Data protection



and



imprint

imprint



Information according to § 5 TMG


Hermsdorf Volunteer Fire Department
At the fire station, 1
39326 Hermsdorf


Postal address


Matthias Schwertner
Am Rodelberg, 2
39326 Hermsdorf


contact


Phone: 01721706176
Email: Contact@Feuerwehr-Hermsdorf.Help


Editorially responsible


Matthias Schwertner

Am Rodelberg,2
39343 Ackendorf / Hohe Börde


Source:eRecht24

Data protection


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 in the context of providing our application.

The terms used are not gender-specific.

As of: February 15, 2023


Table of Contents

Person responsible


Hermsdorf Fire Department

At the Fire Station 1
39326 Hermsdorf / Hohe Börde


Postal address

M. Schwertner
Am Rodelberg 2
39343 Ackendorf / Hohe Börde

Authorized representatives:

Matthias Schwertner


E-mail address:

datenschutz@feuerwehr-hermsdorf.help


Imprint:

https://www.feuerwehr-hermsdorf.help/DatenschutzundImpressum


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.
  • Payment details.
  • Location data.
  • Contact details.
  • Content data.
  • Contract data.
  • Usage data.
  • Meta, communication and procedural data.
  • Event data (Facebook).


Categories of data subjects


  • Customers.
  • Interested parties.
  • Communication partner.
  • Users.
  • Sweepstakes and competition participants.
  • members.
  • Business and contractual partners.
  • Participant.


Purposes of processing


  • Provision of contractual services and customer service.
  • Contact requests and communication.
  • Security measures.
  • Direct marketing.
  • Reach measurement.
  • Tracking.
  • Managing and responding to inquiries.
  • Conducting prize draws and competitions.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.


Relevant legal bases


Below you will find an overview of the GDPR legal bases on which we process personal data. Please note that in addition to the GDPR regulations, national data protection regulations may apply in your or our country of residence or domicile. 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 party or for the implementation of pre-contractual measures taken at the request of the data 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.

In addition to the data protection provisions of the GDPR, national data protection regulations apply in Germany. This includes, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). BDSG In particular, it contains special provisions on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and transmission and automated decision-making in individual cases, including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (Section 26 of the Federal Data Protection Act), particularly with regard to the establishment, implementation, or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.


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.

IP address abbreviation: If IP addresses are processed by us or by the service providers and technologies we use, and the processing of a full IP address is not required, the IP address will be abbreviated (also known as "IP masking"). The last two digits, or the last part of the IP address after a period, are removed or replaced with placeholders. The abbreviation of the IP address is intended to prevent or significantly complicate the identification of a person based on their IP address.

TLS encryption (https): To protect the data you transmit via our online service, we use TLS encryption. You can recognize such encrypted connections by the prefix https:// in your browser's address bar.


Transmission of personal data

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, 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 transfer within the organization: We may transfer personal data to other departments within our organization or grant them access to this data. If this transfer is for administrative purposes, the transfer of data is based on our legitimate business and operational interests, if it is necessary to fulfill our contractual obligations, or if the data subject has given their consent or is permitted by law.


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, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).

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 that purpose). If the data is not 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.

Our privacy policy may also contain further information on the storage and deletion of data, which applies primarily to the respective processing operations.


Use of cookies


Cookies are small text files or other storage devices that store information on end devices and read information from end devices. For example, they can store the login status in a user account, the contents of a shopping cart in an e-shop, the content accessed, or the functions used in an online offering. Cookies can also be used for various purposes, such as improving the functionality, security, and convenience of online offerings, as well as creating analyses of visitor flows.

Notes on consent: We use cookies in accordance with legal regulations. Therefore, we obtain prior consent from users, unless this is not required by law. Consent is particularly unnecessary if the storage and retrieval of information, including cookies, is absolutely necessary to provide users with a telemedia service they have expressly requested (i.e., our online offering). The revocable consent will be clearly communicated to users and will contain information about the respective cookie usage.

Notes on data protection legal bases: The data protection legal basis on which we process users' personal data with the help of cookies depends on whether we ask users for consent. If users consent, the legal basis for processing their data is their 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 of our online offering and improving its usability) or, if this occurs as part of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We clarify the purposes for which we process cookies in the course of this data protection declaration or as part of our consent and processing processes.

