Privacy policy

Introduction

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, mobile, as well as within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer").

The terms used are not gender specific.

Status: 01 October 2022 

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Table of contents

Responsible

E-mail address: hello @followerninja.com

Contact data protection officer

Processing overview

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

Types of data processed

  • Inventory data (e.g., names, addresses).
  • Content data (e.g. entries in online forms).
  • Contact information (e.g., email, phone numbers).
  • Meta/communication data (e.g. device information, IP addresses).
  • Usage data (e.g. web pages visited, interest in content, access times).
  • Location data (information about the geographical position of a device or person).
  • Contract data (e.g. subject matter of the contract, term, customer category).
  • Payment data (e.g. bank details, invoices, payment history).

Categories of persons concerned

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

Processing purposes

  • Assessment of creditworthiness and credit standing.
  • Provision of our online offer and user-friendliness.
  • Visit Action Evaluation.
  • Office and organizational procedures.
  • Cross-device tracking (processing of user data across devices for marketing purposes).
  • Direct marketing (e.g. by e-mail or postal mail).
  • Interest-based and behavioral marketing.
  • Contact requests and communication.
  • Conversion measurement (measurement of the effectiveness of marketing measures).
  • Profiling (creation of user profiles).
  • Remarketing.
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Safety measures.
  • Tracking (e.g., interest/behavioral profiling, use of cookies).
  • Provision of contractual services and customer service.
  • Managing and responding to inquiries.
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content).

Automated decisions in individual cases

  • Credit report (decision based on a credit check).

Relevant legal bases

In the following, we share the legal basis of the General Data Protection Regulation (GDPR) on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, the national data protection provisions in your or our country of residence and domicile may apply. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO) - The data subject has given his/her consent to the processing of personal data concerning him/her for a specific purpose or purposes.
  • Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO) - The 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.
  • Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO) - The processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO) - The processing is necessary for the purposes of the legitimate interests of the controller or of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

Security measures

We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk 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.

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 the access, input, transfer, safeguarding of availability and its separation. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data, and responses to data compromise. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

SSL encryption (https)To protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

 

Transfer and disclosure of personal data

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

Data processing in third countries

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

Subject to express consent or contractually or legally required transfer, we only process or have data processed 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 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

Cookies use

Cookies are small text files or other memory tags that store information on end devices and read information from the end devices. For example, to store the login status in a user account, a shopping cart content in an e-shop, the content accessed or functions used of an online offer. Cookies can also be used for various purposes, e.g. for purposes of functionality, security and convenience of online offers as well as the creation of analyses of visitor flows.

Consent Notes: We use cookies in accordance with the law. Therefore, we obtain prior consent from users, except when it is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary to provide the user with a telemedia service (i.e., our online offering) expressly requested by the user. The revocable consent is clearly communicated to the users and contains the information about the respective cookie use.

Notes on the legal basis for data protection: The legal basis under data protection law on which we process users' personal data using 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 a business operation of our online offer and improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We explain the purposes for which we process the cookies in the course of this privacy policy or as part of our consent and processing procedures.

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 offer and closed his end device (e.g. browser or mobile application).
  • Permanent cookies: Permanent cookies remain stored even after the terminal 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, user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.

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

Processing of cookie data on the basis of consent: We use a cookie consent management procedure in which the consent of users to the use of cookies, or the processing and providers named in the cookie consent management procedure, can be obtained and managed and revoked by users. Here, the declaration of consent is stored in order not to have to repeat its query and to be able to prove the consent in accordance with the legal obligation. The storage can take place on the server side 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 on the providers of cookie management services, the following information applies: The duration of the storage of consent can be up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g., which categories of cookies and/or service providers), as well as the browser, system and end device used.

Cookie settings/opposition:

Commercial and business services

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

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

We inform the contractual partners which data are required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.

We delete the data after the expiry of legal warranty and comparable obligations, i.e., in principle after 4 years, unless the data is stored in a customer account, e.g., as long as it must be kept for legal archiving reasons (e.g., for tax purposes usually 10 years). We delete data disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally after the end of the order.

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.

Customer accountContractual partners can create an account within our online offer (e.g. customer or user account, in short "customer account"). If the registration of a customer account is required, contractual partners will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. Within the scope of registration and subsequent logins and uses of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove the registration and prevent any misuse of the customer account.

If customers have terminated their customer account, the data relating to the customer account will be deleted, unless their retention is required for legal reasons. It is the responsibility of customers to back up their data when the customer account is terminated.

