict with any legal obligations to retain data.
8.3 Comment function Blog
We offer users the opportunity to leave individual comments on individual blog posts on a blog located on our website. A blog is a portal maintained on a website, usually publicly viewable, in which one or more persons, called bloggers or web bloggers, can post articles, or write down thoughts in so-called blogposts. The blogposts can usually be commented on by third parties.
If you leave a comment in the blog published on this website, details of the time you entered the comment and the username you selected will be stored and published in addition to the comments you leave. Furthermore, the IP address assigned by your internet service provider (ISP) is also logged. This storage of the IP address is done for security reasons and in case you have violated the rights of third parties or posted illegal content through a comment you have made. The storage of this personal data is therefore in our own interest so that we can exculpate ourselves in the event of an infringement. This constitutes a legitimate interest within the meaning of Art. 6 (1) lit. f) GDPR. The personal data collected will not be passed on to third parties, unless such a transfer is required by law or serves our legal defence.
8.4 Application Management / job exchange
We collect and process the personal data of applicants for the purpose of processing the application procedure. The processing may also take place electronically. This is particularly the case if an applicant submits the relevant application documents to us electronically, for example by e-mail or via a web form on the website. If we conclude an employment or service contract with an applicant, the transmitted data will be stored for the purpose of processing the employment relationship in compliance with the statutory provisions. If we do not conclude a contract with the applicant, the application documents are automatically deleted two months after notification of the rejection decision, provided that no other legitimate interests on our part oppose deletion. Another legitimate interest in this sense is, for example, a duty to provide evidence in proceedings under the German Equal Treatment Act (Allgemeines Gleichbehandlungsgesetz [AGG]).
The legal basis for processing your data is Art. 6 (1) lit. b) GDPR, Art. 88 GDPR icw § 26 (1) German Federal Data Protection Act (Bundesdatenschutzgesetz [BDSG]).
9. Newsletters
9.1 Newsletter for regular customers (without registration)
If you have provided us with your email address when purchasing goods or services, we may periodically email you offers for similar goods or services to those you have already purchased from our range. In accordance with § 7 (3) of the German Unfair Competition Act (Gesetz gegen den unlauteren Wettbewerb, UWG), we do not need to obtain your separate consent for this. In this respect, the data processing is carried out solely on the basis of our legitimate interest in personalized direct advertising in accordance with Art. 6 (1) lit. f) GDPR. If you have initially objected to the use of your e-mail address for this purpose, no e-mails will be sent by us. You are entitled to object to the use of your e-mail address for the aforementioned advertising purpose at any time with effect for the future by notifying the responsible person named at the beginning. For this, you will only incur transmission costs according to the prime rates. Upon receipt of your objection, the use of your e-mail address for advertising purposes will cease immediately.
9.2 Marketing newsletter (double opt-in)
On our website you are given the opportunity to subscribe to our company newsletter. What personal data is transmitted to us when ordering the newsletter, is determined by the input mask used for this purpose.
We use our newsletter to regularly communicate our offers to our customers and business partners. You can, therefore, only receive our company’s newsletter if
- You have a valid e-mail address and
- You have registered for newsletter delivery.
For legal reasons, a confirmation e-mail will be sent to the e-mail address that you entered for the first time for the newsletter dispatch using the double opt-in procedure. This confirmation e-mail is used to verify that you, as the owner of the e-mail address, have authorized the receipt of the newsletter.
When you register for the newsletter, we also store the IP address assigned by your Internet service provider (ISP) of the IT system used by you at the time of registration, as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of your e-mail address at a later date and therefore serves our legal protection.
The personal data collected in the context of a registration for the newsletter will be used exclusively for sending our newsletter. Furthermore, subscribers to the newsletter could be informed by e-mail if this is necessary for the operation of the newsletter service or a related registration, as could be the case in the event of changes to the newsletter offer or changes in technical circumstances. No personal data collected as part of the newsletter service will be passed on to third parties. The subscription to our newsletter can be cancelled by you at any time. The consent to the storage of personal data that you have given us for the newsletter dispatch can be revoked at any time. For the purpose of revoking the consent, you will find a corresponding link in each newsletter. Furthermore, it is also possible to unsubscribe from the newsletter mailing directly on our website at any time or to inform us of this in another way.
