Privacy Policy

Introduction

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

The terms used are not gender-specific.

As of: March 30, 2022

Table of Contents

Person responsible

Messina Olympic
Dörflistrasse 10b
8572 Berg TG

Authorized representatives : Messina Olimpio

Email address : info@beautywelove.ch

Phone : +41 78 310 04 24

Imprint : //beautywelove.ch/impressum/

Overview of processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

  • Inventory data (e.g. names, addresses).
  • Content data (e.g. text entries, photographs, videos).
  • Contact details (e.g. email, telephone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. websites visited, interest in content, access times).
  • Location data (data indicating the location of an end user’s device).
  • Contract data (e.g. subject matter of the contract, term, customer category).
  • Payment data (e.g. bank details, invoices, payment history).

Categories of data subjects

  • Business and contractual partners.
  • Interested parties.
  • Communication partner.
  • Customers.
  • Users (e.g. website visitors, users of online services).

Purposes of processing

  • Provision of our online offering and user-friendliness.
  • Visit action analysis.
  • Office and organizational procedures.
  • Direct marketing (e.g. by email or post).
  • Interest-based and behavioral marketing.
  • Contact requests and communication.
  • Conversion measurement (measuring the effectiveness of marketing measures).
  • Profiling (creation of user profiles).
  • Remarketing.
  • Reach measurement (e.g. access statistics, recognition of recurring visitors).
  • Security measures.
  • Tracking (e.g. interest/behavior-based profiling, use of cookies).
  • Contractual services and service.
  • Managing and responding to inquiries.

Relevant legal bases

Below, we provide the legal basis of the General Data Protection Regulation (GDPR) on which we process personal data. Please note that in addition to the provisions of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply. Should more specific legal bases apply in individual cases, we will inform you of these in the privacy policy.

  • Consent (Article 6 (1) (a) GDPR) – The data subject has given his or her consent to the processing of personal data concerning him or her for a specific purpose or several specific purposes.
  • Contractual performance and pre-contractual inquiries (Article 6 (1) (b) GDPR) – Processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Article 6 (1) (c) GDPR) – Processing is necessary to fulfill a legal obligation to which the controller is subject.
  • Legitimate interests (Article 6 (1) (f) GDPR) – Processing is necessary to protect the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject which require protection of personal data prevail.

National data protection regulations in Switzerland : In addition to the data protection regulations of the General Data Protection Regulation, national data protection regulations apply in Switzerland. These include, in particular, the Federal Data Protection Act (DSG). The DSG applies in particular when no EU/EEC citizens are affected and, for example, only data of Swiss citizens is processed.

Security measures

In accordance with the legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.

These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as the access, input, and transfer of data, ensuring its availability, and segregation. Furthermore, we have established procedures that ensure the exercise of data subjects' rights, the deletion of data, and responses to data threats. Furthermore, we consider the protection of personal data right from the development and selection of hardware, software, and processes in accordance with the principle of data protection, through technology design, and through data protection-friendly default settings.

Transfer and disclosure of personal data

As part of our processing of personal data, it may happen that the data is transmitted to or disclosed to other bodies, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, payment institutions within the context of payment transactions, service providers commissioned with IT tasks, or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.

Data processing in third countries

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

Subject to express consent or contractually or legally required transmission, we process or have the data processed only in third countries with a recognized level of data protection, which include the US processors certified under the “Privacy Shield”, or on the basis of special guarantees, such as contractual obligations through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: //ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

Use of cookies

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user's computer. A cookie is primarily used to store information about a user during or after their visit to an online service. The stored information may include, for example, the language settings on a website, the login status, a shopping cart, or the location at which a video was viewed. The term "cookies" also includes other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also known as "user IDs").

The following cookie types and functions are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their browser.
  • Persistent cookies: Persistent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, user interests, which are used for reach measurement or marketing purposes, can be stored in such a cookie.
  • First-party cookies: First-party cookies are set by us ourselves.
  • Third-party cookies : Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
  • Necessary (also: essential or absolutely necessary) cookies: Cookies can be absolutely necessary for the operation of a website (e.g. to save logins or other user inputs or for security reasons).
  • Statistics, marketing and personalization cookies : Cookies are also generally used to measure reach and when a user's interests or behavior (e.g. viewing certain content, using functions, etc.) on individual websites are saved in a user profile. Such profiles are used to show users content that corresponds to their potential interests, for example. This process is also referred to as "tracking," i.e., tracking the potential interests of users. If we use cookies or "tracking" technologies, we will inform you separately in our privacy policy or when obtaining your consent.