Economic analysis and market researchFor business reasons and in order to be able to identify market trends, wishes of contractual partners and users, we analyze the data we have on business transactions, contracts, inquiries, etc., whereby the group of data subjects may include contractual partners, interested parties, customers, visitors and users of our online offering.

The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). In doing so, we may, if available, take into account the profiles of registered users together with their details, e.g. on services used. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized, i.e. anonymized values. Furthermore, we take into account the privacy of the users and process the data for the analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarized data).

Store and e-commerceWe process the data of our customers to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery or execution. If necessary for the execution of an order, we use service providers, in particular postal, forwarding and shipping companies, to carry out the delivery, or execution to our customers. For the processing of payment transactions, we use the services of banks and payment service providers. The required information is identified as such in the context of the order or comparable purchase process and includes the information needed for delivery, or provision and billing, as well as contact information, so that any consultation can be held.

  • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Interested parties, business and contractual partners, customers.
  • Purposes of processing: Provision of contractual services and customer service, contact requests and communication, office and organizational procedures, management and response to requests, security measures, visit action evaluation, interest-based and behavioral marketing, profiling (creation of user profiles).
  • Legal basis: Contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legal obligation (Art. 6 para. 1 p. 1 lit. c. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Payment service provider

In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other payment service providers in addition to banks and credit institutions for this purpose (collectively, "payment service providers").

The data processed by the payment service providers includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required in order to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e., we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the payment service providers transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the terms and conditions and the data protection notices of the payment service providers.

The terms and conditions and the data protection notices of the respective payment service providers apply to the payment transactions, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of revocation, information and other data subject rights.

  • 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 contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Customers, prospects.
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

 

Credit check

If we make advance payments or enter into comparable economic risks (e.g. when ordering on account), we reserve the right to obtain identity and creditworthiness information for the purpose of assessing the credit risk on the basis of mathematical-statistical procedures from service companies specializing in this area (credit agencies) in order to protect our legitimate interests.

We process the information received from the credit agencies on the statistical probability of a payment default within the framework of an appropriate discretionary decision on the establishment, implementation and termination of the contractual relationship. We reserve the right to refuse payment on account or any other advance payment in the event of a negative result of the credit check.

In accordance with Art. 22 DSGVO, the decision as to whether we provide advance services is made solely on the basis of an automated decision in the individual case, which is made by our software on the basis of the information provided by the credit agency.

If we obtain express consent from contractual partners, the legal basis for the credit report and the transmission of the customer's data to the credit agencies is the consent. If no consent is obtained, the credit information is provided on the basis of our legitimate interests in the default security of our payment claims.

  • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of contract, term, customer category).
  • Affected persons: Customers, prospects.
  • Purposes of processing: Assessment of creditworthiness and credit standing.
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
  • Automated decisions in individual cases: Credit report (decision based on a credit check).

Services used and service providers:

Provision of the online offer and web hosting

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

The data processed within the scope of the provision of the hosting offer may include all information concerning the users of our online offer, which accrues within the scope of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

Email sending and hostingThe 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 further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.

Collection of access data and log filesWe ourselves (or our web hosting provider) collect data on each access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, 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 rule, IP addresses and the requesting provider.

The server log files may be used, on the one hand, for security purposes, e.g., to prevent server overload (especially in the case of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability.

  • Types of data processed: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Contact

When contacting us (e.g. by contact form, e-mail, telephone or via social media), the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

The response to contact requests in the context of contractual or pre-contractual relationships is made in order to fulfill our contractual obligations or to respond to (pre)contractual inquiries and otherwise on the basis of legitimate interests in responding to the inquiries.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Communication partners, interested parties.
  • Purposes of processing: Contact requests and communication, managing and responding to requests.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

  • Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context to process the communicated request. For this purpose, we process personal data in the context of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfillment, and otherwise on the basis of our legitimate interests as well as the interests of the communication partners in responding to the concerns and our statutory retention obligations.
  • Help Scout: Contact request and communication management; Service provider: Help Scout Inc, 131 Tremont St, Boston, MA 02111-1338, USA; website: https://www.helpscout.net; Privacy Policy: https://www.helpscout.net/company/legal/privacy/Standard contractual clauses (guaranteeing the level of data protection in the case of processing in third countries): https://www.helpscout.com/company/legal/dpa/; Order processing contract: https://www.helpscout.com/company/legal/dpa/.

Newsletter and electronic notifications

We send newsletters, e-mails and other electronic notifications (hereinafter "newsletter") only with the consent of the recipients or a legal permission. Insofar as the contents of the newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. Otherwise, our newsletters contain information about our services and us.