The legal basis for data processing for the purpose of sending newsletters is Art. 6 (1) lit. a) GDPR.
10. Our activities in social networks
To allow us to communicate with you on social networks and inform you about our services, we run our own pages on these social networks. If you visit one of our social media pages, we and the provider of the social media network are joint controllers (Art. 26 GDPR) regarding to the processing operations triggered thereby, which concern personal data.
We are not the original provider of these pages, but only use them within the scope of the options offered to us by the respective providers.
We would therefore like to point out as a precautionary measure that your data may also be processed outside of the European Union or the European Economic Area. Use of these networks may therefore involve data protection risks for you since the protection of your rights may be difficult, e.g. your rights to information, erasure, objection, etc. Processing on social networks frequently takes place directly for advertising purposes or for the analysis of user behaviour by network providers, and we have no control over this. If the provider creates user profiles, cookies are often used or user behaviour may be assigned directly to your own member profile on the respective social network (if you are logged in).
The processing operations of personal data described are carried out in accordance with Art. 6 (1) lit. f) GDPR on the basis of our legitimate interests and the legitimate interests of the respective provider in order to communicate with you in a timely manner or to inform you about our services. If you have to grant your consent to the respective providers to process your data as a user, the legal basis for this processing is Art. 6 (1) lit. a) GDPR in conjunction with Art. 7 GDPR.
Since we have no access to these providers’ databases, we would like to point out that you would be best placed to exercise your rights (e.g. to information, rectification, erasure, etc.) directly with the respective provider. More information on the processing of your data on social networks and your options for exercising your right to object or your right of revocation (opt out) is listed below for each of the social network providers we use:
10.1 Facebook
(Joint) Data controller responsible for data processing in Europe:
Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
Privacy Notice (Data Policy):
https://www.facebook.com/about/privacy
10.2 Instagram
(Joint) Data controller responsible for data processing in Europe:
Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland
Privacy Notice (Data Policy):
http://instagram.com/legal/privacy/
Opt-out and advertising settings:
https://www.instagram.com/accounts/privacy_and_security/
10.3 LinkedIn
(Joint) Data controller responsible for data processing in Europe:
LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland
Privacy Notice:
https://www.linkedin.com/legal/privacy-policy
10.4 YouTube
(Joint) Controller responsible for data processing in Europe:
Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Privacy Notice:
https://policies.google.com/privacy
11. Web analytics
11.1 Meta Pixel (formerly Facebook Pixel)
This website uses the “meta pixel” of Meta Platforms, Inc, 1 Hacker Way, Menlo Park, CA 94025, USA (“Meta”). If explicit consent is given, this allows the behaviour of users to be tracked after they have seen or clicked on a Meta advertisement. This process is used to evaluate the effectiveness of the advertisements for statistical and market research purposes and can help to optimise future advertising measures.
When you visit the website, the following data may be processed by the meta pixel:
- IP address,
- Device information,
- Browsing history,
- Interactions on our website (e.g. page views, clicks, conversions).
The data is stored and processed by Meta so that a connection to the respective user profile is possible and Meta can use the data for its own advertising purposes in accordance with the Facebook Data Usage Policy (https://www.facebook.com/about/privacy/). This enables Meta and its partners to place adverts on and off Facebook. A cookie may also be stored on your computer for these purposes.
The collected data is stored by Meta for a period of 180 days and then deleted if the website is not visited again by the user.
These processing operations are only carried out if express consent is given in accordance with Art. 6 (1) lit. a) GDPR.
Meta is certified under the EU-US Data Privacy Framework. This constitutes an adequacy decision pursuant to Art. 45 GDPR, meaning that personal data may also be transferred without further guarantees or additional measures.
11.2 Google Analytics 4 (GA4)
On our websites we use Google Analytics 4 (GA4), a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. (“Google”).
In this context, pseudonymised usage profiles are created and cookies are used. The information generated by the cookie about your use of this website can be, among other things:
- a short-term recording of the IP address without, permanent storage
- Browser information,
- Date and time of access,
- Device information,
- The URL of the visited website,
- Geographic location,
The pseudonymised data may be transferred by Google to a server in the USA and stored there.
