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” for short) that we process, for what purposes and to what extent. The Privacy Policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “Online Offerings”).

The terms used are not gender-specific.

Table of contents

Responsible

Del Medio Verlag GmbH
Uhlandstraße 4-5
10623 Berlin

Authorized representatives: Olaf Luft, Holger Heißenbüttel

E-mail address: info@easycitypass.com
Phone: +49 30 26 39 89 32

Imprint:

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.
  • Payment data.
  • Contract data.
  • Usage data.
  • Meta/communication data.
  • Event data (Facebook).

Categories of affected persons

  • Customers.
  • Prospects.
  • Communication partners.
  • Users.
  • Sweepstakes and competition participants.
  • Business and contractual partners.

Processing purposes

  • Provision of contractual services and customer service.
  • Contact requests and communication.
  • Security measures.
  • Direct marketing.
  • Reach measurement.
  • Tracking.
  • Office and organization procedures.
  • Affiliate tracking.
  • Managing and responding to inquiries.
  • Conducting sweepstakes and contests.
  • Feedback.
  • Marketing.
  • Profiles with user-related information.
  • Provision of our online services and user experience.
  • Information technology infrastructure.

Relevant legal bases

The following is an overview of the legal basis of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If, in addition, more specific legal bases are relevant in individual cases, we will inform you of these in the data protection declaration.

  • Consent (Art. 6 (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 performance and pre-contractual requests (Art. 6 (1) p. 1 lit. b) DSGVO) – Processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures taken at the data subject’s request.
  • Legal obligation (Art. 6 (1) p. 1 lit. c) DSGVO) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 (1) p. 1 lit. f) DSGVO) – Processing is necessary to protect the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

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

Security measures

The measures include, in particular, safeguarding the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as access to, entry into, disclosure of, assurance of availability of, and segregation of, the data relating to it. 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 as well as procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

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

Transmission 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. The recipients of this data may include, for example, 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 using third-party services or disclosing or transferring data to other persons, entities or companies, this is done only in accordance with legal requirements.

Subject to express consent or contractually or legally required transfer, we process or allow the data to be processed only in third countries with a recognized level of data protection, contractual obligation by 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, EU Commission information page: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

Data deletion

The data processed by us will be deleted in accordance with 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 are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. That is, 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 person or legal entity.

Our privacy notices may also include further information on the retention and deletion of data, which will take precedence for the processing operations in question.

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 notices: 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 in order 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.

Storage duration: In terms of storage duration, 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 app).
  • Permanent cookies: Permanent cookies remain stored even after the end 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., as part of 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): Users can revoke the consents they have given at any time and also file an objection to processing in accordance with the legal requirements in Art. 21 DSGVO. Users can also declare their objection via their browser settings, e.g. by deactivating the use of cookies (although this may also limit the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.

Further guidance on processing operations, procedures and services:

  • Processing of cookie data based on consent: We use a cookie consent management procedure in which the consent of users to the use of cookies, or the processing and providers mentioned 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.

Business services

We process data of our contractual and business partners, e.g. customers and prospective customers (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. in order to answer inquiries.

We process this data to fulfill our contractual obligations. This includes, in particular, the obligations to provide the agreed services, any update obligations and remedies for warranty and other performance problems. In addition, we process the data to safeguard our rights and for the purpose of administrative tasks associated with these obligations and company organization. Furthermore, we process the data on the basis of our legitimate interests in proper and business management as well as security measures to protect our contractual partners and our business operations from misuse, endangerment of their data, secrets, information and rights (e.g. for the involvement of telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfill legal obligations. Contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.