To subscribe to our newsletters, it is generally sufficient to provide your e-mail address. However, we may ask you to provide a name, for the purpose of personal address in the newsletter, or further information, if this is necessary for the purposes of the newsletter.

Double opt-in procedure: The registration for our newsletter is always done in a so-called double opt-in process. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Likewise, the changes to your data stored with the shipping service provider are 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 consent formerly given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. In the event of obligations to permanently observe objections, we reserve the right to store the e-mail address in a blacklist for this purpose alone.

The logging of the registration process takes place on the basis of our legitimate interests for the purpose of proving its proper course. If we commission a service provider to send e-mails, this is done on the basis of our legitimate interests in an efficient and secure sending system.

Notes on legal bases: The newsletter is sent on the basis of the recipients' consent or, if consent is not required, on the basis of our legitimate interests in direct marketing, if and to the extent that this is permitted by law, e.g. in the case of existing customer advertising. Insofar as we commission a service provider to send e-mails, this is done on the basis of our legitimate interests. The registration process is recorded on the basis of our legitimate interests to prove that it was carried out in accordance with the law.

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

Analysis and performance measurementThe 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. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval, are 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 access times. This analysis also includes determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can indeed be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the dispatch service provider to observe individual users. Rather, we use the analyses to identify the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

The evaluation of the newsletter and the measurement of its success are carried out, subject to the express consent of the users, on the basis of our legitimate interests for the purpose of using a user-friendly and secure newsletter system that serves our business interests and meets the expectations of the users.

A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled, or it must be contradicted.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), meta/communication data (e.g. device information, IP addresses), usage data (e.g. websites visited, interest in content, access times).
  • Affected persons: Communication partner.
  • Purposes of processing: Direct marketing (e.g. by e-mail or postal mail).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
  • Possibility of objection (opt-out): You can cancel the receipt of our newsletter at any time, i.e. revoke your consent or object to further receipt. You will find a link to cancel the newsletter either at the end of each newsletter or you can otherwise use one of the above contact options, preferably e-mail, for this purpose.

Services used and service providers:

Web analysis, monitoring and optimization

Web analytics (also referred to as "reach measurement") is used to evaluate the flow of visitors to our online offering and may include behavior, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can recognize, for example, at what time our online offer or its functions or content are most frequently used or invite re-use. Likewise, we can understand which areas require optimization.

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

For these purposes, so-called user profiles may be created and stored in a file (so-called "cookie") or similar procedures may be used with the same purpose. This information may include, for example, content viewed, websites visited and elements used there, and technical information such as the browser used, the computer system used, and information on usage times. If users have consented to the collection of their location data, this may also be processed, depending on the provider.

The IP addresses of the users are also collected. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. In general, we do not store any clear user data (such as e-mail addresses or names) for the purposes of web analysis, A/B testing and optimization, but rather 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 procedures.

Notes on legal bases: If we ask users for their consent to use the third-party providers, the legal basis for processing data is consent. Otherwise, the users' data is 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.

  • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest/behavior-related profiling, use of cookies), visit action evaluation, profiling (creation of user profiles).
  • Safety measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

Online marketing

We process personal data for online marketing purposes, which may include, in particular, marketing advertising space or displaying promotional and other content (collectively, "Content") based on users' potential interests and measuring its effectiveness.

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

The IP addresses of the users are also collected. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that we, as well as the providers of the 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 by means of similar procedures. These cookies can later generally also be read on other websites that use the same online marketing procedure and analyzed for the purpose of displaying content as well as supplemented with further data and stored on the server of the online marketing procedure provider.

Exceptionally, clear data may be associated with the profiles. This is the case if, for example, the users are members of a social network whose online marketing procedures we use and the network links the users' profiles with the aforementioned data. We ask that you note that users can make additional agreements with the providers, e.g., by giving their consent as part of the registration process.

In principle, we only receive access to summarized information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing methods have led to a so-called conversion, i.e., for example, to a contract being concluded with us. The conversion measurement is used solely to analyze the success of our marketing measures.

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

Notes on legal bases: If we ask users for their consent to use the third-party providers, the legal basis for processing data is consent. Otherwise, the users' data is 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.