Storage period: With regard to the storage period, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed his or her device (e.g. browser or mobile application).
  • Persistent cookies: Persistent cookies remain stored even after the device 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, the user data collected through cookies can be used to measure reach. Unless we provide users with explicit information about the type and storage period of cookies (e.g., when obtaining consent), users should assume that cookies are permanent and can be stored for up to two years.

General information on revocation and objection (opt-out): Users can revoke their consent at any time and also object to processing in accordance with the legal requirements of Art. 21 GDPR. Users can also declare their objection via their browser settings, e.g., by deactivating the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be made via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ be explained.

Further information on processing procedures, methods and services:

  • Processing of cookie data based on consent: We use a cookie consent management procedure within the framework of which the user’s consent to the use of cookies or the processing operations and providers named in the cookie consent management procedure can be obtained and managed and revoked by the users. The declaration of consent is saved so that it does not have to be requested again and so that consent can be proven in accordance with legal obligations. The data can be stored on the server and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information about the providers of cookie management services, the following information applies: The consent can be stored for up to two years. A pseudonymous user identifier is created and stored along with the time of consent, information on the scope of the consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and device used.
  • BorlabsCookie: Cookie consent management; Service provider: Hosted locally on our server, no data transfer to third parties; Website: https://de.borlabs.io/borlabs-cookie/; Further information: An individual user ID, language, types of consent and the time of their submission are stored on the server and in the cookie on the user's device.
  • Compliance: Cookie consent management; Service provider: Hosted locally on our server, no data transfer to third parties; Website: https://complianz.io/; Privacy Policy: https://complianz.io/legal/; Further information: An individual user ID, language, types of consent and the time of their submission are stored on the server and in the cookie on the user's device

.

Perception of

Tasks according to

Statutes

or rules of procedure


We process the data of our members, supporters, interested parties, business partners, or other persons (collectively, "data subjects") if we have a membership or other business relationship with them and if they perform our duties and are recipients of services and donations. Otherwise, we process the data of data subjects based on our legitimate interests, e.g., if it concerns administrative tasks or public relations.

The data processed here, the type, scope and purpose and the necessity of their processing are determined by the underlying membership or contractual relationship, from which the necessity of any data disclosure arises (otherwise we refer to required data).

We delete data that is no longer required to fulfill our statutory and business purposes. This is determined according to the respective tasks and contractual relationships. We retain the data for as long as it may be relevant for business transactions, as well as with regard to any warranty or liability obligations based on our legitimate interest in their management. The necessity of retaining the data is regularly reviewed; otherwise, the statutory retention periods apply.

  • Types of data processed: Inventory data (e.g. names, addresses); payment data (e.g. bank details, invoices, payment history); contact data (e.g. email, telephone numbers); contract data (e.g. subject of contract, term, customer category).
  • Data subjects: users (e.g. website visitors, users of online services); members; business and contractual partners.
  • Purposes of processing: provision of contractual services and customer service; contact requests and communication; administration and response to inquiries.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); legitimate interests (Art. 6 (1) (f) GDPR).


Payment methods


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 service providers for this purpose (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 matter of the contract, term, customer category); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status); contact data (e.g. email, telephone numbers).
  • Data subjects: customers; interested parties.
  • Purposes of processing: provision of contractual services and customer service.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR).

Further information on processing procedures, methods and services:

  • Giropay: Payment services (technical connection of online payment methods); Service provider: giropay GmbH, An der Welle 4, 60322 Frankfurt, Germany; Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://www.giropay.de; Privacy Policy: https://www.giropay.de/rechtliches/datenschutzerklaerung/.
  • Google Pay: Payment services (technical connection of online payment methods); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://pay.google.com/intl/de_de/about/; Privacy Policy: https://policies.google.com/privacy.
  • Klarna / Sofortüberweisung: Payment services (technical connection of online payment methods); Service provider: Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden; Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://www.klarna.com/de; Privacy Policy: https://www.klarna.com/de/datenschutz.
  • PayPal: Payment services (technical connection of online payment methods) (e.g. PayPal, PayPal Plus, Braintree); Service provider: PayPal (Europe) S.à rl et Cie, SCA, 22-24 Boulevard Royal, L-2449 Luxembourg; Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Website: https://www.paypal.com/de; Privacy Policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

Provision of the

Online offer

and

Web hosting


We process user data to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or device.

