Privacy policy
This translation is provided for your convenience. In case of doubt, the German version is legally binding.
This privacy policy explains the nature, scope and purpose of the processing of personal data (hereinafter "data") in the course of providing our services and within our online offering and the associated websites, functions and content, as well as external online presences such as our social media profiles (hereinafter jointly referred to as "online offering"). With regard to the terms used, such as "processing" or "controller", we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Controller
addservice media GmbH
Otto-Volger-Str. 19
65843 Sulzbach am Taunus
Germany
Email: info@addservicemedia.com
Managing Director: Junaid Din
Link to the imprint: https://www.addservicemedia.com/en/imprint
Contact data protection officer:
dataprotection@addservicemedia.com
Types of data processed
- Inventory data (e.g. personal master data, names or addresses).
- Contact data (e.g. email, telephone numbers).
- Content data (e.g. text entries, photographs, videos).
- Usage data (e.g. websites visited, interest in content, access times).
- Meta/communication data (e.g. device information, IP addresses).
Categories of data subjects
Visitors and users of the online offering (hereinafter we also refer to the data subjects collectively as "users").
Purpose of processing
- Provision of the online offering, its functions and content.
- Responding to contact requests and communicating with users.
- Security measures.
- Reach measurement/marketing
Terms used
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
"Processing" means any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and covers practically every handling of data.
"Pseudonymisation" means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
"Profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
"Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
"Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Art. 13 GDPR, we inform you of the legal bases of our data processing. For users within the scope of the General Data Protection Regulation (GDPR), i.e. the EU and the EEA, the following applies unless the legal basis is stated in the privacy policy:
The legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 GDPR;
The legal basis for processing in order to perform our services and carry out contractual measures as well as to respond to enquiries is Art. 6(1)(b) GDPR;
The legal basis for processing in order to comply with our legal obligations is Art. 6(1)(c) GDPR;
In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6(1)(d) GDPR serves as the legal basis.
The legal basis for processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Art. 6(1)(e) GDPR.
The legal basis for processing to safeguard our legitimate interests is Art. 6(1)(f) GDPR.
The processing of data for purposes other than those for which it was collected is governed by Art. 6(4) GDPR.
The processing of special categories of data (in accordance with Art. 9(1) GDPR) is governed by Art. 9(2) GDPR.
Security measures
In accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.
These measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access, input, disclosure, ensuring availability and separation of the data. Furthermore, we have established procedures to ensure that data subjects' rights are exercised, data is deleted and threats to data are responded to. We also take the protection of personal data into account when developing or selecting hardware, software and procedures, in accordance with the principle of data protection by design and by default.
Cooperation with processors, joint controllers and third parties
If, in the course of our processing, we disclose data to other persons and companies (processors, joint controllers or third parties), transfer it to them or otherwise grant them access to the data, this is done only on the basis of a legal permission (e.g. if a transfer of data to third parties, such as payment service providers, is necessary for the performance of a contract), if users have consented, if a legal obligation provides for it or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we disclose or transfer data to other companies in our group of companies or otherwise grant them access, this is done in particular for administrative purposes as a legitimate interest and, beyond that, on a basis that complies with the legal requirements.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this occurs in the context of using third-party services or disclosing or transferring data to other persons or companies, this only takes place if it is necessary to fulfil our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to express consent or a contractually required transfer, we only process or have data processed in third countries with a recognised level of data protection, which include US processors certified under the "Privacy Shield", or on the basis of special guarantees, such as a contractual obligation through so-called standard contractual clauses of the EU Commission, the existence of certifications or binding internal data protection rules (Art. 44 to 49 GDPR, information page of the EU Commission).
Rights of data subjects
You have the right to request confirmation as to whether data concerning you is being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements.
In accordance with the legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
In accordance with the legal requirements, you have the right to request that data concerning you be deleted without undue delay or, alternatively, to request a restriction of the processing of the data in accordance with the legal requirements.
You have the right to request to receive the data concerning you that you have provided to us in accordance with the legal requirements and to request its transfer to other controllers.
You also have the right, in accordance with the legal requirements, to lodge a complaint with the competent supervisory authority.
Right of withdrawal
You have the right to withdraw consent given with effect for the future.