  • Types of data processed: Usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information about the geographical position of a device or person).
  • Affected persons: Users (e.g., website visitors, users of online services), prospects.
  • Purposes of processing: Tracking (e.g. interest/behavior-based profiling, use of cookies), remarketing, visit action evaluation, interest-based and behavior-based marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors), targeting (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes).
  • Safety measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).
  • Possibility of objection (opt-out): We refer to the data protection notices of the respective providers and the objection options (so-called "opt-out") given for the providers. If no explicit opt-out option has been specified, it is possible to disable cookies in the settings of your browser. However, this may restrict functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary for the respective areas:a) Europe: https://www.youronlinechoices.eu.
    b) Canada: https://www.youradchoices.ca/choices.
    c) USA: https://www.aboutads.info/choices.
    d) Cross-territory: https://optout.aboutads.info.

Services used and service providers:

  • Facebook pixel and targeting (Custom Audiences): With the help of the Facebook pixel (or comparable functions, for the transmission of event data or contact information by means of interfaces in apps), it is possible for Facebook, on the one hand, to determine the visitors to our online offer as a target group for the display of advertisements (so-called "Facebook ads"). Accordingly, we use the Facebook pixel in order to display the Facebook ads placed by us only to such users on Facebook and within the services of the partners cooperating with Facebook (so-called "Audience Network". https://www.facebook.com/audiencenetwork/ ) who have also shown an interest in our online offer or who have certain characteristics (e.g. interest in certain topics or products that are evident from the web pages visited) that we transmit to Facebook (so-called "Custom Audiences"). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of users and do not have a harassing effect. With the help of the Facebook pixel, we can further track the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a Facebook ad (so-called "conversion measurement"); service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy; Standard contractual clauses (guaranteeing the level of data protection in the case of processing in third countries): The "Facebook EU Data Transfer Supplement" applies (https://www.facebook.com/legal/EU_data_transfer_addendum) in the case of commissioned processing by Facebook as the basis for the processing of event data of EU citizens in the USA and the inclusion in the "Platform Terms of Use of Facebook" (https://developers.facebook.com/terms) with regard to the autonomous processing of event data from Facebook in the context of ad placement; Further information: The "Data Processing Conditions" (https://www.facebook.com/legal/terms/dataprocessing/update) with respect to Event Data that Facebook processes on behalf to provide reporting and analytics to companies; Furthermore, the "Controller Addendum" is deemed to be a joint responsibility agreement (Article 26 (1) sentence 3 of the GDPR), which is relevant in the case of Facebook's own processing of Event Data for purposes of targeting and improving and securing Facebook's products.
  • Google Ad Manager: We use the "Google Marketing Platform" (and services such as "Google Ad Manager") to place ads in the Google advertising network (e.g., in search results, in videos, on web pages, etc.). The Google Marketing Platform is characterized by the fact that ads are displayed in real time based on presumed user interests. This allows us to display ads for and within our online offering in a more targeted manner in order to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products in which he or she was interested on other online offers, this is referred to as "remarketing"; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Further information: Types of processing as well as the data processed: https://privacy.google.com/businesses/adsservices; Data processing conditions for Google advertising products: Information on services Data processing conditions between data controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms; where Google acts as processor, data processing terms and conditions for Google advertising products and standard contractual clauses for third country transfers of data: https://business.safety.google/adsprocessorterms.
  • Google Ads and conversion measurement: We use the online marketing method "Google Ads" to place ads in the Google advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads (so-called "conversion"). Furthermore, we measure the conversion of the ads. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page marked with a so-called "conversion tracking tag". However, we ourselves do not receive any information with which users can be identified; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Further information: Types of processing as well as the data processed: https://privacy.google.com/businesses/adsservices; Data processing conditions for Google advertising products: Information on services Data processing conditions between data controllers and standard contractual clauses for third country transfers of data: https://business.safety.google/adscontrollerterms.

Presence in social networks (social media)

We maintain online presences within social networks and process user data in this context in order to communicate with 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 result in risks for the users because, for example, the enforcement of the rights of the users could be made more difficult.

Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created based on the usage behavior and resulting interests of the users. The usage profiles can in turn 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 usually stored on the users' computers, in which the usage behavior and interests of the users are stored. Furthermore, data independent of the devices used by the users may also be stored in the usage profiles (especially if the users are members of the respective platforms and are logged in to them).

For a detailed presentation of the respective forms of processing and the options to object (opt-out), we refer to the privacy statements 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 also like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Users (e.g., website visitors, users of online services).
  • Purposes of processing: Contact requests and communication, tracking (e.g. interest/behavioral profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Services used and service providers:

Plugins and embedded functions and content

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

The integration always requires that the third-party providers of this content process the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content or function. We strive to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to analyze 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 offer as well as be combined with such information from other sources.