  • Types of data processed: Usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status); content data (e.g., entries in online forms).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online services and user-friendliness; information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)); security measures; provision of contractual services and customer service.
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing procedures, methods and services:

  • Provision of online services on rented storage space: To provide our online services, we use storage space, computing capacity, and software that we rent from a corresponding server provider (also called a "web host") or obtain from other sources; legal basis: legitimate interests (Art. 6 (1) (f) GDPR).
  • Collection of access data and log files: Access to our online offering is logged in the form of 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, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. Server log files may be used for security purposes, e.g., to prevent server overload (particularly in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure server utilization and stability. Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Deletion of data: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data that needs to be retained for evidentiary purposes will not be deleted until the incident in question has been finally resolved.
  • E-mail sending and hosting: The web hosting services we use also include the sending, receiving, and storing of e-mails. For these purposes, the addresses of the recipients and senders, as well as other information relating to the e-mail sending (e.g. the providers involved), and the content of the respective e-mails are processed. The aforementioned data may also be processed for the purposes of detecting SPAM. Please note that e-mails are generally not sent encrypted over the Internet. As a rule, e-mails are encrypted during transport, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We cannot therefore accept any responsibility for the transmission path of the e-mails between the sender and the recipient on our server; legal basis: legitimate interests (Art. 6 (1) (f) GDPR).
  • 1&1 IONOS: Services in the field of providing information technology infrastructure and related services (e.g. storage space and/or computing capacity); Service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.ionos.de; Privacy Policy: https://www.ionos.de/terms-gtc/terms-privacy; Data processing agreement: https://www.ionos.de/hilfe/datenschutz/allgemeine-informationen-zur-datenschutz-grundverordnung-dsgvo/auftragsverarbeitung/.


Blogs and publication media


We use blogs or similar means of online communication and publication (hereinafter "publication medium"). Readers' data is processed for the purposes of the publication medium only to the extent necessary for its presentation and communication between authors and readers, or for security reasons. Furthermore, we refer to the information on the processing of visitors to our publication medium within the framework of this privacy policy.

  • Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers); content data (e.g. entries in online forms); usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, consent status).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of contractual services and customer service; feedback (e.g. collecting feedback via online form); provision of our online offering and user-friendliness; security measures; administration and response to inquiries.
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing procedures, methods and services:

  • Comments and contributions: When users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests. This is done for our security in case someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc.). In this case, we ourselves can be held liable for the comment or contribution and are therefore interested in the identity of the author. Furthermore, we reserve the right to process user information for the purpose of spam detection based on our legitimate interests. On the same legal basis, we reserve the right to store users' IP addresses for the duration of surveys and to use cookies to prevent multiple voting. The personal information provided in the comments and contributions, any contact and website information as well as the content information will be stored by us permanently until the user objects; legal basis: legitimate interests (Art. 6 (1) (f) GDPR).
  • Access to WordPress emojis and smileys: Access to WordPress emojis and smileys - Within our WordPress blog, graphic emojis (or smileys), i.e., small graphic files that express emotions, are used for the purpose of efficiently integrating content elements. These files are obtained from external servers. The server providers collect the users' IP addresses. This is necessary so that the emoji files can be transmitted to the users' browsers. Service provider: Aut O'Mattic A8C Ireland Ltd., Grand Canal Dock, 25 Herbert Pl, Dublin, D02 AY86, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://automattic.com; Privacy Policy: https://automattic.com/privacy.


Contact and inquiry management


When you contact us (e.g. by post, contact form, email, telephone or via social media) as well as within the framework of existing user and business relationships, 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.

  • Types of data processed: Contact data (e.g., email, telephone numbers); content data (e.g., entries in online forms); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
  • Data subjects: communication partners.
  • Purposes of processing: Contact requests and communication; administration and response to requests; feedback (e.g. collecting feedback via online form); provision of our online services and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR).

Further information on processing procedures, methods and services:

  • Contact form: If users contact us via our contact form, email, or other communication channels, we process the data communicated to us in this context to process the communicated request; legal basis: contract fulfillment and pre-contractual inquiries (Art. 6 (1) (b) GDPR), legitimate interests (Art. 6 (1) (f) GDPR).


.

Communication via Messenger


We use messengers for communication purposes and therefore ask you to note the following information on the functionality of the messengers, encryption, the use of communication metadata and your options for objection.

