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Privacy

Hpsmedia GmbH – Privacy policy for the websites of hpsmedia GmbH, 16 May 2018

This privacy policy informs you about all privacy-related aspects of the services offered by hpsmedia GmbH, An den Hafergärten 9, D-35410 Hungen (hereinafter “hpsmedia” or “we”), on its websites (the “websites”) and mobile app (the “app”), together the “services”.

We collect, process and use your personal data only in accordance with the following privacy policy. Personal data in this context means any individual information about the personal or factual circumstances of an identified or identifiable natural person, such as your name, telephone number and address, as well as other information about yourself which you provide when registering, using our services or contacting us (“personal data”).

Unless defined differently in this privacy policy, all terms used here have the same meaning as in the general terms and conditions of hpsmedia GmbH (the “terms and conditions”).

Controller responsible for data processing

hpsmedia GmbH is the controller responsible for data processing within the meaning of Article 4(4) of EU Regulation 2016/679 (“GDPR”), represented by Managing Director Prof. Dr. Andreas Lauterbach.

Collection and storage of personal data, and the nature and purpose of its use

1. Processing data for use of the website

When you access the website through your browser or the app through your mobile device, we collect only the personal data that your browser or mobile device automatically transmits to enable you to visit our website or app and to ensure stability and security. These may include, in particular:

  • your IP address;
  • your device identifier, i.e. the device's unique number;
  • the content, date and time of the request;
  • the time zone of the requesting computer or mobile device;
  • the website from which the request was referred;
  • the page requested;
  • the HTTP status code;
  • the amount of data transferred;
  • the browser ID;
  • your operating system;
  • the language and version of your browser software; and
  • Advertising Identifier (IDFA)

. These data are processed for the purposes of:

  • ensuring a smooth connection to the website;
  • displaying our services and products;
  • enabling use of our services;
  • analysis and system security and stability; and
  • other administrative purposes.

The legal basis for this processing of your personal data is Article 6(1), first sentence, point (f) GDPR. Our legitimate interest arises from the data-collection purposes stated above.


2. Processing data when using the contact form

We offer you the opportunity to contact us using a form provided on the website. A valid email address is required to use it; all other information is voluntary. These data are processed to enable you to contact us, on the basis of your freely given consent under Article 6(1), first sentence, point (a) GDPR.

 

3. Processing data for use of our services and products

If you wish to use our services and products, you may be asked at various times to provide personal data such as:

  • your name and date of birth;
  • your address;
  • your email address;
  • your telephone or mobile telephone number; and
  • credit card information.

We process your personal data for the following purposes, for which these data are necessary:

  • under Article 6(1), first sentence, point (b) GDPR, to fulfil contractual obligations or take steps prior to entering into a contract: to process your orders, including verifying your identity, activating your subscription, processing your payments and providing customer service; to correspond with you; to handle claims made by you or us; to ensure the technical administration of our website; and to manage our customer data;
  • under Article 6(1), points (b) and (c) GDPR, to fulfil contractual obligations and comply with legal requirements: to send you important emails about use of the website, the products and services offered, current technical problems or matters relating to our legal or regulatory obligations.

 

III. Disclosure of your data to processors and third parties

We use specialist external service providers to process your data, such as the financial institution handling payments, online marketing providers, marketing automation providers, web analytics providers and IT service providers. We select and engage these providers carefully; they are bound by our instructions and are monitored regularly.

We may also disclose your personal data to third parties, such as credit reference agencies, where this is necessary to protect our legitimate interests under Article 6(1), first sentence, point (f) GDPR.

Otherwise, your personal data are disclosed to third parties only if you have given prior consent under Article 6(1), first sentence, point (a) GDPR or a legal authorisation exists within the meaning of Article 6(1), first sentence, point (c) GDPR.

 

IV. Transfer of personal data abroad

Where we transfer personal data to countries outside the European Economic Area, we ensure that the recipient provides an adequate level of data protection within the meaning of Article 45 GDPR. Where there is no adequacy decision, hpsmedia GmbH will ensure that recipients have provided appropriate safeguards within the meaning of Article 46 GDPR and will use, in particular, the European Union's standard contractual clauses for transfers of data outside the EU, in their current version. When transferring data to the USA, hpsmedia GmbH will seek to require the recipient to observe and comply with the Privacy Shield principles, i.e. to recognise minimum standards for handling personal data.