Notes on legal bases: If we ask users for their consent to use the third-party providers, the legal basis for processing data is consent. Otherwise, the users' data is 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.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (information on the geographical position of a device or a person), content data (e.g. entries in online forms), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers).
  • Affected persons: Users (e.g., website visitors, users of online services), communication partners.
  • Purposes of processing: Provision of our online offer and user experience, provision of contractual services and customer service, contact requests and communication, tracking (e.g. interest/behavioral profiling, use of cookies), interest-based and behavioral marketing, profiling (creation of user profiles), security measures, administration and response to requests.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO), consent (Art. 6 para. 1 p. 1 lit. a. DSGVO), contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO).

Services used and service providers:

  • Facebook plugins and content: Facebook Social Plugins and Content - This may include, for example, content such as images, videos or text and buttons that allow users to share content from this online offering 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 in connection with a transmission (but not the further processing) of "Event Data" that Facebook collects or receives in connection with a transmission through the Facebook social plugins (and content embedding features) that run on our Online Service for the purposes of: a) displaying content and advertising information that is relevant to users' perceived interests; b) delivering commercial and transactional messages (e.g., targeting users via Facebook Messenger); c) improving ad delivery and personalizing features and content (e.g., improving the identification of which content or advertising information is relevant to users' perceived interests). e.g., targeting users via Facebook Messenger); c) improving ad delivery and personalization of features and content (e.g., improving the detection of which content or advertising information presumably matches users' interests). We have entered into a special agreement with Facebook ("Responsible Party Addendum, https://www.facebook.com/legal/controller_addendum), which regulates in particular which security measures Facebook must observe (https://www.facebook.com/legal/terms/data_security_terms) and in which Facebook has agreed to comply with data subjects' rights (i.e., users can, for example, provide information or make deletion requests directly to Facebook). Note: If Facebook provides us with metrics, analytics, and reports (which are aggregated, i.e., do not receive information about individual users and are anonymous to us), then this processing is not done under shared responsibility, but rather on the basis of a commissioned 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) as well as with regard to processing in the U.S. based on standard contractual clauses ("Facebook EU Data Transfer Addendum, https://www.facebook.com/legal/EU_data_transfer_addendum). The rights of users (in particular 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; Website: https://www.facebook.com; Privacy Policy: https://www.facebook.com/about/privacy.
  • Google Fonts: We integrate the fonts ("Google Fonts") of the provider Google, whereby the user's data is used solely for the purpose of displaying the fonts in the user's browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and taking into account possible licensing restrictions for their integration; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://fonts.google.com/; Privacy policy: https://policies.google.com/privacy.
  • Google Maps: We integrate the maps of the service "Google Maps" of the provider Google. The data processed may include, in particular, IP addresses and location data of users, which, however, are not collected without their consent (usually executed in the context of the settings of their mobile devices); service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; Website: https://cloud.google.com/maps-platform; Privacy policy: https://policies.google.com/privacy; Opt-Out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • reCAPTCHA: We integrate the "reCAPTCHA" function to be able to recognize whether entries (e.g. in online forms) are made by humans and not by automatically acting machines (so-called "bots"). The data processed may include IP addresses, information on operating systems, devices or browsers used, language settings, location, mouse movements, keyboard strokes, time spent on websites, previously visited websites, interactions with ReCaptcha on other websites, possibly cookies as well as results of manual recognition processes (e.g. answering questions asked or selecting objects in images); Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://www.google.com/recaptcha/; Privacy policy: https://policies.google.com/privacy; Opt-Out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • X plugins and content: X plugins and buttons - This may include, for example, content such as images, videos or text and buttons with which users can share content from this online service within X; service provider: X International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland, parent company: X Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA; Website:https://twitter.com/de; Privacy policy:https://twitter.com/privacy, (Settings: https://twitter.com/personalization).
  • YouTube videos: Video content; service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website:https://www.youtube.com; Privacy policy:https://policies.google.com/privacy; Opt-Out: Opt-out plugin: https://tools.google.com/dlpage/gaoptout?hl=de, settings for the display of advertisements: https://adssettings.google.com/authenticated.
  • Vimeo: Video content; Service provider: Vimeo Inc, Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA; Website: https://vimeo.com; Privacy policy: https://vimeo.com/privacy; Possibility of objection (opt-out): We point out that Vimeo may use Google Analytics and refer to the privacy policy (https://policies.google.com/privacy) and the opt-out options for Google Analytics (https://tools.google.com/dlpage/gaoptout?hl=de) or Google's settings for data use for marketing purposes (https://adssettings.google.com/).