You can also contact us via alternative means, such as telephone or email. Please use the contact options provided to you or the contact options provided within our online offering.

In the case of end-to-end encryption of content (i.e., the content of your message and attachments), please note that the communication content (i.e., the content of the message and attached images) is encrypted end-to-end. This means that the content of the messages cannot be viewed, not even by the messenger providers themselves. You should always use a current version of the messenger with encryption enabled to ensure the encryption of the message content.

However, we would also like to point out to our communication partners that although the providers of the messengers cannot see the content, they can find out that and when communication partners communicate with us, as well as technical information about the device used by the communication partners and, depending on the settings of their device, location information (so-called metadata) is processed.

Notes on legal bases: If we ask communication partners for permission before communicating with them via messenger, the legal basis for our processing of their data is their consent. Otherwise, if we do not ask for consent and they contact us on their own initiative, for example, we use messenger in our relationship with our contractual partners and in the context of contract initiation as a contractual measure and, in the case of other interested parties and communication partners, on the basis of our legitimate interests in fast and efficient communication and fulfilling the needs of our communication partners in communicating via messenger. We would also like to point out that we will not transmit the contact details provided to us to the messenger for the first time without your consent.

Revocation, objection and deletion: You can revoke your consent at any time and - This text area must be activated with a Premium License. -

  • Types of data processed: Contact data (e.g. email, telephone numbers); Usage data (e.g. websites visited, interest in content, - This text area must be activated with a premium license. - premiumtext premiumtext premiumtext ); Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers, - This text area must be activated with a premium license. - premiumtext premiumtext premiumtext ).
  • Data subjects: communication partners.
  • Purposes of processing: contact requests and communication; direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6 (1) (a) GDPR); Legitimate interests (Art. 6 (1) (f) GDPR).


Chatbots and chat functions


We offer online chats and chatbot features (collectively referred to as "Chat Services") as a means of communication. A chat is an online conversation conducted with a certain degree of real-time proximity. A chatbot is software that answers users' questions or informs them about messages. If you use our chat features, we may process your personal data.

If you use our chat services within an online platform, your identification number will also be stored within the respective platform. We may also collect information about which users interact with our chat services and when. Furthermore, we store the content of your conversations via the chat services and log registration and consent processes in order to be able to prove them in accordance with legal requirements.

We would like to point out to users that the respective platform provider may learn that and when users communicate with our chat services, as well as collect technical information about the device used by the user and, depending on their device settings, location information (so-called metadata) for the purposes of optimizing the respective services and for security purposes. Likewise, the metadata of communication via chat services (e.g., information about who communicated with whom) may be used by the respective platform provider for marketing purposes or to display user-tailored advertising in accordance with their terms and conditions, to which we refer for further information.

If users agree to receive regular messages from a chatbot, they have the option to unsubscribe from these messages at any time. The chatbot will inform users how and with which terms they can unsubscribe from the messages. Unsubscribing from chatbot messages will delete user data from the message recipient list.

We use the aforementioned information to operate our chat services, e.g., to address users personally, to answer their inquiries, to transmit any requested content and also to improve our chat services (e.g., to "teach" chatbots answers to frequently asked questions).


  • Types of data processed: Contact data (e.g. email, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, - This text area must be activated with a premium license. - premiumtext premiumtext premiumtext ); Meta, communication and procedural data (e.g. IP addresses, time information, identification numbers.
  • Data subjects: communication partners.
  • Purposes of processing: contact requests and communication; direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6 (1) (a) GDPR); Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR); Legitimate interests (Art. 6 (1) (f) GDPR).


Newsletter and electronic

Notifications


We send newsletters, emails, and other electronic notifications (hereinafter "newsletters") only with the recipient's consent or legal permission. If the newsletter's content is specifically described when registering for the newsletter, it is decisive for the user's consent. Furthermore, 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 deletion request 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 block list (so-called "blocklist") 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.

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

  • Types of data processed: Inventory data (e.g., names, addresses); contact data (e.g., email, telephone numbers); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status); usage data (e.g., websites visited, interest in content, access times).
  • Data subjects: communication partners; users (e.g. website visitors, users of online services).
  • Purposes of processing: direct marketing (e.g. by email or post); provision of contractual services and customer service.
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
  • Opt-out: You can cancel your subscription to 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.

