Data protection

With this privacy statement, we aim to inform you about the nature, scope, and purpose of processing personal data (hereafter referred to as ‘data’). Personal data includes all data that has a personal connection to you, such as your name, address, email address, or user behavior. This privacy statement applies to all data processing activities we conduct, both within the framework of our core activities and through online media we provide.

Commerce Partner B.B.

Schenkkade 50

2595 AR The Hague

Netherlands

+49 (0) 221 670 56 00

hallo@commerce-partner.de

Contact details for our Data Protection Officer

You can reach our Data Protection Officer via email at woywodt@commerce-partner.de or at our postal address with the addition "for the Data Protection Officer."

Processing your data as part of the agency services we offer

We provide agency services. If you are our client or business partner or are interested in our services, the nature, scope, and purpose of processing your data depend on the contractual or pre-contractual services agreed upon between us. This includes conceptual and strategic consulting, software and design development, consulting and maintenance in this area, campaign planning and implementation, IT and server administration, as well as other consulting and training services. The data we process for these purposes includes all data provided by or required from you to utilize contractual or pre-contractual services and to process your inquiries or the contract concluded between you and us. Unless otherwise stated in the additional notes of this privacy statement, the processing of your data and their disclosure to third parties are limited to the data required to respond to your inquiries and/or fulfill the contract between you and us, protect our rights, and comply with legal obligations. We inform you about which data is necessary before or during the data collection process. If we employ third-party providers to deliver our services, the privacy notices of those providers apply.

Data concerned:

Inventory data (e.g., names, addresses)

Payment data (e.g., banking details, invoices)

Contact data (e.g., email address, phone number, postal address)

Contract data (e.g., contract object, duration)

Persons affected:

Customers, prospects, business, and contractual partners

Purpose of processing:

Handling contractual services, communication, and responding to contact requests, office and organizational processes

Legal basis:

Contract performance and pre-contractual inquiries, Article 6(1)(b) GDPR, legal obligation, Article 6(1)(c) GDPR, legitimate interest, Article 6(1)(f) GDPR

Your rights under the GDPR

Under the GDPR, you are entitled to the following rights, which you can exercise at any time by contacting the responsible party mentioned in Section 1 of this privacy statement:

Right of access: You have the right to request information from us about whether and which data we process about you.

Right to rectification: You have the right to request the correction of inaccurate or incomplete data.

Right to erasure: You have the right to request the deletion of your data.

Right to restriction: In certain cases, you have the right to request that we restrict the processing of your data.

Right to data portability: You have the right to request that we provide your data to you or another responsible party in a structured, common, and machine-readable format.

Right to complain: You have the right to lodge a complaint with a supervisory authority. The competent authority is the one in your habitual residence, workplace, or our company’s headquarters.

Right to withdraw consent

You have the right to withdraw your consent for data processing at any time.

Right to object

You have the right to object to the processing of your data, which we base on our legitimate interest under Article 6(1)(f) GDPR, at any time. If you exercise your right to object, we kindly ask you to provide us with your reasons. We will then no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that outweigh your interests and rights.

Notwithstanding the foregoing, you have the right to object at any time to the processing of your personal data for advertising and data analysis purposes.

Please address your objection to the above-cited contact address of the responsible party.

When do we delete your data?

We delete your data when they are no longer needed, or you instruct us to do so. This means that – unless otherwise noted in the individual data protection hints of this privacy statement – we delete your data once the purpose for which the data were processed ceases, and the relevant legal basis stated in the individual data protection hints no longer exists, such as:

after the termination of our contractual or membership relationships (Article 6(1)(a) GDPR), or

after the legitimate interest in further processing or storing your data no longer applies (Article 6(1)(f) GDPR),

when you exercise your right to withdraw and there is no legal basis for further processing as per Article 6(1)(b-f) GDPR,

when you exercise your right to object unless there are compelling legitimate reasons against deletion.