Right to object
You may object to the future processing of data concerning you at any time in accordance with the legal requirements. The objection may in particular be made against processing for the purposes of direct marketing.
Cookies and right to object to direct marketing
"Cookies" are small files that are stored on users' computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offering. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offering and closes their browser. Such a cookie can store, for example, the contents of a shopping basket in an online shop or a login status. Cookies that remain stored even after the browser is closed are referred to as "permanent" or "persistent". For example, the login status can be saved if users visit it after several days. Likewise, the interests of users can be stored in such a cookie, which are used for reach measurement or marketing purposes. "Third-party cookies" are cookies that are offered by providers other than the controller who operates the online offering (otherwise, if they are only its cookies, they are referred to as "first-party cookies").
We may use temporary and permanent cookies and explain this in our privacy policy.
If we ask users for their consent to the use of cookies (e.g. as part of a cookie consent), the legal basis for this processing is Art. 6(1)(a) GDPR. Otherwise, users' personal cookies are processed in accordance with the following explanations in this privacy policy on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offering within the meaning of Art. 6(1)(f) GDPR) or, if the use of cookies is necessary to provide our contract-related services, in accordance with Art. 6(1)(b) GDPR, or, if the use of cookies is necessary for the performance of a task carried out in the public interest or in the exercise of official authority, in accordance with Art. 6(1)(e) GDPR.
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in their browser's system settings. Stored cookies can be deleted in the browser's system settings. Excluding cookies may lead to functional restrictions of this online offering.
A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be prevented by deactivating them in the browser settings. Please note that in this case not all functions of this online offering may be available.
Deletion of data
The data processed by us will be deleted or restricted in its processing in accordance with the legal requirements. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and there are no statutory retention obligations preventing its deletion.
If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons.
Changes and updates to the privacy policy
We ask you to regularly inform yourself about the content of our privacy policy. We adapt the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.
Agency services
We process the data of our customers within the scope of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services and training services.
In doing so, we process inventory data (e.g. customer master data such as names or addresses), contact data (e.g. email, telephone numbers), content data (e.g. text entries, photographs, videos), contract data (e.g. subject matter of the contract, term), payment data (e.g. bank details, payment history), usage and metadata (e.g. in the context of evaluating and measuring the success of marketing measures). As a matter of principle, we do not process special categories of personal data unless they are part of a commissioned processing. The data subjects include our customers, prospective customers and their customers, users, website visitors or employees as well as third parties. The purpose of the processing is the provision of contractual services, billing and our customer service. The legal bases for the processing are Art. 6(1)(b) GDPR (contractual services) and Art. 6(1)(f) GDPR (analysis, statistics, optimisation, security measures). We process data that is required to establish and fulfil the contractual services and point out the necessity of providing it. Disclosure to external parties only takes place if it is necessary within the scope of an order. When processing the data provided to us within the scope of an order, we act in accordance with the instructions of the clients and the legal requirements for processing on behalf of a controller pursuant to Art. 28 GDPR and do not process the data for any purposes other than those specified in the order.
We delete the data after the expiry of statutory warranty and comparable obligations. The necessity of retaining the data is reviewed every three years; in the case of statutory archiving obligations, deletion takes place after their expiry (6 years pursuant to § 257(1) HGB, 10 years pursuant to § 147(1) AO). In the case of data disclosed to us by the client within the scope of an order, we delete the data in accordance with the specifications of the order, generally after the end of the order.
Contractual services
We process the data of our contractual partners and prospective customers as well as other clients, customers or contractual partners (uniformly referred to as "contractual partners") in accordance with Art. 6(1)(b) GDPR in order to provide them with our contractual or pre-contractual services. The data processed, the nature, scope, purpose and necessity of its processing are determined by the underlying contractual relationship.
The data processed includes the master data of our contractual partners (e.g. names and addresses), contact data (e.g. email addresses and telephone numbers) as well as contract data (e.g. services used, contract content, contractual communication, names of contact persons) and payment data (e.g. bank details, payment history).
As a matter of principle, we do not process special categories of personal data unless they are part of a commissioned or contractual processing.
We process data that is required to establish and fulfil the contractual services and point out the necessity of providing it, unless this is evident to the contractual partners. Disclosure to external persons or companies only takes place if it is necessary within the scope of a contract. When processing the data provided to us within the scope of an order, we act in accordance with the instructions of the clients and the legal requirements.
