With the following privacy policy we would like to inform you which types of your personal data (hereinafter also abbreviated as “data”) we process for which purposes and in which scope. The privacy statement 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 services”).
The terms used are not gender-specific.
Last Update: 31. March 2021
Caroline Burkhart
AURA GmbH & Co. KG
Siebeinstrasse 3 (Zone 2)
76726 Germersheim, Germany
Authorised Representatives: Patric Burkhart (CEO)
E-mail address: info@auragmbh.com
Phone: +49(0)7274-7006-0
c.burkhart@auragmbh.com
The following table summarises the types of data processed, the purposes for which they are processed and the concerned data subjects.
In the following, you will find an overview of the legal basis of the GDPR on which we base the processing of personal data. Please note that in addition to the provisions of the GDPR, national data protection provisions of your or our country of residence or domicile may apply. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.
National data protection regulations in Germany: In addition to the data protection regulations of the General Data Protection Regulation, national regulations apply to data protection in Germany. This includes in particular the Law on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special provisions on the right to access, the right to erase, the right to object, the processing of special categories of personal data, processing for other purposes and transmission as well as automated individual decision-making, including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (§ 26 BDSG), in particular with regard to the establishment, execution or termination of employment relationships as well as the consent of employees. Furthermore, data protection laws of the individual federal states may apply.
We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.
The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as access to, input, transmission, securing and separation of the data. In addition, we have established procedures to ensure that data subjects’ rights are respected, that data is erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and service providers, in accordance with the principle of privacy by design and privacy by default.
SSL encryption (https): In order to protect your data transmitted via our online services in the best possible way, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.
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 his visit within an online service. The information stored can include, for example, the language settings on a website, the login status, a shopping basket or the location where a video was viewed. The term “cookies” also includes other technologies that fulfil the same functions as cookies (e.g. if user information is stored using pseudonymous online identifiers, also referred to as “user IDs”).
The following types and functions of cookies are distinguished:
Information on legal basis: The legal basis on which we process your personal data with the help of cookies depends on whether we ask you 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 will be processed on the basis of our legitimate interests (e.g. in a business operation of our online service and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.
Retention period: Unless we provide you with explicit information on the retention period of permanent cookies (e.g. within the scope of a so-called cookie opt-in), please assume that the retention period can be as long as two years.
General information on Withdrawal of consent and objection (Opt-Out): Respective of whether processing is based on consent or legal permission, you have the option at any time to object to the processing of your data using cookie technologies or to revoke consent (collectively referred to as “opt-out”). You can initially explain your objection using the settings of your browser, e.g. by deactivating the use of cookies (which may also restrict the functionality of our online services). An objection to the use of cookies for online marketing purposes can be raised for a large number of services, especially in the case of tracking, via the websites https://www.aboutads.info/choices/ and https://www.youronlinechoices.com. In addition, you can receive further information on objections in the context of the information on the used service providers and cookies.
Processing Cookie Data on the Basis of Consent: We use a cookie management solution in which users’ consent to the use of cookies, or the procedures and providers mentioned in the cookie management solution, can be obtained, managed and revoked by the users. The declaration of consent is stored so that it does not have to be retrieved again and the consent can be proven in accordance with the legal obligation. Storage can take place server-sided and/or in a cookie (so-called opt-out cookie or with the aid of comparable technologies) in order to be able to assign the consent to a user or and/or his/her device.Subject to individual details of the providers of cookie management services, the following information applies: The duration of the storage of the consent can be up to two years. In this case, a pseudonymous user identifier is formed and stored with the date/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 used end device.
In order to provide our online services securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers they manage) the online services 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 within the framework of the provision of the hosting services may include all information relating to the users of our online services that is collected in the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online services to browsers, and all entries made within our online services or from websites.
E-mail Sending and Hosting: The web hosting services we use also include sending, receiving and storing e-mails. For these purposes, the addresses of the recipients and senders, as well as other information relating to the sending of e-mails (e.g. the providers involved) and the contents of the respective e-mails are processed. The above data may also be processed for SPAM detection purposes. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted during transport, but not on the servers from which they are sent and received (unless a so-called end-to-end encryption method is used). We can therefore accept no responsibility for the transmission path of e-mails between the sender and reception on our server.
Collection of Access Data and Log Files: We, ourselves or our web hosting provider, collect data on the basis of each access to the server (so-called server log files). Server log files may include the address and name of the web pages and files accessed, the date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a general rule, IP addresses and the requesting provider.
The server log files can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the stability and optimal load balancing of the servers .
Services and service providers being used:
When contacting us (e.g. by contact form, e-mail, telephone or via social media), the data of the inquiring persons are processed insofar as this is necessary to answer the contact enquiries and any requested activities.
The response to contact enquiries within the framework of contractual or pre-contractual relationships is made in order to fulfil our contractual obligations or to respond to (pre)contractual enquiries and otherwise on the basis of the legitimate interests in responding to the enquiries.
Services and service providers being used:
We provide online chats and chatbot functions as a means of communication (together referred to as “Chat Services”). A chat is an online conversation that is conducted with a certain degree of immediacy. A chatbot is software that answers users’ questions or informs them about messages. If you use our chat functions, we may process your personal data.