However, if we are required to retain (parts of) your data for other purposes, such as tax retention periods (generally 6 years for business correspondence or 10 years for accounting records) or in order to establish, exercise or defend legal claims arising from contractual relationships (up to four years) or if the data is needed to protect the rights of another natural or legal person, we will only delete (the part of) your data after the expiration of those periods. Until the expiration of these periods, we will restrict the processing of these data to these purposes (fulfillment of retention obligations).

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Cookie & Cookie Group Overview

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Our website uses cookies. Cookies are small text files made up of a series of numbers and letters stored and saved on the device you use. Cookies are mainly used to exchange information between your device and our website, such as language settings on a page, login status, or the point at which a video was viewed.

Two types of cookies are used when visiting our websites:

Temporary cookies (session cookies): These store a session ID, allowing different requests from your browser to be assigned to the shared session. The session cookies are deleted when you log out or close your browser.

Permanent cookies: Permanent cookies remain stored even after closing the browser. This allows our website to recognize your device when you return. These cookies may store information, such as language settings or login information. Additionally, your browsing behavior can be documented and stored with these cookies for statistical, marketing, and personalization purposes.

In addition to this division, cookies can also be distinguished based on their purpose:

Necessary cookies: These cookies are mandatory for the operation of our website, ensuring that logins or shopping carts are saved for the duration of your session, or to set cookies for security reasons.

Statistics, marketing, and personalization cookies are used for analysis purposes or to measure reach. Through such "tracking" cookies, particularly the information on search terms entered or the frequency of page visits can be stored. In addition, the surfing behavior of a single user (e.g., viewing specific content, using functions, etc.) can be saved in a user profile. Such profiles are used to display content to users corresponding to their potential interests. If we use services that store cookies on your device for statistical, marketing, and personalization purposes, we will inform you in separate sections of our privacy statement or within the context of obtaining your consent.

Data concerned:

Usage data (e.g., access times, clicked websites)

Communication data (e.g., information about the device used, IP address).

Persons affected:

Users of our online offers

Purpose of processing:

Playing our websites, ensuring the operation of our websites, improving our online offerings, communication, and marketing

Legal basis:

Legitimate interest, Article 6(1)(f) GDPR

If we do not obtain your consent for setting cookies, we base the processing of your data on our legitimate interest in improving the quality and user-friendliness of our online presence, especially the content and functions. You have the option in your browser’s security settings to object to the cookies we set under our legitimate interest. There you can specify whether you want to accept no cookies, only cookies on request, or cookies that are deleted after each browser session. If cookies are disabled for our website, some functions of the website may not be fully usable.

Consent, Article 6(1)(a) GDPR

If, before visiting our online presence, we request your permission to place certain cookies on your device, and you consent, the legal basis lies in the consent you provided. We will inform you during the consent process about which cookies we set in detail. If you do not consent to the setting of these cookies, only the so-called technically necessary cookies are set, which are required for the proper operation of our websites and their display in your browser. If you have consented to the setting of cookies, you can revoke your consent to us at any time.

Web hosting

We use a provider to host our websites, where the websites are stored and made available for retrieval on the Internet (hosting). All data transmitted by your browser during your use of our websites may be processed by the provider. This includes in particular your IP address, which the provider needs to be able to deliver our online offerings to your browser, as well as any input made by you through our website. Furthermore, the provider we use may

record the date and time of access to our website

time zone difference to Greenwich Mean Time (GMT)

access status (HTTP status)

the amount of data transferred

the internet service provider of the accessing system

the browser type and version you use

the operating system you use

the website from which you may have reached our website

the pages or subpages you visit on our website.

The listed data are stored as log files on the servers of our provider. This is necessary to ensure the stability and security of our website's operation.