The information is used to evaluate the use of the website, to compile reports on website activity and to provide other services related to website and internet use for the purposes of market research and demand-oriented design of these internet pages. This information may also be transferred to third parties if this is required by law or if third parties process this data on our behalf. Under no circumstances will your IP address be merged with other Google data.
These processing operations are carried out exclusively when explicit consent is given in accordance with Art. 6 (1) lit. a) GDPR.
The parent company Google LLC is certified as a US company under the EU-US Data Privacy Framework. There is hereby an adequacy decision pursuant to Art. 45 GDPR, so that a transfer of personal data may also take place without further guarantees or additional measures.
Additional information on the service can be found at the following link:
https://support.google.com/analytics/answer/12017362?hl=de
11.3 Google Analytics 4 (GA4) – Additional information on Google Signals
Google Signals is a feature in Google Analytics that collects session data from websites and apps where users are logged in with their Google Account and have enabled personalised advertising. It enables advanced analysis by linking user behaviour across different devices and providing additional information such as demographic characteristics and interests. Your consent to the use of Google Analytics (see above) also includes consent to the Google Signals add-on function.
11.4 Google Analytics 4 (GA4) – Additional information on Consent Mode, advanced implementation
Under the Digital Markets Act, Google is obliged to obtain user consent before processing user data for personalised advertising. Google fulfils this requirement with the “Consent Mode”. Users are obliged to implement this and thus prove that they have obtained the consent of website visitors.
Google offers two implementation modes, the basic and the advanced implementation.
We use the extended implementation method of Google Consent Mode. If you consent to data processing in connection with the use of GA4 (see above), a connection to Google is established, Google Analytics cookies are set and the corresponding processing is carried out. If you refuse consent, no Google Analytics cookies will be set. However, a unique “ping ID” will be generated and transmitted to Google. The Google code is executed, whereby only limited user data is transmitted to Google, including information such as:
- IP address
- Browser details
- Visited URL
A personalised user ID is not assigned.
If you have consented to the execution of Google Analytics 4, Consent Mode, extended implementation, the legal basis for the processing of personal data is Art. 6 (1) lit. a GDPR. In addition, it is in our legitimate interest within the meaning of Art. 6 (1) lit. f GDPR to use Google Analytics 4, Consent Mode, extended implementation, in order to obtain data on conversions without creating user profiles and thus increase profitability.
11.5 Google Analytics Remarketing
We have integrated Google Remarketing services on this website. The company operating the Google Remarketing services is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Remarketing is a function of Google AdWords that enables a company to display advertisements to Internet users who have previously visited the company’s website. The integration of Google Remarketing thus allows a company to create user-related advertising and consequently to display interest-relevant advertisements to the Internet user.
The purpose of Google Remarketing is the display of interest-relevant advertising. Google Remarketing enables us to display advertisements via the Google advertising network or to have them displayed on other Internet pages, which are tailored to the individual needs and interests of Internet users.
Google Remarketing sets a cookie on the IT system of the data subject. By setting the cookie, Google can recognise the visitors to our website when they subsequently visits websites that are also members of the Google advertising network. Each time you visit a website on which the Google Remarketing service has been integrated, your internet browser automatically identifies itself to Google. Within the scope of this technical procedure, Google obtains knowledge of personal data, such as your IP address or surfing behaviour, which Google uses, among other things, to display interest-relevant advertising.
The cookie is used to store personal information, such as the websites you visit. Each time you visit our website, personal data, including your IP address, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on this personal data collected via the technical procedure to third parties.
These processing operations are carried out exclusively when explicit consent is given in accordance with Art. 6 (1) lit. a) GDPR.
The parent company Google LLC is certified as a US company under the EU-US Data Privacy Framework. There is hereby an adequacy decision pursuant to Art. 45 GDPR, so that a transfer of personal data may also take place without further guarantees or additional measures.
Additional information on the service can be found at the following link:
https://www.google.de/intl/de/policies/privacy
11.6 Hotjar
This website uses Hotjar. The provider is Hotjar Ltd, Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta.
Hotjar is a tool for analysing your user behaviour on this website. With Hotjar, we can record your mouse movements, scrolling movements and clicks, among other things. Hotjar can also determine how long you have stayed with the mouse pointer on a certain spot. From this information, Hotjar creates so-called heat maps, which can be used to determine which areas of the website visitors prefer to look at.