 

V. Use of cookies

hpsmedia GmbH uses “cookies” on the website: small files containing text information which are stored on your hard drive when you access the service (“cookies”). Cookies store information relating to the particular device used. This does not, however, mean that we gain direct knowledge of your identity.

We use cookies to make navigation and use of our website as user-friendly as possible. We need cookies to identify and authorise you for the duration of your visit after you have signed in successfully. These cookies are automatically deleted from your hard drive at the end of the browser session (session cookies).

We also use cookies that remain on your hard drive for a specified period beyond the browser session (persistent cookies). These make it easier to use our website, services and products, for example by storing certain entries and settings so that you do not have to repeat them continually. These cookies also enable us to compile statistics on use of our website, optimise our services and personalise our websites and offers for you (see also section VII of this privacy policy). Persistent cookies are stored on your hard drive and deleted by the browser after a predetermined period which may vary from cookie to cookie. These may also be third-party cookies, as we work with advertising partners who help make the website and its services more interesting for you (see also section VII of this privacy policy).

The data processed through cookies are necessary for these purposes to protect our legitimate interests and those of third parties under Article 6(1), first sentence, point (f) GDPR.

We inform you about our use of cookies when you first visit our website or app. You can prevent future use of cookies at any time by deleting them and refusing cookies in your browser settings. You can also configure your browser to notify you when cookies are set, allow cookies only in individual cases, reject cookies in certain cases or generally, and delete cookies automatically when the browser is closed. If you do so, you may not be able to enjoy all the benefits of our services. Instructions on making these changes are available at www.allaboutcookies.org/manage-cookies/.

 

VI. Use of IDFA

In our apps, we use the “Advertising Identifier” (“IDFA”). This is a unique, non-personal and non-permanent identification number provided by iOS for a particular device. Data collected through the IDFA are not linked with other device-related information. We use the IDFA to provide personalised advertising and analyse your use. If you enable “Limit Ad Tracking” under “Privacy” – “Advertising” in the iOS settings, we can perform only the following measures: measure your interaction with banners by counting how often a banner is displayed without a click (“frequency capping”), measure click-through rates, identify unique use (“unique user”), and implement security measures, fraud prevention and troubleshooting. You can delete the IDFA at any time in your device settings (“Reset Advertising Identifier”); a new IDFA is then created and will not be combined with previously collected data. Please note that restricting use of the IDFA may prevent you from using all app functions.

 

VII. Use of analytics and tracking technologies

We use, among others, the following analytics, tracking and third-party technologies on the basis of Article 6(1), point (f) GDPR:

  • to carry out data analyses;
  • to compile statistics on use of our website and analyse them to optimise our services for you;
  • to improve and administer our services continually;
  • to measure and optimise the success of our advertising; and
  • to provide you with advertising, including personalised marketing information.

These interests are legitimate within the meaning of the provision stated above.

 

1. Google AdWords Conversion Tracking

To compile statistics on use of our website and analyse them to optimise it for you, we also use Google Conversion Tracking. This is a service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google places a cookie on your computer (see section V of this privacy policy) if you reach our website through a Google advertisement. These cookies expire after thirty days and are not used for personal identification. If you visit one of our pages while the cookie is still valid, Google and we can identify that you clicked the advertisement and were redirected to our page.

Each AdWords customer receives a different cookie, so cookies cannot be tracked across AdWords customers' websites. Information generated by the conversion cookie about your use of our services, including your IP address, is transferred to and stored on a Google server in the USA. Google is certified under the Privacy Shield, providing an adequate level of data protection according to the European Commission's implementing decision. The certificate is available at https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI. On our website and app, however, Google first truncates your IP address within EU Member States or other states party to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transferred to a Google server in the USA and truncated there.

Google uses this information on our behalf to compile visitor statistics for our website. We use these statistics to determine the total number of users referred to us through AdWords advertisements and thereby optimise those advertisements. This information may also be disclosed to third parties where required by law or where third parties process the data on behalf of others. Neither we nor other Google AdWords advertisers receive information from Google that could identify you personally.

You can prevent cookies from being stored by configuring your browser software accordingly. Please note, however, that you may then be unable to use all functions of our services to their full extent.

You can also object to interest-based advertising by Google. To do this, open the following link in each internet browser you use:

www.google.de/settings/ads and select the settings you want.

Further information about Google's privacy practices is available at the following links:

http://google.de/intl/de/policies/privacy und https://www.google.com/privacy/ads/.

 

2. Facebook Custom Audiences

We also use the “Custom Audiences” remarketing function of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). This enables users of our website to be shown interest-based advertisements (“Facebook Ads”) when visiting the Facebook social network or other websites using this method.