Notes on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask for your consent. If this applies and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g., in the commercial operation and improvement of our online offering) or if the use of cookies is necessary to fulfill our contractual obligations.

Storage period: Unless we provide you with explicit information about the storage period of permanent cookies (e.g. as part of a so-called cookie opt-in), please assume that the storage period can be up to two years.

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

Processing of cookie data based on consent : Before we process data through the use of cookies, or have data processed, we ask users for consent that can be revoked at any time. Until consent is given, only cookies necessary for the operation of our online offering will be used. Their use is based on our interest and the interest of the users in the expected functionality of our online offering.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a GDPR), Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).

Commercial and business services

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

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

We will inform our contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.

We delete data after the expiration of statutory warranty and similar obligations, i.e., generally after four years, unless the data is stored in a customer account, e.g., for as long as it must be retained for legal archiving reasons (e.g., for tax purposes, usually for ten years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the terms of the order, generally after the end of the order.

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

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

The analyses are carried out for the purposes of business evaluations, marketing, and market research (e.g., to identify customer groups with different characteristics). In doing so, we may, where available, consider the profiles of registered users, including their information, e.g., regarding services used. The analyses serve our sole purpose and are not disclosed externally, unless they are anonymous analyses with aggregated, i.e., anonymized values. Furthermore, we respect the privacy of users and process the data for analysis purposes pseudonymously wherever possible and, where feasible, anonymously (e.g., as aggregated data).

Shop and e-commerce : We process our customers’ data to enable them to select, purchase or order the selected products, goods and related services, as well as to pay for them and to deliver or execute them.

The required information is marked as such in the ordering or similar purchasing process and includes the information required for delivery, provision and billing, as well as contact information for any possible follow-up.

  • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject of the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: interested parties, business and contractual partners, customers.
  • Purposes of processing: Contractual services and service, contact requests and communication, office and organizational procedures, administration and response to inquiries, visitor action evaluation, interest-based and behavioral marketing, profiling (creation of user profiles), security measures.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legal obligation (Art. 6 (1) (c) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

Privacy Policy for CusRev

Our website includes features from the Cusrev service. These features are provided by CUSTOMER REVIEWS LTD (Registered in England & Wales), 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ. This service allows us to collect feedback on products. Further information can be found in Cusrev's privacy policy : https://www.cusrev.com/privacy-policy

Payment service providers

Within the framework of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer the data subjects efficient and secure payment options and, in addition to banks and credit institutions, we use other payment service providers (collectively “payment service providers”).

The data processed by the payment service providers includes inventory data such as name and address, bank details such as account numbers or credit card numbers, passwords, TANs and checksums as well as contract, amount and recipient-related information. This information is required to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account- or credit card-related information, but only information confirming or rejecting the payment. Under certain circumstances, the payment service providers will transmit the data to credit agencies. This transmission is for the purpose of identity and credit checks. For more information, please refer to the terms and conditions and the privacy policy of the payment service providers.

Payment transactions are subject to the terms and conditions and privacy policy of the respective payment service providers, which are available on the respective websites or transaction applications. We also refer to these for further information and to assert your rights of withdrawal, information, and other data subjects.

  • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject of the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: customers, interested parties.

Provision of the online offer and web hosting

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

The data processed in the context of providing the hosting service may include all information concerning the users of our online offering that arises during use and communication. This usually includes the IP address, which is necessary to deliver the content of online offerings to browsers, and all entries made within our online offering or on websites.

Collection of access data and log files : We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). Server log files may include the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, the referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider.

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

  • Types of data processed: 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).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

Contact us

When you contact us (e.g. via contact form, email, telephone or social media), the information provided by the person making the inquiry will be processed to the extent necessary to answer the contact inquiries and any requested measures.

Contact requests within the framework of contractual or pre-contractual relationships are answered to fulfill our contractual obligations or to answer (pre-)contractual requests and, moreover, on the basis of our legitimate interests in answering the requests.