Data deletion

The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose).

If the data is not deleted because it is required for other and legally permissible purposes, its processing is limited to these purposes. I.e., the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.

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

Modification and update of the privacy policy

We ask you to regularly inform yourself about the content of our privacy policy. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

Where we provide addresses and contact information for companies and organizations in this privacy statement, please note that the addresses may change over time and please check the information before contacting us.

Rights of the data subjects

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

  • Right to object: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purposes of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purposes of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
  • Right of withdrawal for consents: You have the right to revoke any consent you have given at any time.
  • Right to Information: You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with the legal requirements.
  • Right of rectification: In accordance with the legal requirements, you have the right to request that the data concerning you be completed or that incorrect data concerning you be corrected.
  • Right to erasure and restriction of processing: In accordance with the statutory provisions, you have the right to demand that data relating to you be deleted immediately or, alternatively, to demand restriction of the processing of the data in accordance with the statutory provisions.
  • Right to data portability: You have the right to receive data concerning you, which 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 transferred to another responsible party.
  • Complaint to supervisory authority: You also have the right, in accordance with the law, 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 relating to you infringes the GDPR.

Definitions

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

  • Visit Action Evaluation: "Visit action evaluation" (English "Conversion Tracking") refers to a procedure with which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users' devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we have placed on other websites have been successful).
  • Credit Report: Automated decisions are based on automatic data processing without human intervention (e.g. in the case of an automatic rejection of a purchase on account, an online credit application or an online application process without any human intervention. Such automated decisions are only permitted under Art. 22 GDPR if data subjects consent, if they are necessary for the performance of a contract, or if national laws permit such decisions.
  • Cross-Device Tracking: Cross-device tracking is a form of tracking in which user behavior and interest information is recorded across devices in so-called profiles by assigning users an online identifier. This allows user information to be analyzed for marketing purposes, irrespective of the browsers or devices used (e.g. cell phones or desktop computers). For most providers, the online identifier is not linked to clear data such as names, postal addresses or e-mail addresses.
  • IP Masking: IP masking" is a method in which the last octet, i.e., the last two numbers of an IP address, is deleted so that the IP address can no longer be used to uniquely identify a person. Therefore, IP masking is a means of pseudonymizing processing procedures, especially in online marketing
  • Interest-based and behavioral marketing: Interest-based and/or behavior-based marketing is when users' potential interests in ads and other content are determined as precisely as possible. This is done on the basis of information about their previous behavior (e.g., visiting and staying on certain websites, purchasing behavior or interaction with other users), which is stored in a profile. Cookies are generally used for these purposes.
  • Conversion measurement: Conversion measurement is a method used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the users' devices within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the ads we have placed on other websites have been successful.
  • Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiling: Profiling" is any form of automated processing of personal data which consists of using such personal data to analyze, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include information concerning age, gender, location data and movement data, interaction with websites and their content, shopping behavior, social interactions with other people) (e.g. interests in certain content or products, click behavior on a website or location). Cookies and web beacons are often used for profiling purposes.
  • Reach measurement: Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include visitors' behavior or interests in certain information, such as website content. With the help of reach analysis, website owners can see, for example, at what time visitors visit their website and what content they are interested in. This enables them, for example, to better adapt the content of the website to the needs of their visitors. For the purposes of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more precise analyses of the use of an online offer.
  • Remarketing: We speak of "remarketing" or "retargeting" when, for example, it is noted for advertising purposes which products a user was interested in on a website in order to remind the user of these products on other websites, e.g. in advertisements.
  • Location data: Location data is generated when a mobile device (or another device with the technical requirements of location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. Location data is used to indicate the geographically determinable position on earth at which the respective device is located. Location data can be used, for example, to display map functions or other information dependent on a location.
  • Tracking: Tracking" is when the behavior of users can be traced across several online offerings. As a rule, behavioral and interest information is stored in cookies or on servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
  • Person responsible: Controller" means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
  • Processing: "Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data, be it collection, analysis, storage, transmission or deletion.
  • Target group formation: We speak of target group formation (or "custom audiences") when target groups are determined for advertising purposes, e.g., insertion of advertisements. For example, based on a user's interest in certain products or topics on the Internet, it can be concluded that this user is interested in advertisements for similar products or the online store in which he viewed the products. In turn, we speak of "lookalike audiences" (or similar target groups) when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were formed. Cookies and web beacons are generally used for the purpose of creating Custom Audiences and Lookalike Audiences.