Furthermore, we can determine how long you stayed on a page and when you left it. We can also determine at which point you abandoned your entries in a contact form (so-called conversion funnels). In addition, Hotjar can be used to obtain direct feedback from website visitors. This function serves to improve the web offers of the website operator.
Hotjar uses cookies. Cookies are small text files that are stored on your device and saved by your browser. They serve to make our offer more user-friendly, effective and secure. In particular, these cookies allow us to determine whether this website has been visited with a specific end device or whether the Hotjar functions have been deactivated for the browser in question. Hotjar cookies remain on your terminal device until you delete them.
You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. If you deactivate cookies, the functionality of this website may be limited.
These processing operations are carried out exclusively when explicit consent is given in accordance with Art. 6 (1) lit. a) GDPR.
Additional information on the service can be found at the following link:
https://help.hotjar.com/hc/en-us/categories/115001323967-About-Hotjar
11.7 LinkedIn Analytics
This website uses the retargeting tool a well as the conversion tracking of LinkedIn Ireland, Wilton Plaza, Wilton Place, Dublin 2, Irland (LinkedIn).
For this purpose, the LinkedIn Insight Tag is integrated on our website, which enables LinkedIn to collect statistical data about your visit and use of our website and to provide us with corresponding aggregated statistics on this basis. In addition, the service is used to be able to show you interest-specific and relevant offers and recommendations after you have found out about certain services, information and offers on the website. The relevant information is stored in a cookie.
As a rule, the following data are collected and processed in the process:
- IP-address,
- Device-information,
- Browser-information,
- Referrer-URL and
- Timestamp.
These processing operations are only carried out when express consent is given in accordance with Art. 6 (1) lit. a) GDPR. Your data will be stored until you withdraw your consent.
Personal data are kept for as long as they are necessary to fulfil the purpose of processing. The data will be deleted as soon as they are no longer necessary to achieve the purpose.
Within the scope of processing via LinkedIn, data may be transferred to the USA and Singapore. The US company is certified under the EU-US Data Privacy Framework. This constitutes an adequacy decision pursuant to Art. 45 GDPR, meaning that personal data may be transferred without further guarantees or additional measures. Furthermore the security of the transfer is regularly ensured by so-called standard contractual clauses, which guarantee that the processing of personal data is subject to a level of security that corresponds to that of the GDPR. If the standard contractual clauses are not sufficient to ensure an adequate level of security, your consent will be obtained in accordance with Art. 49 (1) lit. a) GDPR.
Additional information on the service can be found at the following link:
https://de.linkedin.com/legal/privacy-policy
12. Advertising
12.1 Google Ads (AdWords) Remarketing/Retargeting
Our website uses the functions of Google Ads. We use these to advertise this website in Google search results and on third-party websites. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). For this purpose, Google sets a cookie in the browser of your terminal device, which automatically enables interest-based advertising by means of a pseudonymous cookie ID and on the basis of the pages you have visited.
Additional data processing will only take place if you have granted Google permission to link your internet and app browsing history to your Google Account and to use information from your Google Account to personalise the ads you view on the web. In this case, if you are logged into Google while visiting our website, Google will use your data together with Google Analytics data to create and define target group lists for cross-device remarketing. For this purpose, your personal data will be temporarily linked by Google with Google Analytics data in order to form said target groups.
These processing operations are only carried out when express consent is given in accordance with Art. 6 (1) lit. a) GDPR.
The parent company Google LLC is certified as a US company under the EU-US Data Privacy Framework. There is hereby an adequacy decision pursuant to Art. 45 GDPR, so that a transfer of personal data may also take place without further guarantees or additional measures.
Additional information on the service can be found at the following link:
https://www.google.com/policies/technologies/ads/
12.2 Google Ads with Conversion-Tracking
We have integrated Google Ads on this website. The operating company of the Google Ads services is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Ads is an Internet advertising service that allows advertisers to place ads both in Google’s search engine results and in the Google advertising network. Google Ads allows an advertiser to specify certain keywords in advance, by means of which an ad is displayed in Google’s search engine results exclusively when the user retrieves a keyword-relevant search result using the search engine. In the Google advertising network, the ads are distributed on topic-relevant websites by means of an automatic algorithm and in compliance with the previously defined keywords.