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

We delete the data after the expiry of statutory warranty and comparable obligations, i.e., in principle after the expiry of 4 years, unless the data is stored in a customer account, for example, as long as they must be kept for legal reasons of archiving. The statutory retention period for documents relevant to tax law as well as for commercial books, inventories, opening balances, annual financial statements, the work instructions required to understand these documents and other organizational documents and accounting records is ten years and for received commercial and business letters and reproductions of sent commercial and business letters six years. The period begins at the end of the calendar year in which the last entry was made in the book, the inventory, the opening balance sheet, the annual financial statements or the management report was prepared, the commercial or business letter was received or sent, or the accounting document was created, furthermore, the record was made or the other documents were created.

  • 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: Customers; prospective customers; business and contractual partners.
  • Purposes of processing: provision of contractual services and customer service; security measures; contact requests and communication; office and organizational procedures; management and response to requests.
  • 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).

Further guidance on processing operations, procedures and services:

  • Store and e-commerce: We 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 in order to be able to consult; legal basis: contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Provision of the online offer and web hosting

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

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); content data (e.g. entries in online forms).
  • Data subjects: Users (e.g. website visitors, users of online services).
    Purposes of processing: provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.).); security measures.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Provision of online offer on rented storage space: For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called “web hoster”);
  • legal basis: legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
    Collection of access data and log files: Access to our online offer is logged in the form of so-called “server log files”. The server log files may include the address and name of the web pages and files accessed, the date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a 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 event of abusive attacks, so-called DDoS attacks) and, on the other hand, to ensure the utilization of the servers and their stability;
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO);
  • Deletion of data: Log file information is stored for a maximum period of 30 days and then deleted or anonymized. Data whose further storage is required for evidentiary purposes is excluded from deletion until final clarification of the respective incident.

Contact and request management

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

  • Types of data processed: contact data (e.g. email, phone 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).
  • Data subjects: Communication partners.
  • Purposes of processing: contact inquiries and communication; managing and responding to inquiries; feedback (e.g. collecting feedback via online form); providing our online offer and user experience.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b) DSGVO).

Further guidance on processing operations, procedures and services:

  • 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 for the purpose of processing the communicated request; Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b) DSGVO), Legitimate Interests (Art. 6 para. 1 sentence 1 lit. f) DSGVO).

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 in the context of a registration for the newsletter its contents are specifically circumscribed, 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 email address. However, we may ask you to provide a name, for the purpose of personal address in the newsletter, or other information as necessary for the purposes of the newsletter.

Double opt-in procedure: Registration for our newsletter is always carried out 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 will be 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 block list (so-called “block list”) 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.

Contents

Information about us, our services, promotions and offers.

  • Types of data processed: inventory data (e.g. names, addresses); contact data (e.g. email, phone numbers); meta/communication data (e.g. device information, IP addresses); usage data (e.g. websites visited, interest in content, access times).
    Data subjects: Communication partners.
  • 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).
  • Option to object (opt-out): You can cancel 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.

Further guidance on processing operations, procedures and services:

  • Measurement of opening and click-through rates: The newsletters contain a so-called “web beacon”, i.e., a pixel-sized file that is retrieved from our server when the newsletter is opened, or, if we use a shipping service provider, from their server. In the course 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 for the technical improvement of our newsletter based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. This analysis also includes determining whether the newsletters are opened, when they are opened and – This text area must be activated with a premium license. Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).

Promotional communication via e-mail, mail, fax or telephone

We process personal data for the purposes of promotional communications, which may take place through various channels, such as e-mail, telephone, mail or fax, in accordance with legal requirements.

The recipients have the right to revoke consent given or to object to promotional communications at any time.

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

  • Types of data processed: inventory data (e.g., names, addresses); contact data (e.g., email, phone numbers).
  • Data subjects: Communication partners.
  • Purposes of processing: direct marketing (e.g. by e-mail or post).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO); Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Sweepstakes and contests

We process personal data of participants in sweepstakes and contests only in compliance with the relevant data protection provisions, to the extent that the processing is contractually necessary for the provision, implementation and execution of the sweepstakes, the participants have consented to the processing or the processing serves our legitimate interests (e.g., in the security of the sweepstakes or the protection of our interests against misuse by possible collection of IP addresses when submitting sweepstakes entries).