For this marketing function, we use “Facebook pixels”, i.e. tracking pixels integrated into our websites. When you visit our pages, a tracking pixel establishes a direct connection between your browser and Facebook's server. Your browser thereby informs Facebook, among other things, that our page was accessed from your device. Please note that we have no influence over the extent of the data transmitted or their subsequent use by Facebook, so we provide the following information to the best of our knowledge: integrating Facebook Custom Audiences informs Facebook that you accessed the relevant page of our website or clicked one of our advertisements. If you are registered with a Facebook service, Facebook can associate the visit with your account. Even if you are not registered with or signed into Facebook, the provider may obtain and store your IP address and other identifying characteristics.

Facebook is certified under the Privacy Shield, providing an adequate level of data protection according to the European Commission's implementing decision. The certificate is available at https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC.

You can object to future use of Facebook Website Custom Audiences at any time at https://www.facebook.com/settings/?tab=ads and http://www.youronlinechoices.com/de/praf erenzmanagement/. Further information about privacy and the settings available to you can be found at https://www.facebook.com/settings/?tab=ads and https://www.facebook.com/about/privacy.

 

3. Twitter Conversion Tracking

We use the remarketing function of Twitter Inc., 1355 Market St, San Francisco, California 94103, USA (“Twitter”). Twitter's remarketing function allows us to show you interest-based advertisements on the Twitter platform. Twitter uses “tags” for this purpose. These tags record website visits and website-use data in pseudonymous, non-personal form. When you subsequently visit Twitter, you are shown advertisements based on your interests. Your browser thereby informs Twitter, among other things, that our page was accessed from your device. Please note that we have no influence over the extent of the data transmitted or their subsequent use by Twitter, so we provide the following information to the best of our knowledge: integrating tags informs Twitter that you accessed the relevant page of our website. If you are registered with a Twitter service, Twitter can associate the visit with your account. Even if you are not registered with or signed into Twitter, the provider may obtain and store your IP address and other identifying characteristics.

Information generated by the tags about your use of our services is transferred to and stored on a Twitter server in the USA. Twitter is certified under the Privacy Shield, providing an adequate level of data protection according to the European Commission's implementing decision. The certificate is available at https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.

If you do not want to use Twitter's remarketing function, you can disable it at https://support.twitter.com/articles/20171528. Twitter also supports the “Do Not Track (DNT)” option. Alternatively, you can disable cookies for interest-based advertising through the Network Advertising Initiative by following the instructions at https://networkadvertising.org/managing/opt_out.asp.

Further information about Twitter remarketing and Twitter's privacy policy is available at https://business.twitter.com/de/help/troubleshooting/howtwitteradswork.html.

 

4. Use of social plugins

We use social plugins from social networks such as Facebook, Twitter and Google+ on our websites (Twitter, Facebook and Google collectively the “social networks”, and the corresponding plugins collectively the “plugins”). These plugins let you interact with the social networks and other users so that we can improve our services and make them more interesting for you, while also increasing awareness of our company. The legal basis for using social plugins is Article 6(1), first sentence, point (f) GDPR. The respective provider is responsible for ensuring operation in compliance with data protection law.

We use Facebook plugins such as the “Like” button. These are offered and operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”) and are clearly marked with the Facebook logo. We also use plugins from the Google network, operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, California 94043, USA (“Google”). These are marked with the Google logo or “Google +1”. Our website also integrates Twitter plugins offered and operated by Twitter Inc., 1355 Market St, Suite 900, San Francisco, CA 94103, USA (“Twitter”), marked with the Twitter logo or “Tweet”.

When you access one of our websites containing such a plugin, your browser connects directly to the servers of the relevant social network. The social network transmits the plugin's content directly to your browser, which integrates it into the webpage; we have no influence over its content.

Whether or not you have an account with or are signed into the social network, websites containing social-network plugins transmit information to that network in the USA, where it is stored. This includes your operating system and version, browser type and version, IP address, domain name and/or the date and time of your visit. Each time the website is accessed, the relevant social network places a cookie containing an identifier that is valid for two years. Because your browser automatically sends this cookie whenever it connects to a server, the social network could create a profile of websites visited by the user associated with that identifier. If you are signed into the social network at the same time, it can associate the profile with your account and therefore with you personally. Even if you are not signed into the social network when using our website, such an association cannot be ruled out, for example when you sign in later.