If you use our Chat Services within an online platform, your identification number is also 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 these in accordance with legal requirements.
We would like to inform users that the respective platform provider can find out that and when users communicate with our Chat Services and can collect technical information about the user’s device used and, depending on the settings of their device, also location information (so-called metadata) for the purpose of optimising the respective services and for security purposes. Likewise, the metadata of communication via Chat Services (i.e., information about who has communicated with whom) could be used by the respective platform providers for marketing purposes or to display advertising tailored to users in accordance with their regulations, to which we refer for further information.
If users agree to activate information with regular messages to a chatbot, they have the possibility to unsubscribe from the information for the future at any time. The chatbot points out to users how and with which terms they can unsubscribe the messages. By unsubscribing from the chatbot messages, Users’ data is deleted from the directory of message recipients.
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 or to identify unanswered inquiries).
Information on Legal basis: We use the Chat Services on the basis of a consent if we first obtain the permission of the users to process their data by the Chat Services (this applies in cases where users are asked for consent, e.g. so that a chatbot regularly sends them messages). If we use Chat Services to answer user queries about our services or our company, this is done for contractual and pre-contractual communication. In addition, we use Chat Services based on our legitimate interests in optimizing the Chat Services, its operating efficiency and enhancing the positive user experience.
Withdrawal, objection and deletion: You can revoke a given consent at any time or contradict the processing of your data in the context of our hatbot use.
Services and service providers being used:
Web analysis is used to evaluate the visitor traffic on our website and may include the behaviour, interests or demographic information of users, such as age or gender, as pseudonymous values. With the help of web analysis we can e.g. recognize, at which time our online services or their functions or contents are most frequently used or requested for repeatedly, as well as which areas require optimization.
In addition to web analysis, we can also use test procedures, e.g. to test and optimize different versions of our online services or their components.
For these purposes, so-called user profiles can be created and stored in a file (so-called “cookie”) or similar procedures in which the relevant user information for the aforementioned analyses is stored. This information may include, for example, content viewed, web pages visited and elements and technical data used there, such as the browser used, computer system used and information on times of use. If users have consented to the collection of their location data, these may also be processed, depending on the provider.
The IP addresses of the users are also stored. However, we use any existing IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect the user. In general, within the framework of web analysis, A/B testing and optimisation, no user data (such as e-mail addresses or names) is stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.
Information on legal basis: If we ask the users for their consent to the use of third party providers, the legal basis of the processing is consent. Furthermore, the processing can be a component of our (pre)contractual services, provided that the use of the third party was agreed within this context. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient friendly services). In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Services and service providers being used:
We process personal data for the purposes of online marketing, which may include in particular the marketing of advertising space or the display 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 “cookie”) or similar procedure in which the relevant user information for the display of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, communication partners and technical information such as the browser used, computer system used and information on usage times. If users have consented to the collection of their sideline data, these can also be processed.
The IP addresses of the users are also stored. However, we use provided IP masking procedures (i.e. pseudonymisation by shortening the IP address) to ensure the protection of the user’s by using a pseudonym. In general, within the framework of the online marketing process, no clear user data (such as e-mail addresses or names) is secured, but pseudonyms. This means that we, as well as the providers of online marketing procedures, do not know the actual identity of the users, but only the information stored in their profiles.
The information in the profiles is usually stored in the cookies or similar memorizing procedures. These cookies can later, generally also on other websites that use the same online marketing technology, be read and analyzed for purposes of content display, as well as supplemented with other data and stored on the server of the online marketing technology provider.
Exceptionally, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing technology we use and the network links the profiles of the users in the aforementioned data. Please note that users may enter into additional agreements with the social network providers or other service providers, e.g. by consenting as part of a registration process.
As a matter of principle, we only gain access to summarised information about the performance of our advertisements. However, within the framework of so-called conversion measurement, we can check which of our online marketing processes have led to a so-called conversion, i.e. to the conclusion of a contract with us. The conversion measurement is used alone for the performance analysis of our marketing activities.
Unless otherwise stated, we kindly ask you to consider that cookies used will be stored for a period of two years.
Information on legal basis: If we ask users for their consent (e.g. in the context of a so-called “cookie banner consent”), the legal basis for processing data for online marketing purposes is this consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online services. In this context, we would also like to refer you to the information on the use of cookies in this privacy policy.
Facebook Pixel and Custom Audiences (Custom Audiences): With the help of the Facebook pixel (or equivalent functions, to transfer Event-Data or Contact Information via interfaces or other software in apps), Facebook is on the one hand able to determine the visitors of our online services as a target group for the presentation of ads (so-called “Facebook ads”). Accordingly, we use Facebook pixels to display Facebook ads placed by us only to Facebook users and within the services of partners cooperating with Facebook (so-called “audience network” https://www.facebook.com/audiencenetwork/ ) who have shown an interest in our online services or who have certain characteristics (e.g. interests in certain topics or products that are determined on the basis of the websites visited) that we transmit to Facebook (so-called “custom audiences”). With the help of Facebook pixels, we also want to ensure that our Facebook ads correspond to the potential interest of users and do not appear annoying. The Facebook pixel also enables us to track the effectiveness of Facebook ads for statistical and market research purposes by showing whether users were referred to our website after clicking on a Facebook ad (known as “conversion tracking”).
