Privacy policy

1) Information on the Collection of Personal Data and Contact Details of the Controller

1.1 We are pleased that you are visiting our website and thank you for your interest. On the following pages, we inform you about the handling of your personal data when using our website. Personal data is all data with which you can be personally identified.

1.2 The controller in charge of data processing on this website, within the meaning of the General Data Protection Regulation (GDPR), is Dr. Elmar Schlappack, Stadels 7, 88179 Oberreute, Deutschland, Tel.: +49 151 599 83713, E-Mail: info@elmar.digital. The controller in charge of the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

2) Data Collection When You Visit Our Website

2.1 When using our website for information only, i.e. if you do not register or otherwise provide us with information, we only collect data that your browser transmits to our server (so-called "server log files"). When you visit our website, we collect the following data that is technically necessary for us to display the website to you:

  • Our visited website
  • Date and time at the moment of access
  • Amount of data sent in bytes
  • Source/reference from which you came to the page
  • Browser used
  • Operating system used
  • IP address used (if applicable: in anonymized form)

Data processing is carried out in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to check the server log files subsequently, if there are any concrete indications of illegal use.

2.2 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller). You can recognize an encrypted connection by the character string https:// and the lock symbol in your browser line.

3) Cookies

In order to make your visit to our website more attractive and to enable the use of certain functions, we use cookies, i.e. small text files that are stored on your end device. In some cases, these cookies are automatically deleted again after the browser is closed (so-called "session cookies"), in other cases, these cookies remain on your end device for longer and allow page settings to be saved (so-called "persistent cookies"). In the latter case, you can find the duration of the storage in the overview of the cookie settings of your web browser.

If personal data is also processed by individual cookies set by us, the processing is carried out either in accordance with Art. 6 (1) point b GDPR for the performance of the contract, in accordance with Art. 6 (1) point a GDPR in the case of consent given or in accordance with Art. 6 (1) point f GDPR to safeguard our legitimate interests in the best possible functionality of the website as well as a customer-friendly and effective design of the page visit.

You can set your browser in such a way that you are informed about the setting of cookies and you can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general.

Please note that the functionality of our website may be limited if cookies are not accepted.

4) Contacting Us

4.1 WhatsApp Business

We offer visitors to our website the opportunity to contact us via the WhatsApp news service of WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. For this purpose we use the so-called "Business Version" of WhatsApp.

If you contact us via WhatsApp in connection with a specific business transaction (e.g. an order placed), we will store and use the mobile telephone number you use at WhatsApp and - if provided - your first name and surname in accordance with Art. 6 para. 1 lit. b. GDPR to process and answer your request. On the basis of the same legal basis, we will ask you via WhatsApp to provide further data (order number, customer number, address or e-mail address), if necessary, in order to be able to allocate your enquiry to a specific transaction.

If you use our WhatsApp contact for general enquiries (e.g. about the range of services, availability or our website), we will store and use the mobile phone number you use at WhatsApp and - if provided - your first and last name in accordance with Art. 6 Para. 1 lit. f GDPR on the basis of our justified interest in the efficient and prompt provision of the requested information.

Your data will always be used only to answer your request via WhatsApp. Your data will not be passed on to third parties.

Please note that WhatsApp Business gains access to the address book of the mobile device we use for this purpose and automatically transfers telephone numbers stored in the address book to a server of the parent company Meta Platforms Inc. in the USA. To operate our WhatsApp Business account, we use a mobile device whose address book stores only the WhatsApp contact data of those users who have also contacted us via WhatsApp.

This ensures that each person whose WhatsApp contact data is stored in our address book has already consented to the transmission of his WhatsApp telephone number from the address books of his chat contacts in accordance with Art. 6 Para. 1 lit. a GDPR when using the app on his device for the first time by accepting the WhatsApp terms of use. The transmission of data of such users who do not use WhatsApp and/or have not contacted us via WhatsApp is therefore excluded.

For the purpose and scope of data collection and the further processing and use of data by WhatsApp, as well as your rights and setting options for protecting your privacy, please refer to WhatsApp's data protection information: https://www.whatsapp.com/legal/?eea=1#privacy-policy

In the course of the above-mentioned processing, data may be transferred to servers of Meta Platforms Inc. in the USA.

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

4.2 When you contact us (e.g. via contact form or e-mail), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for establishing contact and for the associated technical administration.