Further information on processing procedures, methods and services:

  • Measuring opening and click rates: The newsletters contain a so-called "web beacon", i.e., a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a shipping service provider, from their server. During this retrieval, technical information such as information about the browser and your system, as well as your IP address and the time of retrieval, is initially collected. This information is used to technically improve our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. This information is assigned to the individual newsletter recipients and stored in their profiles until they are deleted. The evaluations help us to recognize the reading habits of our users and adapt our content to them or to send different content according to the interests of our users. Measuring open rates and click rates, as well as saving the measurement results in user profiles. This text area must be activated with a premium license. - premiumtext; Legal basis: Consent (Art. 6 (1) (a) GDPR).
  • Prerequisite for using free services: Consent to receive mailings may be made a condition for using free services (e.g., access to certain content or participation in certain promotions). If users would like to use the free service without subscribing to the newsletter, please contact us.
  • Sending via SMS: The electronic notifications can also be sent as SMS text messages (or will be sent exclusively via SMS if the authorization to send them, e.g., consent, only covers sending via SMS); legal basis: consent (Art. 6 (1) (a) GDPR).


Advertising communication via email, post,
Fax or telephone


We process personal data for the purposes of advertising communication, which can be carried out via various channels, such as e-mail, telephone, post or fax, in accordance with legal requirements.

Recipients have the right to revoke consent given at any time or to object to advertising communication at any time.

After revocation or objection, we will store the data required to prove previous authorization for contacting or sending for up to three years after the end of the year of revocation or objection based on our legitimate interests. The processing of this data is limited to the purpose of a possible defense against claims. Based on our legitimate interest in permanently respecting the user's revocation or objection, we also store the data required to avoid further contact (e.g., depending on the communication channel, the email address, telephone number, name).

  • Types of data processed: Inventory data (e.g. names, addresses); contact data (e.g. email, telephone numbers).
  • Data subjects: communication partners.
  • Purposes of processing: direct marketing (e.g. by email or post).
  • Legal basis: Consent (Art. 6 (1) (a) GDPR); Legitimate interests (Art. 6 (1) (f) GDPR).


Sweepstakes and competitions


We process personal data of participants in prize draws and competitions only in compliance with the relevant data protection regulations, insofar as the processing is contractually necessary for the provision, implementation and processing of the prize draw, the participants have consented to the processing or the processing serves our legitimate interests (e.g. in the security of the prize draw or the protection of our interests against misuse through possible collection of IP addresses when submitting prize draw entries).

If entries from participants are published as part of the competition (e.g., as part of a vote or presentation of the competition entries or winners, or in the reporting on the competition), we would like to point out that the names of the participants may also be published in this context. Participants can object to this at any time.

If the competition takes place within an online platform or social network (e.g., Facebook or Instagram, hereinafter referred to as the "online platform"), the terms of use and data protection provisions of the respective platforms also apply. In these cases, we point out that we are responsible for the information provided by participants within the framework of the competition and that inquiries regarding the competition should be directed to us.

Participants' data will be deleted as soon as the prize draw or competition has ended and the data is no longer required to inform the winners or because queries about the prize draw are expected. Participants' data will generally be deleted no later than six months after the end of the prize draw. Winners' data may be retained for longer, for example to answer queries about the prizes or to fulfill the prize draw services; in this case, the retention period depends on the type of prize and is up to three years for items or services, for example to process warranty claims. Participants' data may also be stored for longer, for example in the form of reports on the prize draw in online and offline media.

If data was collected for other purposes as part of the competition, its processing and retention period are governed by the data protection information for this use (e.g. in the case of registration for the newsletter as part of a competition).

  • Types of data processed: Inventory data (e.g., names, addresses); content data (e.g., entries in online forms); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
  • Data subjects: Participants in prize draws and competitions.
  • Purposes of processing: Conducting prize draws and competitions.
  • Legal basis: Contractual performance and pre-contractual inquiries (Art. 6 (1) (b) GDPR).


Surveys and polls


We conduct surveys and questionnaires to collect information for the respective communicated survey or questionnaire purpose. The surveys and questionnaires we conduct (hereinafter "surveys") are evaluated anonymously. Personal data is processed only to the extent necessary for the provision and technical implementation of the surveys (e.g., processing the IP address to display the survey in the user's browser or to enable resumption of the survey using a cookie).