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos).
  • Data subjects: communication partners.
  • Purposes of processing: contact requests and communication.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).

Newsletter and broad communication

We send newsletters, emails, and other electronic notifications (hereinafter "newsletters") only with the recipient's consent or legal permission. If the newsletter content is specifically described when registering for the newsletter, this information is decisive for the user's consent. Otherwise, our newsletters contain information about our services and us.

To subscribe to our newsletter, it is generally sufficient to provide your email address. However, we may ask you to provide a name for the purpose of addressing you personally in the newsletter, or other information if this is necessary for the purposes of the newsletter.

Double opt-in process: Registration for our newsletter is generally carried out using a so-called double opt-in process. This means that after registration, you will receive an email asking you to confirm your registration. This confirmation is necessary to ensure that no one can register using someone else's email address. Newsletter registrations are logged to provide evidence of the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation, as well as the IP address. Changes to your data stored by the shipping service provider are also logged.

Deletion and restriction of processing: We may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them in order to be able to prove previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous consent is confirmed at the same time. In the case of obligations to permanently observe objections, we reserve the right to store the email address on a blocking list (so-called "blacklist") for this purpose alone.

The registration process is logged based on our legitimate interests for the purpose of demonstrating its proper execution. If we commission a service provider to send emails, this is done based on our legitimate interests in an efficient and secure delivery system.

Notes on legal bases: The newsletter is sent based on the recipient's consent or, if consent is not required, on our legitimate interest in direct marketing, if and to the extent that this is permitted by law, e.g., in the case of advertising to existing customers. If we commission a service provider to send emails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to demonstrate that it was carried out in accordance with the law.

Content : Information about us, our services, promotions and offers.

  • Types of data processed: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: communication partners.
  • Purposes of processing: direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a GDPR), Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
  • Opt-out: You can unsubscribe from our newsletter at any time, i.e., revoke your consent or object to further receipt. You will find a link to unsubscribe from the newsletter either at the end of each newsletter or by using one of the contact options listed above, preferably email.

Newsletter

If you would like to receive the newsletter offered on the website, we require an email address from you as well as information that allows us to verify that you are the owner of the specified email address and that you agree to receive the newsletter. No further data will be collected. We use this data exclusively to send the requested information and do not share it with third parties.
After you have given your consent to the storage of your data, your email address and their use for sending the newsletter, you can revoke this consent at any time, for example via the "unsubscribe link" in the newsletter.

Send newsletter - Mailchimp

The newsletter is sent via the shipping service provider 'MailChimp', a newsletter distribution platform of the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view the shipping service provider's privacy policy here. Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield Agreement and thus guarantees compliance with the European data protection level (PrivacyShield). The use of the shipping service provider is based on our legitimate interests pursuant to Art. 6 (1) (f) GDPR and a data processing agreement pursuant to Art. 28 (3) (1) GDPR.

The shipping service provider may use the recipients' data in pseudonymous form, i.e., without assignment to a specific user, to optimize or improve its own services, e.g., for the technical optimization of the delivery and presentation of the newsletter or for statistical purposes. However, the shipping service provider does not use the data of our newsletter recipients to contact them directly or to pass it on to third parties.

Online marketing

We process personal data for the purposes of online marketing, which may include, in particular, the marketing of advertising space or the presentation of advertising and other content (collectively referred to as “content”) based on the potential interests of users and the measurement of their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called "cookies"), or similar processes are used to store user information relevant to the presentation of the aforementioned content. This information may include, for example, content viewed, websites visited, online networks used, as well as communication partners and technical information such as the browser used, the computer system used, and information on usage times. If users have consented to the collection of their location data, this may also be processed.

Users' IP addresses are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no real user data (such as email addresses or names) is stored as part of the online marketing process; instead, pseudonyms are used. This means that neither we nor the providers of the online marketing process know the actual identity of the users, only the information stored in their profiles.

The information in profiles is usually stored in cookies or similar processes. These cookies can generally also be read later on other websites that use the same online marketing process, analyzed for the purpose of displaying content, and supplemented with additional data and stored on the server of the online marketing process provider.