We are jointly responsible (so-called “joint-controllership”) with Facebook Ireland Ltd. for the collection or transmission (but not the further processing) of “event data” that Facebook collects or receives as part of a transmission for the following purposes using the Facebook pixel and comparable functions (e.g. APIs) that are implemented in our online services: a) displaying content advertising information that matches users’ presumed interests; b) delivering commercial and transactional messages (e.g. b) delivering commercial and transactional messages (e.g., addressing users via Facebook Messenger); c) improving ad delivery and personalizing features and content (e.g., improving recognition of which content or advertising information is believed to be of interest to users). We have entered into a special agreement with Facebook (“Controller Addendum”, https://www.facebook.com/legal/controller_addendum), which specifically addresses the security measures that Facebook must take (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to comply with the rights of data subjects (i.e., users can, for example, submit information access or deletion requests directly to Facebook). Note: If Facebook provides us with measurements, analyses and reports (which are aggregated, i.e. do not contain information on individual users and are anonymous to us), then this processing is not carried out within the scope of joint responsibility, but on the basis of a DPA (“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). The rights of users (in particular to access to information, erasure, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook.
Services and service providers being used:
We maintain online presences within social networks and process user data in this context 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 may entail risks for users, e.g. by making it more difficult to enforce users’ rights.
In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the associated interests of users. The user profiles can then be used, for example, to place advertisements within and outside the networks which are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer, in which the user’s usage behaviour and interests are stored. Furthermore, data can be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective networs or will become members later on).
For a detailed description of the respective processing operations and the opt-out options, please refer to the respective data protection declarations and information provided by the providers of the respective networks.
Also in the case of requests for information and the exercise of rights of data subjects, we point out that these can be most effectively pursued with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us.
Facebook: We are jointly responsible (so called “joint controller”) with Facebook Ireland Ltd. for the collection (but not the further processing) of data of visitors to our Facebook page. This data includes information about the types of content users view or interact with, or the actions they take (see “Things that you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/policy), and information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie information; see “Device Information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Data Policy under “How we use this information?” Facebook also collects and uses information to provide analytics services, known as “page insights,” to site operators to help them understand how people interact with their pages and with content associated with them. We have concluded a special agreement with Facebook (“Information about Page-Insights”, https://www.facebook.com/legal/terms/page_controller_addendum), which regulates in particular the security measures that Facebook must observe and in which Facebook has agreed to fulfill the rights of the persons concerned (i.e. users can send information access or deletion requests directly to Facebook). The rights of users (in particular to access to information, erasure, objection and complaint to the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the “Information about Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data).
Services and service providers being used:
Within our online services, we integrate functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may, for example, be graphics, videos or city maps (hereinafter uniformly referred to as “Content”).
The integration always presupposes that the third-party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We strive to use only those contents, whose respective offerers use the IP address only for the distribution of the contents. Third parties 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 include technical information about the browser and operating system, referring websites, visit times and other information about the use of our website, as well as may be linked to such information from other sources.
Information on legal basis: If we ask users for their consent (e.g. in the context of a so-called “cookie banner consent”), the legal basis for processing is this consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online services. We refer you to the note on the use of cookies in this privacy policy.
Services and service providers being used:
The data processed by us will be erased in accordance with the statutory provisions as soon as their processing is revoked or other permissions no longer apply (e.g. if the purpose of processing this data no longer applies or they are not required for the purpose).
If the data is not deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data will be restricted and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or for which storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.
In the context of our information on data processing, we may provide users with further information on the deletion and retention of data that is specific to the respective processing operation.
We kindly ask you to inform yourself regularly about the contents of our data protection declaration. We will adjust the privacy policy as changes in our data processing practices 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, we ask you to note that addresses may change over time and to verify the information before contacting us.
As data subject, you are entitled to various rights under the GDPR, which arise in particular from Articles 15 to 21 of the GDPR:
Supervisory authority competent for us:
Rheinland-Pfalz
Postanschrift
Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Rheinland-Pfalz
Postfach 30 40
55020 Mainz
Besucheradresse
Der Landesbeauftragte für den Datenschutz und die Informationsfreiheit Rheinland-Pfalz
Hintere Bleiche 34
55116 Mainz
Tel.: 061 31/208-24 49
Fax: 061 31/208-24 97
E-Mail: poststelle@datenschutz.rlp.de
Internet: www.datenschutz.rlp.de
This section provides an overview of the terms used in this privacy policy. Many of the terms are drawn from the law and defined mainly in Article 4 GDPR. The legal definitions are binding. The following explanations, on the other hand, are intended above all for the purpose of comprehension. The terms are sorted alphabetically.
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AURA GmbH & Co. KG
Siebeinstrasse 3 (Zone 2)
76726 Germersheim, Germany