  • Types of data processed: Contact data (e.g., email, telephone numbers); content data (e.g., entries in online forms); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
  • Data subjects: communication partners; participants.
  • Purposes of processing: Feedback (e.g. collecting feedback via online form).
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).


Web analysis, monitoring and optimization


Web analytics (also known as "reach measurement") is used to evaluate visitor traffic to our online offering and may include behavior, interests, or demographic information about visitors, such as age or gender, as pseudonymous values. Reach analysis allows us to determine, for example, when our online offering or its functions or content are most frequently used or encourage reuse. Likewise, we can understand which areas require optimization.

In addition to web analysis, we can also use testing procedures to, for example, test and optimize different versions of our online offering or its components.

Unless otherwise stated below, profiles, i.e., data summarized for a usage process, may be created for these purposes, and information may be stored in a browser or on a device and read from it. The information collected includes, in particular, websites visited and elements used there, as well as 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 by us or by the providers of the services we use, location data may also be processed.

Users' IP addresses are also stored. However, we use an IP masking process (i.e., pseudonymization by shortening the IP address) to protect users. Generally, no real user data (such as email addresses or names) is stored for web analysis, A/B testing, and optimization; instead, pseudonyms are used. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.

  • Types of data processed: Usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: reach measurement (e.g. access statistics, recognition of recurring visitors); profiles with user-related information (creation of user profiles); tracking (e.g. interest/behavior-related profiling, use of cookies); provision of our online offering and user-friendliness.
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).

Further information on processing procedures, methods and services:

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.

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: Contact data (e.g., email, telephone numbers); content data (e.g., entries in online forms); usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form); marketing.
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR).

Further information on processing procedures, methods and services:

  • Instagram: Social network; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.instagram.com; Privacy Policy: https://instagram.com/about/legal/privacy.
  • Facebook Pages: Profiles within the social network Facebook - We, together with Meta Platforms Ireland Limited, are responsible for collecting (but not further processing) data from visitors to our Facebook page (so-called "fan page"). This data includes information about the types of content users view or interact with, or the actions they take (see "Things you and others do and provide" in the Facebook Data Policy). https://www.facebook.com/policy), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see "Device Information" in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services, called "Page Insights," to Page operators so that they can gain insights into how people interact with their Pages and the content associated with them. We have entered into a specific agreement with Facebook ("Page Insights Information," https://www.facebook.com/legal/terms/page_controller_addendum), which specifically regulates the security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of those affected (i.e., users can, for example, submit information or deletion requests directly to Facebook). Users' rights (in particular, the right to information, deletion, objection, and complaint to the responsible supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information on Page Insights" (https://www.facebook.com/legal/terms/information_about_page_insights_data); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Standard contractual clauses (guaranteeing data protection levels when processing in third countries): https://www.facebook.com/legal/EU_data_transfer_addendum; Further information: Joint Responsibility Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_dataJoint controllership is limited to the collection and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. Further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, in particular the transmission of data to its parent company, Meta Platforms, Inc., in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
  • Twitter: Social network; Service provider: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, Parent company: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Privacy policy: https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
  • YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Privacy policy: https://policies.google.com/privacy; Possibility of objection (opt-out): https://adssettings.google.com/authenticated.


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, or city maps (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. These "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.

  • Types of data processed: Usage data (e.g., websites visited, interest in content, access times); meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status); inventory data (e.g., names, addresses); contact data (e.g., email, telephone numbers); content data (e.g., entries in online forms); location data (information on the geographical position of a device or person); Event data (Facebook) ("Event data" is data that can be transmitted by us to Facebook, e.g., via Facebook pixel (via apps or other means) and relates to individuals or their actions. This data includes, for example, information about visits to websites, interactions with content, functions, app installations, product purchases, etc.; the event data is processed for the purpose of creating target groups for content and advertising information (custom audiences); event data does not contain the actual content (such as comments written), login information, or contact information (i.e., no names, email addresses, or phone numbers). Event data is deleted by Facebook after a maximum of two years; the target groups created from it are deleted when our Facebook account is deleted.
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online services and user-friendliness.
  • Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Consent (Art. 6 (1) (a) GDPR).