When using our online services, we may store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as the interests of users in protection against misuse and other unauthorised use. As a matter of principle, this data is not passed on to third parties unless it is necessary to pursue our claims pursuant to Art. 6(1)(f) GDPR or there is a legal obligation to do so pursuant to Art. 6(1)(c) GDPR.
The data is deleted when it is no longer required to fulfil contractual or statutory duties of care or to deal with any warranty and comparable obligations, whereby the necessity of retaining the data is reviewed every three years; otherwise, the statutory retention obligations apply.
Administration, financial accounting, office organisation, contact management
We process data in the context of administrative tasks and the organisation of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of providing our contractual services. The processing bases are Art. 6(1)(c) GDPR and Art. 6(1)(f) GDPR. Customers, prospective customers, business partners and website visitors are affected by the processing. The purpose of and our interest in the processing lies in administration, financial accounting, office organisation and data archiving, i.e. tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information provided for these processing activities.
In doing so, we disclose or transfer data to the tax authorities, consultants such as tax advisors or auditors as well as other fee offices and payment service providers.
Furthermore, based on our business interests, we store information on suppliers, event organisers and other business partners, e.g. for the purpose of later contact. As a matter of principle, we store this mostly company-related data permanently.
Microsoft cloud services
We use the cloud and cloud software services offered by Microsoft (so-called Software as a Service, e.g. Microsoft Office) for the following purposes: document storage and management, calendar management, sending emails, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing web pages, forms or other content and information, as well as chats and participation in audio and video conferences.
In doing so, users' personal data is processed insofar as it becomes part of the documents and content processed within the services described or is part of communication processes. This may include, for example, master data and contact data of users, data on transactions, contracts, other processes and their content. Microsoft also processes usage data and metadata, which Microsoft uses for security purposes and service optimisation.
When using publicly accessible documents, websites or other content, Microsoft may store cookies on users' computers for the purposes of web analysis or to remember users' settings.
We use Microsoft cloud services on the basis of our legitimate interests pursuant to Art. 6(1)(f) GDPR in efficient and secure administrative and collaboration processes. Furthermore, processing takes place on the basis of a data processing agreement with Microsoft.
Further information can be found in Microsoft's privacy statement (https://privacy.microsoft.com/en-gb/privacystatement) and the security information on Microsoft cloud services (https://www.microsoft.com/en-gb/trustcenter). You can object to the processing of your data in the Microsoft cloud vis-à-vis us in accordance with the legal requirements. Otherwise, the deletion of data within Microsoft's cloud services is determined by the other processing operations within the scope of which the data is processed (e.g. deletion of data no longer required for contractual purposes or storage of data required for tax purposes).
The Microsoft cloud services are offered by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399 USA. Insofar as data is processed in the USA, we refer to Microsoft's certification under the Privacy Shield (https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active).
Contacting us
When contacting us (e.g. via contact form, email, telephone or via social media), the user's details are processed to handle the contact request and its processing in accordance with Art. 6(1)(b) GDPR (in the context of contractual/pre-contractual relationships) and Art. 6(1)(f) GDPR (other enquiries). The users' details may be stored in a customer relationship management system ("CRM system") or comparable enquiry organisation.
We delete the enquiries if they are no longer required. We review the necessity every two years; statutory archiving obligations also apply.
Hosting and email sending
The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, email sending, security services and technical maintenance services, which we use for the purpose of operating this online offering.
In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, prospective customers and visitors to this online offering on the basis of our legitimate interests in the efficient and secure provision of this online offering pursuant to Art. 6(1)(f) GDPR in conjunction with Art. 28 GDPR (conclusion of a data processing agreement).
Collection of access data and log files
We, or our hosting provider, collect data on every access to the server on which this service is located (so-called server log files) on the basis of our legitimate interests within the meaning of Art. 6(1)(f) GDPR. The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.
For security reasons (e.g. to investigate misuse or fraud), log file information is stored for a maximum of 7 days and then deleted. Data whose further retention is required for evidential purposes is excluded from deletion until the respective incident has been finally clarified.
Google Analytics
We use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). Google uses cookies. The information generated by the cookie about the use of the online offering by users is generally transmitted to a Google server in the USA and stored there.