The legal basis for processing data is our legitimate interest in responding to your request in accordance with Art. 6 (1) point f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) point b GDPR. Your data will be deleted after final processing of your enquiry; this is the case if it can be inferred from the circumstances that the facts in question have been finally clarified, provided there are no legal storage obligations to the contrary.

5) Use of Client Data for Direct Advertising

5.1 Subscribe to our e-mail newsletter

If you register for our e-mail newsletter, we will regularly send you information about our offers. The only mandatory data for sending the newsletter is your e-mail address. The provision of further data is voluntary and will be used to address you personally. We use the so-called double opt-in procedure for sending the newsletter. This means that we will only send you an e-mail newsletter once you have expressly confirmed that you consent to receiving newsletters. We will then send you a confirmation e-mail asking you to confirm that you wish to receive the newsletter in future by clicking on an appropriate link.

By activating the confirmation link, you give us your consent for the use of your personal data pursuant to Art. 6 (1) point a GPPR. When you register for the newsletter, we store your IP address entered by your Internet service provider (ISP) as well as the date and time of registration for the purpose of tracing any possible misuse of your e-mail address at a later date. The data collected by us when you register for the newsletter is used exclusively for the promotional purposes by way of the newsletter. You can unsubscribe from the newsletter at any time via the link provided for this purpose in the newsletter or by sending a corresponding message to the responsible person named at the beginning. After unsubscribing, your e-mail address will be deleted from our newsletter distribution list immediately, unless you have expressly consented to further use of your data, or we reserve the right to a more extensive use your data which is permitted by law and about which we inform you in this declaration.

5.2 CleverReach

Our e-mail newsletters are sent via this provider: CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede

On the basis of our legitimate interest in effective and user-friendly newsletter marketing, we pass on the data you provided when registering for the newsletter to this provider in accordance with Art. 6 (1) point f GDPR so that they can send the newsletter on our behalf.

Subject to your express consent pursuant to Art. 6 (1) point a GDPR, the provider also carries out a statistical analysis of the success of newsletter campaigns by means of web beacons or tracking pixels in the emails sent, which can measure opening rates and specific interactions with the newsletter content. In the process, end device information (e.g. time of page view, IP address, browser type and operating system) is also collected and analysed, but not combined with other data records.

You can revoke your consent to newsletter tracking at any time with effect for the future.

We have concluded an order processing agreement with the provider, which safeguards the data of our website visitors and prohibits a transfer to third parties.

5.3 WhatsApp newsletter

If you subscribe to our WhatsApp newsletter, we will regularly send you information about our offers via WhatsApp. Only your mobile phone number is required for sending the newsletter.

To send the newsletter, please add our mobile phone number to the address book of your mobile phone and send us the message "Start" via WhatsApp. By sending this WhatsApp message, you give us your consent to use your personal data in accordance with Art. 6 (1) point a GDPR for the purpose of sending the newsletter. We will then add you to our newsletter distribution list.

The data we collect when you subscribe to the newsletter will be processed exclusively for the purpose of addressing you in an advertising manner by the newsletter. You can unsubscribe from the newsletter at any time by sending us the message "Stop" via WhatsApp. After unsubscribing, your mobile phone number will be immediately deleted from our newsletter distribution list, unless you have expressly consented to further use of your data or we reserve the right to use data beyond this, which is legally permitted and about which we inform you in this policy.

Please note that WhatsApp obtains access to the address book of the mobile device used by us for sending the newsletter and automatically transfers telephone numbers stored in the address book to a Facebook server in the USA.

For sending our WhatsApp newsletter, we therefore use a mobile end device in whose address book only the WhatsApp contact data of our newsletter recipients are stored. This ensures that each person whose WhatsApp contact data is stored in our address book has already consented to the transfer of their WhatsApp telephone number from the address books of their chat contacts in accordance with Art. 6 (1) point a GDPR when using the app on their device for the first time by accepting the WhatsApp terms of use. A transfer of data of such users who do not use WhatsApp and/or have not contacted us via WhatsApp is excluded in this respect.

For the purpose and scope of the data collection and the further processing and use of the data by WhatsApp, as well as your rights in this regard and setting options for protecting your privacy, please refer to the WhatsApp privacy policy: https://www.whatsapp.com/legal/privacy-policy-eea?lang=en

In the course of the above-mentioned processing, data may be transferred to servers of Meta Platforms Inc. in the USA.

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

6) Web Analysis Services

Google Analytics 4

This website uses Google Analytics 4, a service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"), which can be used to analyze the use of websites.