Further information on processing procedures, methods and services:

  • Facebook Plugins and Content: Facebook Social Plugins and Content - This may include content such as images, videos, or text, and buttons that allow users to share content from this website within Facebook. The list and appearance of Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/ - We are jointly responsible with Meta Platforms Ireland Limited for the collection or receipt during transmission (but not the further processing) of "Event Data" that Facebook collects or receives during transmission using the Facebook social plugins (and content embedding functions) running on our online offering for the following purposes: a) Displaying content and advertising information that corresponds to the presumed interests of users; b) Delivering commercial and transaction-related messages (e.g., addressing users via Facebook Messenger); c) Improving ad delivery and personalizing features and content (e.g., improving the recognition of which content or advertising information presumably corresponds to users' interests). We have concluded a special agreement with Facebook ("Additional Data Controller"). https://www.facebook.com/legal/controller_addendum), which specifically regulates which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to fulfill the data subject's rights (i.e., users can, for example, submit information or deletion requests directly to Facebook). Note: If Facebook provides us with metrics, analyses, and reports (which are aggregated, i.e., do not contain any information about individual users and are anonymous to us), then this processing does not take place within the framework of joint controllership, but on the basis of a data processing agreement ("Data Processing Terms"). https://www.facebook.com/legal/terms/dataprocessing), the "Data Security Conditions" (https://www.facebook.com/legal/terms/data_security_terms) and with regard to processing in the USA on the basis of standard contractual clauses ("Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). Users' rights (in particular the right to information, deletion, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook; Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Legal basis: Consent (Art. 6 (1) (a) GDPR); Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy.
  • Google Fonts (obtained from Google servers): Obtaining fonts (and symbols) for the purpose of technically secure, maintenance-free, and efficient use of fonts and symbols with regard to timeliness and loading times, their consistent presentation, and consideration of possible licensing restrictions. The font provider is informed of the user's IP address so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) is transmitted that is necessary for providing the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA. When visiting our online offering, users' browsers send their browser HTTP requests to the Google Fonts Web API (i.e., a software interface for retrieving fonts). The Google Fonts Web API provides users with Google Fonts' Cascading Style Sheets (CSS) and subsequently the fonts specified in the CCS. These HTTP requests include (1) the IP address used by the respective user to access the Internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of website visitors, as well as the referring URL (i.e., the web page where the Google font should be displayed). IP addresses are neither logged nor stored on Google servers, and they are not analyzed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent, and referring URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must adapt the font generated for the respective browser type. The user agent is logged primarily for debugging purposes and used to generate aggregated usage statistics that measure the popularity of font families. These aggregated usage statistics are published on the Google Fonts Analytics page. Finally, the referring URL is logged so that the data can be used for production maintenance and to generate an aggregated report on top integrations based on the number of font requests. According to Google, no information collected by Google Fonts is used to create profiles of end users or to serve targeted ads. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Further information: https://developers.google.com/fonts/faq/privacy?hl=de.
  • Google Maps: We integrate maps from the "Google Maps" service provided by Google. The data processed may include, in particular, users' IP addresses and location data. Service provider: Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland. Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR). Website: https://mapsplatform.google.com/; Privacy Policy: https://policies.google.com/privacy.
  • YouTube videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal basis: Legitimate interests (Art. 6 (1) (f) GDPR); Website: https://www.youtube.com; Privacy Policy: https://policies.google.com/privacy; Opt-out option: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for displaying advertisements: https://adssettings.google.com/authenticated.

Change and update of the

Data protectionDeclaration of intent


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 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 the data in question 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.
  • 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: Without prejudice to any other administrative or judicial remedy, you have the right 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 consider that the processing of personal data concerning you violates the provisions of 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.

  • 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.
  • Profiles with user-related information: The processing of "profiles with user-related information," or "profiles" for short, includes any type of automated processing of personal data consisting of the use of this personal data to analyze, evaluate, or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include different information relating to demographics, behavior, and interests, such as interaction with websites and their content, etc.). 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.
  • Location data: Location data is generated when a mobile device (or other device with the technical capabilities for location determination) connects to a cell tower, a Wi-Fi network, or similar technical intermediaries and location determination functions. Location data is used to indicate the geographically identifiable position of the respective device on Earth. Location data can be used, for example, to display map functions or other location-dependent information.
  • 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 any handling of data, whether it involves collecting, analyzing, storing, transmitting, or deleting.

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