The purpose of Google Ads is to promote our website by displaying interest-relevant advertisements ads on the websites of third-party companies and in the search engine results of the Google search engine and a display of third-party advertisements on our website.
If you access our website via a Google ad, a so-called conversion cookie is stored on your IT system by Google. A conversion cookie loses its validity after thirty days and is not used to identify you. If the cookie has not yet expired, the conversion cookie is used to track whether certain sub-pages, for example the shopping cart of an online store system, have been called up on our website. Through the conversion cookie, both we and Google can track whether a user has reached our website via an AdWords ad, generated a turnover, i.e. completed or cancelled a purchase of goods.
The data and information collected through the use of the conversion cookie are used by Google to create visit statistics for our website. These visit statistics are in turn used by us to determine the total number of users who were referred to us via ads, i.e. to determine the success or failure of the respective Ads ad and to optimize our Ads ads for the future. Neither our company nor other advertisers of Google Ads receive information from Google by means of which you could be identified.
By means of the conversion cookie, personal information, for example the Internet pages visited by you, is stored. Each time you visit our website, personal data, including the IP address of the internet connection you use, is transmitted to Google in the United States of America. This personal data is stored by Google in the United States of America. Google may pass on these personal data collected via the technical procedure to third parties.
These processing operations are carried out exclusively when explicit consent is given in accordance with Art. 6 (1) lit. a) GDPR.
The parent company Google LLC is certified as a US company under the EU-US Data Privacy Framework. There is hereby an adequacy decision pursuant to Art. 45 GDPR, so that a transfer of personal data may also take place without further guarantees or additional measures.
Additional information on the service can be found at the following link:
https://www.google.de/intl/de/policies/privacy/
12.3 Google Ads with enhanced Conversions
We have integrated Google Ads on this website. The operating company of the Google Ads services is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Google Ads is an Internet advertising service that allows advertisers to place ads in Google’s search engine results as well as in the Google advertising network. The purpose of Google Ads is to advertise our website by displaying interest-relevant advertisements on the websites of third-party companies and in the search engine results of the Google search engine and to display third-party advertisements on our website.
If you reach our website via a Google advertisement, a so-called conversion cookie is stored on your IT system by Google. A conversion cookie loses its validity after thirty days and is not used to identify you. If the cookie has not yet expired, the conversion cookie is used to track whether certain sub-pages, for example the shopping cart of an online store system, have been accessed on our website. The conversion cookie allows both us and Google to track whether a user who arrived on our website via a Google Ads ad generated a sale, i.e. completed or cancelled a purchase.
We use the option of enhanced conversions from Google Ads. For this purpose, we transmit personal data collected by us, such as telephone numbers or email addresses to Google. This data is matched with event data on Google Ads in such a way to capture more conversions.
Each time you visit our website, personal data, including the IP address of the Internet connection you are using, is transmitted to Google in the United States of America. Google may pass on this personal data collected via the technical procedure to third parties.
These processing operations are carried out exclusively when explicit consent is given in accordance with Art. 6 (1) lit. a) GDPR.
The parent company Google LLC is certified as a US company under the EU-US Data Privacy Framework. There is hereby an adequacy decision pursuant to Art. 45 GDPR, so that a transfer of personal data may also take place without further guarantees or additional measures.
You can view the privacy policy and further information of Google Ads at:
https://www.google.de/intl/de/policies/privacy/ and
https://support.google.com/adspolicy/answer/9755941?hl=de&ref_topic=7012636&sjid=9061832235671554201-EU
12.4 Google Ads – Additional information on Consent Mode, extended implementation
Under the Digital Markets Act, Google is obliged to obtain user consent before processing user data for personalised advertising. Google fulfils this requirement with the “Consent Mode”. Users are obliged to implement this and thus prove that they have obtained the consent of website visitors.
Google offers two implementation modes, the basic and the advanced implementation.
We use the extended implementation method of Google Consent Mode. If you consent to data processing in connection with the use of Google Ads (see above), a connection to Google is established, Google Analytics cookies are set and the corresponding processing is carried out. If you refuse your consent, no Google Ads cookies will be set. However, a unique “ping ID” will be generated and transmitted to Google. The Google code is executed, whereby only limited user data is transmitted to Google, including information such as
- IP address
- Browser details
- Visited URL
A personalised user ID is not assigned.