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

If the competition takes place within an online platform or social network (e.g. Facebook or Instagram, hereinafter referred to as “online platform”), the usage and data protection provisions of the respective platforms shall also apply. In these cases, we point out that we are responsible for the information provided by the participants within the scope of the sweepstakes and that inquiries with regard to the sweepstakes are to be directed to us.

The participants’ data will be deleted as soon as the competition or contest has ended and the data is no longer required to inform the winners or because queries about the competition are to be expected. In principle, the participants’ data will be deleted no later than 6 months after the end of the sweepstakes. Winners’ data may be retained for longer in order, for example, to be able to answer queries about the prizes or to fulfill the prize services; in this case, the retention period depends on the type of prize and is up to three years for items or services, for example, in order to be able to process warranty claims. Furthermore, the participants’ data may be stored for longer, e.g. in the form of reporting on the sweepstakes in online and offline media.

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

  • Types of data processed: inventory data (e.g., names, addresses); content data (e.g., input in online forms); meta/communication data (e.g., device information, IP addresses).
  • Data subjects: Sweepstakes and contest participants.
  • Purposes of processing: implementation of sweepstakes and contests.
  • Legal basis: Contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b) DSGVO).

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, for example, recognize 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 need 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.

Unless otherwise stated below, profiles, i.e. data summarized for a usage process, can be created for these purposes and information can be stored in a browser, or in a terminal device and read from it. The information collected includes, in particular, websites visited and elements used there, as well as technical information such as the browser used, the computer system used, and information on usage times. If users have agreed to the collection of their location data to us or to the providers of the services we use, location data may also be processed.

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The IP addresses of users are also stored. However, we use an IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, in the context of web analysis, A/B testing and optimization, no clear data of the users (such as e-mail addresses or names) are stored, but pseudonyms. I.e., 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.

  • 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).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: reach measurement (e.g. access statistics, recognition of returning visitors); profiling with user-related information (creation of user profiles); tracking (e.g. interest/behavior-based profiling, use of cookies); provision of our online offer and user experience.
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).

Further guidance on processing operations, procedures and services:

Affiliate programs and affiliate links

We include so-called affiliate links or other references (which may include, for example, search masks, widgets or discount codes) to the offers and services of third-party providers (collectively referred to as “Affiliate Links”) in our online offering. If users follow the Affiliate Links, or subsequently take advantage of the offers, we may receive a commission or other benefits from those third parties (collectively, “Commission”).

In order to be able to track whether users have taken advantage of the offers of an affiliate link used by us, it is necessary that the respective third-party providers learn that users have followed an affiliate link used within our online offer. The assignment of the affiliate links to the respective business transactions or to other actions (e.g. purchases) is solely for the purpose of commission accounting and will be cancelled as soon as it is no longer necessary for the purpose.

For the purposes of the aforementioned assignment of the Affiliate Links, the Affiliate Links may be supplemented by certain values that are a component of the link or may be stored elsewhere, e.g. in a cookie. The values may include, in particular, the source website (referrer), the time, an online identifier of the operators of the website on which the affiliate link was located, an online identifier of the respective offer, the type of link used, the type of offer and an online identifier of the user.

Notes on legal bases: If we ask users for their consent to use third-party providers, the legal basis for processing data is consent. Otherwise, users’ data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical 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: contractual data (e.g. subject matter of contract, term, customer category); usage data (e.g. web pages visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: affiliate tracking.
  • Legal Grounds: Consent (Art. 6 para. 1 sentence 1 lit. a) DSGVO); Legitimate Interests (Art. 6 para. 1 sentence 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

Customer reviews and evaluation process

We participate in review and rating processes in order to evaluate, optimize and promote our services. If users rate us or otherwise provide feedback via the participating rating platforms or procedures, the General Terms and Conditions of Business or Use and the privacy notices of the providers also apply. As a rule, the evaluation also requires registration with the respective providers.