In exceptional cases, clear data may be assigned to profiles. This is the case, for example, if users are members of a social network whose online marketing processes we use, and the network links the users' profiles with the aforementioned information. Please note that users may enter into additional agreements with the providers, e.g., by providing consent during registration.

We generally only receive access to aggregated information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes led to a so-called conversion, i.e., to the conclusion of a contract with us. Conversion measurements are used solely to analyze the success of our marketing measures.

Unless otherwise stated, we ask you to assume that cookies used will be stored for a period of two years.

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

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: users (e.g. website visitors, users of online services), interested parties.
  • Purposes of processing: Tracking (e.g. interest/behavior-related profiling, use of cookies), remarketing, visitor action analysis, interest-based and behavior-related marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of recurring visitors).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 Para. 1 S. 1 lit. a GDPR), Legitimate Interests (Art. 6 Para. 1 S. 1 lit. f. GDPR).
  • Opt-out option: We refer to the data protection information of the respective providers and the opt-out options specified for the providers (so-called “opt-out”). If no explicit opt-out option has been provided, you have the option of deactivating cookies in your browser settings. However, this may restrict the functions of our online offering. We therefore recommend the following additional opt-out options, which are offered in summary for the respective regions: a) Europe: //www.youronlinechoices.eu . b) Canada: //www.youradchoices.ca/choices . c) USA: //www.aboutads.info/choices . d) Cross-regional: //optout.aboutads.info .

Services and service providers used:

Presences in social networks (social media)

We maintain online presences within social networks and, in this context, process user data in order to communicate with the users active there or to offer information about us.

We would like to point out that user data may be processed outside the European Union. This could pose risks for users, for example, because it could make it more difficult to enforce their rights. With regard to US providers certified under the Privacy Shield or offering comparable guarantees of a secure level of data protection, we would like to point out that they are thereby committed to complying with EU data protection standards.

Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on user behavior and the resulting interests of the users. These user profiles can then be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are generally stored on users' computers in which the user behavior and interests are saved. Furthermore, user profiles can also store data independent of the devices used by the users (particularly if the users are members of the respective platforms and are logged in to them).

For a detailed description of the respective processing methods and the options for opting out, please refer to the privacy policies and information provided by the operators of the respective networks.

In the case of requests for information and the assertion of data subject rights, we would like to point out that these can be most effectively asserted with the providers. Only the providers have access to the user data and can directly take appropriate measures and provide information. If you still need assistance, please contact us.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, 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).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: contact requests and communication, tracking (e.g. interest/behavior-related profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of recurring visitors).
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

Services and service providers used:

TikTok Advertising

We use TikTok Pixel on our website, a conversion tracking tool for advertisers. The service provider is the Chinese company TikTok. For the European region, the company is TikTok Technology Limited (10 Earlsfort Terrace,
Dublin, D02 T380, Ireland).
TikTok processes your data, among other places, in the USA. We would like to point out that, according to the European Court of Justice, there is currently no adequate level of protection for data transfers to the USA. This may entail various risks to the legality and security of data processing.
TikTok uses so-called standard contractual clauses (= Art. 46, Paragraphs 2 and 3 GDPR) as the basis for data processing with recipients located in third countries (outside the European Union, Iceland, Liechtenstein, Norway, and in particular the USA) or for data transfers there. Standard contractual clauses (SCCs) are templates provided by the EU Commission and are intended to ensure that your data complies with European data protection standards even if it is transferred to and stored in third countries (such as the National Security Agency).
Through these clauses, TikTok undertakes to comply with European data protection standards when processing your relevant data, even if the data is stored, processed, and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses here: https://eur-
lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de
You can find out more about the standard contractual clauses and the data processed through the use of TikTok Pixel in the Privacy Policy at https://www.tiktok.com/legal/page/eea/privacy-policy/de-DE or at
https://ads.tiktok.com/i18n/official/policy/controller-to-controller.

Plugins and embedded functions and content

We integrate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may include, for example, graphics, videos, social media buttons, and posts (hereinafter collectively referred to as "content").

Integration always requires that the third-party providers of this content process the user's IP address, as without the IP address they would not be able to send the content to their browser. The IP address is therefore required to display this content or functions. We endeavor to only use content whose respective providers only use the IP address to deliver the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, the time of visit and other information about the use of our online offering, as well as be linked to such information from other sources.