If you have consented to the execution of Google Ads, Consent Mode, extended implementation, the legal basis for the processing of personal data is Art. 6 (1) lit. a GDPR. In addition, it is in our legitimate interest within the meaning of Art. 6 (1) lit. f GDPR to use Google Analytics 4, Consent Mode, extended implementation, in order to obtain data on conversions without creating user profiles and thus increase profitability.
13. Plugins and other services
13.1 Google Maps
We use Google Maps (API) on our website. The operating company of Google Maps is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Ireland Limited is part of the Google group of companies with headquarters at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Maps is a web service for displaying interactive (land) maps in order to visually present geographical information. By using this service, for example, our location can be displayed to you and a possible approach can be facilitated.
Already when calling up those sub-pages in which the map of Google Maps is integrated, information about your use of our website (such as your IP address) is transmitted to Google servers in the USA and stored there, as long as you have given your consent within the meaning of Art. 6 (1) lit. a) GDPR. In addition, Google Maps reloads the Google Web Fonts and Google Photo (as well as google stats). The provider of these services is also Google Ireland Limited. When you call up a page that embeds Google Maps, your browser loads the web fonts and photos required to display Google Maps into your browser cache. Also for this purpose, the browser you are using establishes a connection to Google’s servers. Through this, Google obtains knowledge that our website was accessed via your IP address. This occurs regardless of whether Google provides a user account through which you are logged in or whether no user account exists. If you are logged in to Google, your data will be directly assigned to your account. If you do not want the assignment with your profile at Google, you must log out of your Google user account. Google stores your data (even for users who are not logged in) as usage profiles and evaluates them. You have the right to object to the creation of these user profiles, and to exercise this right you must contact Google as follows.
If you do not agree to the future transmission of your data to Google in the context of the use of Google Maps, you also have the option of completely disabling the Google Maps web service by turning off the JavaScript application in your browser. Google Maps and thus also the map display on this website can then not be used.
These processing operations are carried out exclusively when explicit consent is given in accordance with Art. 6 (1) lit. a) GDPR.
Additional information on the service can be found at the following links
https://www.google.de/intl/de/policies/terms/regional.html
https://www.google.com/intl/de_US/help/terms_maps.html
The parent company Google LLC is certified as a US company under the EU-US Data Privacy Framework. There is hereby an adequacy decision pursuant to Art. 45 GDPR, so that a transfer of personal data may also take place without further guarantees or additional measures.
The privacy plicy of Google Maps could be found here: (“Google Privacy Policy”): https://www.google.de/intl/de/policies/privacy/
13.2 Google Tag Manager
On this website we use the Google Tag Manager service. The operating company of Google Tag Manager is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Ireland Limited is part of the Google group of companies headquartered at 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Through this tool, “website tags” (i.e. keywords, which are integrated into HTML elements) can be implemented and managed via an interface. Through the use of Google Tag Manager, we can automatically track which button, link or personalized image you have actively clicked on and can then record which content of our website is of particular interest to you.
The tool also triggers other tags, which in turn may collect data. Google Tag Manager does not access this data. If you have made a deactivation at the domain or cookie level, this remains in place for all tracking tags implemented with Google Tag Manager.
These processing operations are carried out exclusively when explicit consent is given in accordance with Art. 6 (1) lit. a) GDPR.
The parent company Google LLC is certified as a US company under the EU-US Data Privacy Framework. There is hereby an adequacy decision pursuant to Art. 45 GDPR, so that a transfer of personal data may also take place without further guarantees or additional measures.
Additional information on the service can be found at the following link:
https://www.google.com/intl/de/policies/privacy/
13.3 Zoho CRM-System
We use the CRM system of the provider Zoho Corporation, 4141 Hacienda Drive Pleasanton, CA 94588, USA (“Zoho CRM”). Zoho CRM is a software CRM solution for the management of customer relationships and includes, among other things, the following functions:
- Deal management, lead management and task management,
- E-mail tracking and notifications,
- E-mail templates and appointment scheduling,
- Online booking system for appointments,
- Sharing of documents,
- Telephony solutions such as automatic call recording & logging.