Data concerned:

Content data (e.g., posts, photos, videos)

Usage data (e.g., access times, clicked websites)

Communication data (e.g., information about the device used, IP address)

Persons affected:

Users of our online presence

Purpose of processing:

Providing our websites, ensuring the operation of our websites

Legal basis:

Legitimate interest, Article 6(1)(f) GDPR

Commissioned web hoster:

Profihost GmbH

Service provider: Profihost GmbH

Website: Expo Plaza 1 30539 Hanover Germany

Website

Privacy statement

Contact

If you contact us via email, social media, phone, fax, post, our contact form, or otherwise and provide us with personal data such as your name, phone number, or email address or other details about you or your concern, we process this data to respond to your inquiry as part of our pre-contractual or contractual relationships with you.

Data concerned:

Inventory data (e.g., names, addresses)

Contact data (e.g., email address, phone number, postal address)

Content data (texts, photos, videos)

Contract data (e.g., subject of contract, duration)

Persons affected:

Interested parties, customers, business, and contractual partners

Purpose of processing:

Communication and handling of contact requests, office and organizational procedures

Legal basis:

Performance of the contract and pre-contractual inquiries, Article 6(1)(b) GDPR, legitimate interest, Article 6(1)(f) GDPR

Handling your data in the application process

If you apply to us, we process the personal data you provide in the application process, such as your name, address, place of residence, age, application photo, email, and phone number, career history, including schools, training, and studies. If you send the data by email or through a contact form on our website, the processing takes place electronically. When submitting your application through the contact form, the transmission of your data is encrypted according to the state of the art. If you send your data by email, please note that the transmission is generally unencrypted. If the application process concludes with an employment contract, we store your data to handle the employment relationship while observing statutory regulations.

Data concerned:

Inventory data (e.g., names, addresses)

Payment data (e.g., banking details, invoices)

Contact data (e.g., email address, phone number, postal address)

Contract data (e.g., contract object, duration)

Persons affected: Applicants

Purpose of processing:

Executing the application process

Legal basis:

Performance of the contract and pre-contractual inquiries, Article 6(1)(b) GDPR, legal obligation, Article 6(1)(c) GDPR

Deletion:

If an employment contract is not concluded, your data will be deleted after the conclusion of the application process or, at the latest, two months after its conclusion. This does not apply if statutory provisions oppose the deletion or if further storage of your data is necessary for evidential purposes, for example, in a procedure under the General Equal Treatment Act (AGG). The application process is considered completed when the rejection letter has been sent to you.

You have the opportunity to comment on, express your opinion, or post content in the designated areas of our website. Since we can be liable for illegal content in your comment (insults, defamation, incitement, prohibited depiction of violence, etc.), we store your IP address for 7 days to potentially determine your identity.

Legal basis:

Article 6(1)(f) GDPR

Data concerned:

Inventory data (e.g., names, addresses)

Content data (e.g., posts, photos, videos)

Usage data (e.g., access times, clicked websites)

Communication data (e.g., information about the device used, IP address)

Purpose of processing:

Fulfilling performance obligations, communication, and handling of requests, obtaining feedback, security measures.

Review badge

To provide you with an initial impression of the quality of our offers and services, we display a selection of our customers' reviews and the overall rating formed from all reviews via the review badge (also known as the rating widget) embedded on our website. When you click the widget, you will be directed to the provider’s online offering where you can view all reviews of our offer. Moreover, you can rate us there.

The badge embedded on our websites is displayed via an interface from the provider’s server. When you visit our online presence, a data connection to the provider’s server is established. The provider receives certain data needed to play the widget’s contents to your browser. This includes the IP address assigned to you and other access data.

Data concerned:

Usage data (e.g., access times, clicked websites)

Communication data (e.g., information about the device used, IP address).