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

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (data that indicates the location of an end user's device), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online services and user-friendliness, contractual services and support, security measures, administration and response to inquiries.
  • Legal bases: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. GDPR), consent (Art. 6 Para. 1 S. 1 lit. a GDPR), contract fulfillment and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. b. GDPR).

Services and service providers used:

Deletion of data

The data we process will be deleted in accordance with legal requirements as soon as the consent to processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or it is no longer required for the purpose).

Unless the data is deleted because it is required for other legally permissible purposes, its processing will be limited to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons, or whose storage is necessary to assert, exercise, or defend legal claims or to protect the rights of another natural or legal person.

Further information on the deletion of personal data can also be found in the individual data protection notices of this data protection declaration.

Changes and updates to the privacy policy

We ask you to inform yourself regularly about the content of our privacy policy. We will adapt the privacy policy as soon as changes to the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g., consent) or other individual notification.

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

Rights of data subjects

As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 18 and 21 GDPR:

  • Right of objection: You have the right to object at any time to the processing of personal data concerning you based on Art. 6 (1) (e) or (f) GDPR, for reasons related to your particular situation; this also applies to profiling based on these provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for the purposes of such advertising; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw consent at any time.
  • Right to information: You have the right to request confirmation as to whether data in question is being processed and to information about this data as well as further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: You have the right, in accordance with the statutory provisions, to request that the data concerning you be completed or that inaccurate data concerning you be corrected.
  • Right to erasure and restriction of processing: You have the right, in accordance with the statutory provisions, to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.
  • Right to data portability: You have the right to receive the data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transmitted to another controller.
  • Complaint to a supervisory authority: You also have the right, in accordance with the statutory provisions, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you believe that the processing of personal data concerning you violates the GDPR.

Definitions of terms

This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined primarily in Art. 4 GDPR. The legal definitions are binding. The following explanations, however, are primarily intended to facilitate understanding. The terms are sorted alphabetically.

  • Conversion tracking: "Conversion tracking" is a process used to determine the effectiveness of marketing measures. This typically involves storing a cookie on the user's device within the websites where the marketing measures are carried out and then retrieving it on the target website. For example, this allows us to track whether the ads we place on other websites were successful.
  • IP masking: "IP masking" is a method in which the last octet, i.e., the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing procedures, particularly in online marketing.
  • Interest-based and behavioral marketing: Interest-based and/or behavioral marketing refers to the process of predicting users' potential interests in advertisements and other content as precisely as possible. This is done based on information about their previous behavior (e.g., visiting and staying on certain websites, purchasing behavior, or interactions with other users), which is stored in a so-called profile. Cookies are typically used for these purposes.
  • Conversion measurement: Conversion measurement is a method used to determine the effectiveness of marketing measures. This typically involves storing a cookie on users' devices within the websites where the marketing measures are carried out and then retrieving it on the target website. For example, this allows us to understand whether the ads we place on other websites were successful.
  • Personal data: “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. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiling: "Profiling" refers to any form of automated processing of personal data consisting of the use of personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information concerning age, gender, location and movement data, interaction with websites and their content, purchasing behavior, and social interactions with other people) (e.g., interests in certain content or products, click behavior on a website, or location). Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate visitor traffic to an online offering and can include visitor behavior or interests in specific information, such as website content. With the help of reach analysis, website owners can, for example, identify when visitors visit their website and what content they are interested in. This allows them to, for example, better tailor website content to the needs of their visitors. For reach analysis purposes, pseudonymous cookies and web beacons are often used to identify returning visitors and thus obtain more precise analyses of the use of an online offering.
  • Remarketing: “Remarketing” or “retargeting” is the term used when, for example, for advertising purposes, it is noted which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Tracking: "Tracking" refers to the tracking of user behavior across multiple online offerings. Typically, behavioral and interest information related to the online offerings used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to correspond to their interests.
  • Controller: The “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of the processing of personal data.
  • Processing: "Processing" is any operation or set of operations performed on personal data, whether or not by automated means. The term is broad and encompasses virtually every type of data handling, including collection, analysis, storage, transmission, or deletion.