When using Google Analytics 4, so-called "cookies" are used as standard. Cookies are text files that are stored on your terminal device and enable an analysis of your use of a website. The information collected by cookies about your use of the website (including the IP address transmitted by your terminal device, shortened by the last digits, see below) is usually transmitted to a Google server and stored and processed there. This may also result in the transmission of information to the servers of Google LLC, a company based in the USA, where the information is further processed.

When using Google Analytics 4, the IP address transmitted by your terminal device when you use the website is always collected and processed by default and automatically only in an anonymized manner, so that a direct personal reference of the collected information is excluded. This automatic anonymization is carried out by shortening the IP address transmitted by your terminal device by Google within member states of the European Union (EU) or other contracting states of the Agreement on the European Economic Area (EEA) by the last digits.

On our behalf, Google uses this and other information to evaluate your use of the website, to compile reports (reports) on your website activities or your usage behavior and to provide us with other services related to your website usage and internet usage. In this context, the IP address transmitted and shortened by your terminal device within the scope of Google Analytics 4 will not be merged with other data from Google. The data collected in the context of the use of Google Analytics 4 will be retained for 2 months and then deleted.

Google Analytics 4 also enables the creation of statistics with statements about age, gender and interests of website users on the basis of an evaluation of interest-based advertising and with the involvement of third-party information via a special function, the so-called "demographic characteristics". This makes it possible to determine and distinguish between groups of website users for the purpose of targeting marketing measures. However, data collected via the "demographic characteristics" cannot be assigned to a specific person and thus not to you personally. This data collected via the "demographic characteristics" function is retained for two months and then deleted.

All processing described above, in particular the setting of Google Analytics cookies for the storage and reading of information on the terminal device used by you for the use of the website, will only take place if you have given us your express consent for this in accordance with Art. 6 (1) lit. a GDPR. Without your consent, Google Analytics 4 will not be used during your use of the website.

You can revoke your consent once given at any time with effect for the future. To exercise your revocation, please deactivate this service via the "Cookie Consent Tool" provided on the website.

Google Signals
On this website, the "Google Signals" service can also be used as an extension of Google Analytics 4. With Google Signals, cross-device reports can be created by Google (so-called "cross-device tracking"). If you have activated "personalised ads" in your Google account settings and you have linked your internet-enabled devices to your Google account, Google can analyse user behaviour across devices and create database models based on this, provided you have given your consent to the use of Google Analytics in accordance with Art. 6 Para. 1 letter a GDPR (see above). The logins and device types of all page visitors who were logged into a Google account and performed a conversion are taken into account. The data shows, among other things, on which device you first clicked on an ad and on which device the associated conversion took place. Insofar as Google Signals is used, we do not receive any personal data from Google, but only statistics compiled on the basis of Google Signals. You have the option of deactivating the "personalised ads" function in the settings of your Google account and thus turning off the cross-device analysis. To do this, follow the instructions on this page: https://support.google.com/ads/answer/2662922?hl=de
Further information can be found here: https://support.google.com/analytics/answer/7532985?hl=de

User IDs
As an extension of Google Analytics 4, the "UserIDs" function can also be used on this website. By assigning individual UserIDs, we can have Google create cross-device reports (so-called "cross-device tracking"). This means that your usage behaviour can also be analysed across devices if you have given your corresponding consent to the use of Google Analytics in accordance with Art. 6 Para. 1 letter a GDPR, if you have set up a personal account by registering on this website and are logged into your personal account on different end devices with your relevant login data. The data collected in this way shows, among other things, on which end device you clicked on an ad for the first time and on which end device the relevant conversion took place.

We have concluded a so-called data processing agreement with Google for our use of Google Analytics 4, by which Google is obliged to protect the data of our website users and not to pass it on to third parties.

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

Further legal information on Google Analytics 4 can be found at the following link: https://policies.google.com/privacy?hl=en

Details on the processing triggered by Google Analytics 4 and Google's handling of data from websites can be found here: https://policies.google.com/technologies/partner-sites

7) Site functionalities

Microsoft Teams

We use this provider to conduct online meetings, video conferences and/or webinars: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA

The provider processes different data, whereby the scope of the processed data depends on the data you provide before or during the participation in an online meeting, video conference or webinar. Your data as a communication participant is processed and stored on servers of the provider. This may include, in particular, your registration data (name, e-mail address, telephone number (optional) and password) and session data (topic, participant IP address, device information, description (optional)). In addition, participants' image and sound contributions as well as voice input in chats may be processed.