To ensure that the evaluating persons have actually used our services, we transmit, with the consent of the customers, the data required for this purpose with regard to the customer and the service used to the respective evaluation platform (including name, e-mail address and order number or item number). This data is used solely to verify the authenticity of the user.

  • Types of data processed: contractual data (e.g. subject matter of contract, term, customer category); usage data (e.g. web pages visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Customers; users (e.g., website visitors, users of online services).
  • Purposes of processing: feedback (e.g. collecting feedback via online form); marketing.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Rating widget: We integrate so-called “rating widgets” into our online offer. A widget is a functional and content element integrated into our online offer that displays variable information. It can be displayed, for example, in the form of a seal or comparable element, sometimes also called a “badge”. In this case, the corresponding content of the widget is displayed within our online offer, but it is retrieved at that moment from the servers of the respective widget provider. This is the only way to always show the current content, especially the current rating. For this purpose, a data connection must be established from the website called up within our online offer to the server of the widget provider and the widget provider receives certain technical data (access data, including IP address), which are necessary so that the content of the widget can be delivered to the user’s browser. Furthermore, the widget provider receives information that users have visited our online offer. This information may be stored in a cookie and used by the widget provider to identify which online offers participating in the evaluation process have been visited by the user. The information may be stored in a user profile and used for advertising or market research purposes; legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

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 point out that in the process, data of the users may be processed outside the area of the European Union. This may result in risks for the users because, for example, the enforcement of the rights of the users could thus be made more difficult.

Furthermore, the data of users within social networks are usually processed 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: contact data (e.g. email, phone 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).
  • Data subjects: Users (e.g., website visitors, users of online services).
  • Purposes of processing: contact requests and communication; feedback (e.g. collecting feedback via online form); marketing.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).

Further guidance on processing operations, procedures and services:

  • Instagram: Social network; Service provider: Meta Platforms Irland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
  • Facebook pages: Profiles within the Facebook social network – We are jointly responsible with Meta Platforms Ireland Limited for collecting (but not further processing) data from visitors to our Facebook page (known as a “Fan Page”). This data includes information about the types of content users view or interact with, or the actions they take (see under “Things you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/policy), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see under “Device Information” in the Facebook Data Policy: https://www.facebook.com/policy). As explained in the Facebook Privacy Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, known as “Page Insights,” to Page operators to provide them with insights into how people interact with their Pages and with content associated with them. We have entered into a special agreement with Facebook (“Page Insights Information, https://www.facebook.com/legal/terms/page_controller_addendum), in which it is regulated in particular which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of the data subjects (i.e. users can, for example, send information or deletion requests directly to Facebook). 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. Further information can be found in the “Information on Page Insights”.(https://www.facebook.com/legal/terms/information_about_page_insights_data); Service provider: Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); 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): https://www.facebook.com/legal/EU_data_transfer_addendum; More information: Shared Responsibility Agreement: https://www.facebook.com/legal/terms/information_about_page_insights_data. The joint responsibility is limited to the collection by and transfer of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of data is the sole responsibility of Meta Platforms Ireland Limited, which concerns in particular the transfer of data to the parent company Meta Platforms, Inc. in the USA (based on the standard contractual clauses concluded between Meta Platforms Ireland Limited and Meta Platforms, Inc.).
  • LinkedIn: Social network; Service provider: LinkedIn Irland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Irland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Order processing contract: https://legal.linkedin.com/dpa; Standard contractual clauses (guaranteeing the level of data protection in the case of processing in third countries): https://legal.linkedin.com/dpa; Possibility of objection (Opt-Out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • YouTube: Social network and video platform; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Privacy policy: https://policies.google.com/privacy; Possibility of objection (Opt-Out): https://adssettings.google.com/authenticated.