Google will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on the activities within this online offering and to provide us with further services associated with the use of this online offering and internet usage. Pseudonymous user profiles can be created from the processed data.
We only use Google Analytics with IP anonymisation activated. This means that the user's IP address is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user's browser is not merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online offering and from processing this data by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
If we ask users for their consent (e.g. as part of a cookie consent), the legal basis for this processing is Art. 6(1)(a) GDPR. Otherwise, users' personal data is processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offering within the meaning of Art. 6(1)(f) GDPR).
Insofar as data is processed in the USA, we would like to point out that Google is certified under the Privacy Shield agreement and thereby guarantees compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Further information on data use by Google, settings and objection options can be found in Google's privacy policy (https://policies.google.com/privacy) and in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
Users' personal data is deleted or anonymised after 14 months.
Consent management (cookie banner)
On your first visit, a banner asks for your consent to the use of Google Analytics. We store your choice in a technically necessary cookie ("asm_consent") for 12 months so that we do not have to ask you again every time you load a page. Google Analytics is only loaded after you have given your consent. You can change or withdraw your choice at any time via the "Cookie settings" link in the footer of the website. The legal basis is Art. 6(1)(c) GDPR in conjunction with Art. 7(1) GDPR and § 25(2) no. 2 TDDDG.
Contact form and security check
To protect against spam, our contact form uses its own security check (an image with characters) that is generated entirely on our server. A technically necessary session cookie is set for this purpose, which is deleted when the browser is closed. No data is transferred to third parties. The legal basis is our legitimate interest in preventing misuse pursuant to Art. 6(1)(f) GDPR.
Fonts
The fonts used on this website are hosted locally on our server. No connection to third-party servers (e.g. Google Fonts) is established.
Online presences in social media
We maintain online presences within social networks and platforms in order to communicate with customers, prospective customers and users active there and to inform them about our services.
We would like to point out that user data may be processed outside the European Union. This may result in risks for users because, for example, it could make it more difficult to enforce users' rights. With regard to US providers certified under the Privacy Shield, we would like to point out that they thereby undertake to comply with EU data protection standards.
Furthermore, users' data is generally processed for market research and advertising purposes. For example, user profiles can be created from usage behaviour and the resulting interests of users. The user profiles can in turn be used, for example, to place advertisements within and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are generally stored on users' computers in which the usage behaviour and interests of users are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (in particular if the users are members of the respective platforms and are logged in to them).
Users' personal data is processed on the basis of our legitimate interests in effectively informing and communicating with users pursuant to Art. 6(1)(f) GDPR. If users are asked by the respective platform providers for consent to the data processing described above, the legal basis for the processing is Art. 6(1)(a) and Art. 7 GDPR.
For a detailed description of the respective processing operations and the options to object (opt-out), please refer to the information provided by the providers linked below.
In the case of requests for information and the assertion of user rights, we would also like to point out that these can be asserted most effectively with the providers. Only the providers have access to users' data and can take appropriate measures and provide information directly. Should you nevertheless require assistance, you can contact us.
- Facebook, pages, groups (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) on the basis of an agreement on the joint processing of personal data – privacy policy: https://www.facebook.com/about/privacy/, specifically for pages: https://www.facebook.com/legal/terms/information_about_page_insights_data, opt-out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active.
- Google/YouTube (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) – privacy policy: https://policies.google.com/privacy, opt-out: https://adssettings.google.com/authenticated, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
- Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – privacy policy/opt-out: http://instagram.com/about/legal/privacy/.
- Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) – privacy policy: https://twitter.com/privacy, opt-out: https://twitter.com/personalization, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.
- Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA) – privacy policy/opt-out: https://about.pinterest.com/privacy-policy.
- LinkedIn (LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland) – privacy policy: https://www.linkedin.com/legal/privacy-policy, opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.
- Xing (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany) – privacy policy/opt-out: https://privacy.xing.com/en/privacy-policy.
- Wakelet (Wakelet Limited, 76 Quay Street, Manchester, M3 4PR, United Kingdom) – privacy policy/opt-out: https://wakelet.com/privacy.html.
- Soundcloud (SoundCloud Limited, Rheinsberger Str. 76/77, 10115 Berlin, Germany) – privacy policy/opt-out: https://soundcloud.com/pages/privacy.