Persons affected:

Customers, users of our online presence

Purpose of processing:

Obtaining customer feedback, interest-based and behavior-based marketing

Legal basis:

Consent, Article 6(1)(a) GDPR, legitimate interest, Article 6(1)(f) GDPR

We use the following review badges:

Trustpilot

Service provider: Trustpilot A/S, Pilestraede 58, 5th Floor, 1112 Copenhagen, Denmark

Website

Privacy statement

We use services to play internet advertising. Through the services we use, certain user data is collected via a cookie or pixel. This includes, in particular, the information of which website you accessed our online presence from (so-called referrers), which pages of our online presence you accessed, how long you visited our pages, and what interactions you made there. In addition, data on the browser you use, the computer system, and the type of device are collected. Furthermore, demographic information such as age or gender may be captured as pseudonymous values through such a service. If you consented to the collection of your location data, these might also be processed depending on the provider. To capture and store these data, the respective service sets a cookie or so-called counting pixel on the device you use, which also collects the IP address assigned to you. However, this is shortened by a so-called IP masking process, so the IP address can no longer be assigned to your visit to our website. As a rule, no clear data such as names or email addresses are stored when using the respective service. This occurs only if you are a member of a social network that offers one of the services mentioned and your profile is combined with the data mentioned above.

The data analyzed by the service we use is reported with statistical statements about the number of visitors generated through advertising and the success of the advertising campaign. For instance, reports outline the total number of users redirected to our website by our ads. The reports also contain information about the users’ devices and browsers, their locations, and when the advertisement was clicked. However, the reports don’t include any information that could identify you personally as a user of our site.

We want to point out that, depending on the service provider's location, the collected data may be transferred and processed outside the European Union. In this case, the required data protection level stipulated by the GDPR may not be ensured, and enforcing your rights might be difficult.

Data concerned:

Usage data (e.g., access times, clicked websites)

Communication data (e.g., information about the device used, IP address)

Persons affected:

Users of our online offers

Purpose of processing:

Reach measurement, success control of campaigns, remarketing, and interest-based and behavior-based marketing

Legal basis: If we requested your consent before using the respective service, this serves as the legal basis, Article 6(1)(a) GDPR. Otherwise, we employ the service based on our legitimate interest in guiding visitor flows to our website, analyzing them to continually improve the functions, offerings, and user experiences, Article 6(1)(f) GDPR.

We use the following services providers for online advertising:

Facebook Pixel

Service provider: Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA

EU headquarters: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland

Website

Privacy statement

Opt-out option

We also use the "enhanced matching" feature, where your personal data is transferred to Facebook in encrypted form.

Additionally, we use the "Custom Audiences from File" method, where your email address, as a newsletter recipient, is uploaded to Facebook in encrypted form. This helps us identify the recipients of our Facebook ads and ensure that the ads are shown only to those interested.

Google AdSense

Service provider: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

EU headquarters: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland

Website

Privacy statement

Google Ads

Service provider: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

EU headquarters: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland

Website

Privacy statement

Newsletter

We send out a regular newsletter to inform our customers, business partners, and interested parties about our offers and related news. You can register for our newsletter on our website, consenting to receive the newsletter. When you register for our newsletter, you must provide your email address. We save the email address to send you the newsletter. Once you register for our newsletter, a confirmation email is sent to the email address entered during the registration process in the so-called double opt-in process. This email contains a link. By clicking this link, you confirm that you want to receive the newsletter, ensuring your email address wasn’t misused during the registration by a third party. For the same reason, we save the registration date and time, as well as the IP address assigned to you during the registration process. We do not share this data with third parties.

Data concerned:

Content data (e.g., posts, photos, videos)

Usage data (e.g., access times, clicked websites)

Communication data (e.g., information about the device used, IP address)

Persons affected:

Users of our online presence

Purpose of processing:

Displaying our websites, ensuring the operation of our websites

Legal basis:

Consent, Article 6(1)(a) GDPR, legitimate interest, Article 6(1)(f) GDPR

Deletion:

The email address is deleted if you do not click the confirmation link in the double opt-in process within one month after the confirmation email is sent, or directly after you unsubscribe from our newsletter.