Plugins and embedded functions and content

We incorporate into our online offering functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may be, for example, graphics, videos or city maps (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 functionality. 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, time of visit and other information about the use of our online offer as well as be linked to such information from other sources.

  • Types of data processed: Usage data (e.g. websites visited, interest in content, access times); meta/communication data (e.g. device information, IP addresses); inventory data (e.g. names, addresses); contact data (e.g. email, phone numbers); content data (e.g. entries in online forms); event data (Facebook) (“event data” is data that may be transmitted, e.g. via Facebook Pixel (via apps or other means), by us to Facebook and relates to individuals or their actions; the data includes e.g… For example, information about visits to websites, interactions with content, functions, installations of apps, purchases of products, etc.; Event data is processed for the purpose of forming target groups for content and advertising information (Custom Audiences); Event data does not include the actual content (such as comments written), no login information and no contact information (i.e. no names, email addresses and phone numbers). Event data is deleted by Facebook after a maximum of two years, the target groups formed from them with the deletion of our Facebook account).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online offer and user-friendliness; profiles with user-related information (creation of user profiles); marketing.
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Consent (Art. 6 para. 1 p. 1 lit. a) DSGVO).

Further guidance on processing operations, procedures and services:

  • 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 specific 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; Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a) DSGVO); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/about/privacy.
  • Google Fonts (provision on own server): Fonts (“Google Fonts”) for the purpose of a user-friendly presentation of our online offer; Service provider: The Google Fonts are hosted on our server, no data is transmitted to Google; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO).
  • Instagram Plugins and Content: Instagram 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 Service within Instagram. – We are jointly responsible with Meta Platforms Ireland Limited for collecting or receiving in the course of a transmission (but not further processing) “Event Data” that Facebook collects or receives in the course of a transmission by means of Instagram features (e.g., content embedding features) running on our Online Offer for the purposes of: a) displaying content as well as promotional information that matches users’ presumed interests; b) delivering commercial and transactional messages (e.g., targeting users via Instagram); c) providing commercial and transactional messages (e.g., targeting users via Instagram). 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; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO); Website: https://www.instagram.com; Privacy policy: https://instagram.com/about/legal/privacy.
  • LinkedIn Plugins and Content: LinkedIn plugins and content- This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offering within LinkedIn; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f) DSGVO);Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Order processing contract: https://legal.linkedin.com/dpa; Standard contractual clauses (guaranteeing the level of data protection in the case of processing in third countries): https://legal.linkedin.com/dpa; Possibility of objection (Opt-Out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
  • YouTube-Videos: Video content; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland; Legal basis: Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f) DSGVO); Website: https://www.youtube.com; Privacy policy: https://policies.google.com/privacy; Possibility of objection (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; Legal basis: Legitimate interests (Art. 6 Abs. 1 S. 1 lit. f) DSGVO); 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) as well as 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/).

Modification and update of the privacy policy

We ask you to regularly check 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 Policy, please note that addresses may change over time and please verify 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 revocation for consents: You have the right to revoke any consent you have given at any time.
  • Right of access: You have the right to request confirmation as to whether data concerning you is being processed and to obtain information about this data and further information and a copy of the data in accordance with the legal requirements.
  • Right to rectification: you have the right, in accordance with the law, to request that the data concerning you be completed or that inaccurate data concerning you be rectified.
  • Right to erasure and restriction of processing: In accordance with the legal requirements, you have the right to demand that data concerning you be deleted without delay, or alternatively, in accordance with the legal requirements, to demand restriction of the processing of the data.
  • Right to data portability: You have the right to receive data relating to you that you have provided to us in a structured, common and machine-readable format, or to request that it be transferred to another controller, in accordance with the law.
  • Complaint to the supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of the personal data concerning you violates the requirements of the GDPR.

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Questions about data protection

Please direct your questions to the above Data protection to info@easycitypass.com

Thank you very much.