If you interact with the plugins, for example by clicking “Like”, “+1” or “Tweet” or leaving a comment, your browser transmits that information directly to the relevant social network, where it is stored; we have no influence over this. The information is also published on the social network and displayed to your contacts there.

The social network may use the information obtained for advertising, market research and tailoring its pages to users' needs. It creates usage, interest and relationship profiles, for example to analyse your use of our website in relation to advertisements displayed to you on the social network, inform other users of your activities on our website, and provide further services associated with use of the social network. Please note that we do not have complete knowledge of the content of the

data transmitted or their use by the social network. For more precise information about the nature, purpose, extent and subsequent processing and use of your data by the respective social network, please consult its privacy information (Facebook: http://dede.facebook.com/policy.php; Google: https://www.google.de/intl/de/policies/privacy/; Twitter: http://twitter.com/privacy). There you can also find out more about your rights and privacy settings. Facebook, Google and Twitter are certified under the Privacy Shield, providing an adequate level of data protection according to the European Commission's implementing decision. The certificates are available here:

Facebook: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC,

Google: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI,

Twitter: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active.

To prevent a social network collecting information about you while you visit our website, you can sign out of the social network at the start of your visit, delete any existing social-network cookie from your browser and select “Block third-party cookies” in your browser settings. With this setting,

your browser does not transmit cookies to other providers' servers for embedded content. However, this setting may mean that certain cross-site functions, as well as the plugins, are no longer available.

 

Newsletter / marketing

With your consent, which you may give when registering on our website, we will send you email newsletters or marketing materials about our products and services or those of our affiliated companies which we believe may interest you.

You can object to the use of your data for direct marketing with future effect and unsubscribe from the newsletter at any time by clicking the link included in every newsletter email or by emailing us at supporthpsmedia.info .

We reserve the right to email you offers for products or services similar to those you have already purchased, even without your consent. You have the right to object at any time to processing of your data for advertising purposes by emailing supporthpsmedia.info or using the corresponding link in our newsletter, without incurring costs other than transmission costs at the basic rates. The legal basis for processing your data to send newsletters is Article 6(1), first sentence, point (a) or point (f) GDPR.

 

Storage period

We store your personal data for as long as necessary to fulfil the relevant storage purpose. We then delete them unless we are required to retain them longer under Article 6(1), first sentence, point (c) GDPR due to tax, commercial or other statutory retention or documentation obligations, or you have consented to longer storage under Article 6(1), first sentence, point (a) GDPR.

 

Your rights

Under Article 15 GDPR, you are entitled at any time to information about the personal data we store about you. In particular, you may request information about the purposes of processing, categories of data stored, categories of recipients, envisaged storage period, existence of rights to rectification, erasure, restriction of processing or objection, existence of a right to complain to a supervisory authority, the origin of your data if not collected from you, and the existence of automated decision-making, including profiling, together with meaningful information about its details where applicable.

Under Article 16 GDPR, you may also request rectification of inaccurate data and, under Article 17 GDPR, erasure of personal data unless processing is necessary for exercising the right to freedom of expression and information, complying with a legal obligation, reasons of public interest, or establishing, exercising or defending legal claims.

You also have the right under Article 18 GDPR to request the blocking or restriction of processing of your personal data where you contest their accuracy, processing is unlawful but you oppose erasure, we no longer need the data but you require them to establish, exercise or defend legal claims, or you have objected to processing under Article 21 GDPR.

Under Article 20 GDPR, you also have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format or to request their transfer to another controller.

Finally, where your personal data are processed on the basis of legitimate interests under Article 6(1), first sentence, point (f) GDPR, Article 21 GDPR gives you the right to object at any time on grounds relating to your particular situation or where the objection concerns processing for direct marketing. In the latter case, you have a general right to object which hpsmedia GmbH will implement without your having to state a particular situation. If you believe that our processing of your personal data does not comply with applicable law, you may complain to a supervisory authority under Article 77 GDPR. Where processing is based on your consent under Article 6(1), point (a) GDPR, you may withdraw that consent at any time with future effect.

 

Data security

When you visit our website, we use the widely employed SSL protocol with the highest level of encryption supported by your browser.

We also use appropriate technical and organisational security measures to protect your data against manipulation, loss, destruction and unauthorised access by third parties. Our security measures are continually improved in line with technological developments.

 

Your privacy contact

For questions about the collection, processing or use of your personal data, requests for information, rectification, blocking or deletion of data, or withdrawal of consent, please contact info@hpsmedia-verlag.de