For the processing of personal data that is necessary for the performance of a contract with you (this also applies to processing operations that are necessary for the implementation of pre-contractual measures), Art. 6 (1) point b GDPR serves as the legal basis. If you have given us your consent to process your data, the processing is based on Art. 6 (1) point a GDPR. You can revoke your consent at any time with effect for the future.
In addition, the legal basis for data processing when conducting online meetings, video conferences or webinars is our legitimate interest pursuant to Art. 6 (1) point f GDPR in the effective conduct of the online meeting, webinar or video conference.

We have concluded an order processing agreement with the provider, which ensures the protection of our website visitors' data and prohibits unauthorised disclosure to third parties.

For data transfers to the USA, the provider participates in the EU-US Data Privacy Framework, which ensures compliance with the European level of data protection on the basis of an adequacy decision by the European Commission.

8) Tools and Miscellaneous

This website uses a so-called "cookie consent tool" to obtain effective user consent for cookies and cookie-based applications that require consent. The "cookie consent tool" is displayed to users in the form of an interactive user interface when they access the page, on which consent for certain cookies and/or cookie-based applications can be given by ticking the appropriate box. Through the use of the tool, all cookies/services requiring consent are only loaded if the respective user provides the corresponding consent by ticking the corresponding box. This ensures that such cookies are only set on the respective end device of the user if consent has been granted.

The tool sets technically necessary cookies to save your cookie preferences. Personal user data is generally not processed.
If, in individual cases, personal data (such as the IP address) is processed for the purpose of storing, assigning or logging cookie settings, this is done in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in legally compliant, user-specific and user-friendly consent management for cookies and thus in a legally compliant design of our website.

Further legal basis for the processing is Art. 6 (1) point c GDPR. As the responsible party, we are subject to the legal obligation to make the use of technically unnecessary cookies dependent on the respective user consent.

Further information on the operator and the setting options of the cookie consent tool can be found directly in the corresponding user interface on our website.

9) Rights of the Data Subject

9.1 The applicable data protection law grants you the following comprehensive rights of data subjects (rights of information and intervention) vis-à-vis the data controller with regard to the processing of your personal data:

  • Right of access by the data subject pursuant to Art. 15 GDPR;
  • Right to rectification pursuant to Art. 16 GDPR;
  • Right to erasure (“right to be forgotten”) pursuant to Art. 17 GDPR;
  • Right to restriction of processing pursuant to Art. 18 GDPR;
  • Right to be informed pursuant to Art. 19 GDPR;
  • Right to data portability pursuant to Art. 20 GDPR;
  • Right to withdraw a given consent pursuant to Art. 7 (3) GDPR;
  • Right to lodge a complaint pursuant to Art. 77 GDPR.

9.2 RIGHT TO OBJECT

IF, WITHIN THE FRAMEWORK OF A CONSIDERATION OF INTERESTS, WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR PREDOMINANT LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON THE GROUNDS THAT ARISE FROM YOUR PARTICULAR SITUATION.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN PROVE COMPELLING REASONS WORTHY OF PROTECTION FOR PROCESSING WHICH OUTWEIGH YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS.

IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA WHICH ARE USED FOR DIRECT MARKETING PURPOSES. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT ADVERTISING PURPOSES.

10) Duration of Storage of Personal Data

The duration of the storage of personal data is based on the respective legal basis, the purpose of processing and - if relevant – on the respective legal retention period (e.g. commercial and tax retention periods).

If personal data is processed on the basis of an express consent pursuant to Art. 6 (1) point a GDPR, this data is stored until the data subject revokes his consent.

If there are legal storage periods for data that is processed within the framework of legal or similar obligations on the basis of Art. 6 (1) point b GDPR, this data will be routinely deleted after expiry of the storage periods if it is no longer necessary for the fulfillment of the contract or the initiation of the contract and/or if we no longer have a justified interest in further storage.

When processing personal data on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection in accordance with Art. 21 (1) GDPR, unless we can provide compelling grounds for processing worthy of protection which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.

If personal data is processed for the purpose of direct marketing on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection pursuant to Art. 21 (2) GDPR.

Unless otherwise stated in the information contained in this declaration on specific processing situations, stored personal data will be deleted if it is no longer necessary for the purposes for which it was collected or otherwise processed.