Different departments such as marketing, sales and customer service work together with the described software.
The provider of Zoho CRM necessarily receives knowledge of the above-mentioned data, as far as this is provided for in the context of our order processing contract (Art. 28 GDPR), with Zoho CRM. These may include, on the one hand, the IP addresses, but also the names, addresses, e-mail addresses and telephone numbers.
If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 (1) lit. a) GDPR. The legal basis for the use of the service in the context of existing contractual relationships or contractual relationships to be initiated is Art. 6 (1) lit. b) GDPR. In all other cases, the legal basis for processing your personal data is Art. 6 (1) lit. f) GDPR. Here, our interest is in the effective coordination of internal as well as external communication and the management of customer relationships.
To the extent Zoho CRM processes personal data in connection with its own legitimate business operations, Zoho CRM is an independent data controller for such use and, as such, is responsible for compliance with applicable laws and obligations of a data controller.
This US company is certified under the EU-US Data Privacy Framework. There is hereby an adequacy decision pursuant to Art. 45 GDPR, so that a transfer of personal data may also take place without further guarantees or additional measures.
Additional information on the service can be found at the following link:
https://www.zoho.com/gdpr.html
14. Your rights as a data subject
14.1 Right to confirmation
You have the right to request confirmation from us as to whether personal data relating to you will be processed.
14.2 Right to information (Article 15 GDPR)
You have the right to obtain information about the personal data stored about you at any time, free of charge, as well as the right to access a copy of such data from us, in accordance with the statutory provisions.
14.3 Right to rectification (Article 16 GDPR)
You have the right to request the immediate rectification of incorrect personal data relating to yourself. Furthermore, the data subject has the right to request the completion of incomplete personal data, taking into account the purposes of the processing.
14.4 Erasure (Article 17 GDPR)
You have the right to demand that we erase the personal data relating to you be deleted without delay, provided that one of the reasons provided by law applies and if processing or further storage is not required.
14.5 Restriction to processing (Article 18 GDPR)
You have the right to request that we restrict the processing of your data if one of the legal requirements is met.
14.6 Data transferability (Article 20 GDPR)
You have the right obtain personal data relating to you that you provided us in a structured, commonly used and machine-readable format. You also have the right to transfer this data to another controller without hindrance by us, to whom the personal data was provided, provided that the processing is based on the consent pursuant to Art. 6 (1) lit. a) GDPR or Art. 9 (2) lit. a) GDPR or on a contract pursuant to Art. 6 (1) lit. b) GDPR, and the data are processed using automated procedures, unless processing is necessary to complete a task, is in the public interest or is carried out in the exercise of an official authority assigned to us.
Furthermore, when exercising your right to data transferability pursuant to Art. 20 (1) GDPR, you have the right to have personal data transferred directly from one controller to another, provided this is technically feasible and does not impede the rights and freedoms of other persons.
14.7 Objection (Article 21 GDPR)
You have the right to lodge an objection to the processing of personal data relating to you for reasons relating to your particular situation where this is done on the basis of Art. 6 (1) lit. e) (data processing in the public interest) or lit. f) (data processing on the basis of the weighing of legitimate interests) GDPR.
This also applies to profiling based on these provisions pursuant to Article 4 Number 4 GDPR.
Should you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling and legitimate reasons for such processing that outweigh your interests, rights and freedoms, or where processing serves the assertion, exercise or defence of legal claims.
In individual cases, we process your personal data for direct marketing purposes. You have the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling where this is connected to this kind of direct marketing. Should you object to the processing of your data for direct marketing purposes, we will no longer process your personal data for this purpose.
14.8 Revocation of consent regarding data protection
You have the right to revoke any consent to the processing of personal data at any time with future effect.
14.9 Lodging a complaint with a supervisory authority
You have the right to complain to a supervisory authority responsible for data protection about our processing of personal data.
15. Version and amendments to the Privacy Notice
This Privacy Policy is currently valid.
Due to the further development of our Internet pages and offers or due to changed legal or official requirements, it may become necessary to change this Privacy Policy. You can access and print out the current data protection declaration at any time on the website under https://frameworx.de/en/privacy/.