Withdrawal:

You can withdraw your consent to receive the newsletter and unsubscribe from the newsletter at any time. We offer the following options for withdrawing your consent:

Click on the link provided for this purpose in the newsletter

Advertising via email, mail, or phone

For our promotional communication via email, mail, or phone, we process personal data. You can object to receiving our promotional communication at any time or withdraw consent previously given to receive our promotional communication. To prove in case of doubt that your consent was given, we may store your data up to four years after your objection/withdrawal. We do not use your data for other purposes after your objection/withdrawal. If you wish your data to be deleted earlier, we will do so after you confirm that you originally consented to us.

Data concerned:

Contact data (e.g., email, phone number, postal address)

Inventory data (e.g., names, addresses)

Persons affected:

Communication partners

Purpose of processing:

Direct promotional measures (marketing) via email, mail, or phone

Legal basis:

Consent, Article 6(1)(a) GDPR, legitimate interest, Article 6(1)(f) GDPR

Web analysis and statistics

We use web analytics services to collect and statistically evaluate visitor flows on our online presence. Such services collect, among other things, data about which website you came to our online presence from (so-called referrers), which pages of our online presence you visited, how long you spent on our pages, and what interactions you made there. Additionally, data about the browser you use, computer system, and device type are collected. Furthermore, demographic information, such as age or gender, can also be captured as pseudonymous values through such a service. If you have consented to the collection of your location data, this data can also be processed depending on the provider.

To collect and store these data, the web analytics service we use generally sets a cookie on your device, which also records the IP address assigned to you. However, this is shortened through an IP masking process, so that the IP address can no longer be associated with your visit to our website. Also, no clear data such as names or email addresses are saved otherwise. Neither we nor the service we use knows the identity of the visitors to our websites.

We want to point out that, depending on the country of the services provider's location stated below, the data collected through the service may be transferred and processed outside the European Union. There is a risk that the data protection level prescribed by the GDPR is not adhered to, and enforcing your rights may be difficult or impossible.

Data concerned:

Usage data (e.g., access times, clicked websites)

Communication data (e.g., information about the device used, IP address).

Persons affected:

Users of our online offers

Purpose of processing:

Reach measurement, success control of campaigns, remarketing, as well as interest and behavior-based marketing

Legal basis:

If we request your consent before using the respective service, this serves as the legal basis, Article 6(1)(a) GDPR. Otherwise, we base the service's use on our legitimate interest in analyzing our online presence's visitor flows to improve functions, offers, and user experiences continuously, Article 6(1)(f) GDPR.

We use the following web analysis services:

Google Analytics

Service provider: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

EU headquarters: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland

Website

Privacy statement

Opt-out option:

If you don't want your data used by Google Analytics, you can set up an opt-out plugin to prevent data collection from your visit to our website in the future. You can find this plugin here.

Google Universal Analytics

Service provider: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

EU headquarters: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland

Website

Privacy statement

Cross-device tracking:

With cross-device tracking, data from websites you visited and other devices can be evaluated using a user ID, and the user can be recognized on the other device. The user ID is issued by us and serves as a pseudonym. The internet user’s identity is thereby excluded.

Opt-out option:

If you don’t want your data used by Google Analytics, you can set an opt-out plugin to prevent future data collection on our website. This plugin can be obtained here.

Our online presences on social networks

We operate online presences on the social networks listed below. When you visit one of these presences, the respective provider collects and processes the data outlined below. These data are generally collected for advertising and market research purposes, whereby usage profiles are created. Data can be saved in usage profiles, independent of the device you use. This is particularly the case if you are a member of the respective platform and are logged in. Providers may use the usage profiles to display interest-based advertising to you. You have the right to object to the creation of user profiles. To exercise this right, you must contact the respective provider directly.

If you have an account with one of the providers listed below and are logged in to that account when visiting our site, the respective provider can collect data about your browsing behavior on our website. To prevent your data from being linked in this way, you can log out of the provider’s account before visiting our site.

The purpose and scope of data collection by the provider and further processing and use of your data, along with rights and settings options for protecting your privacy, are detailed in the following disclosed privacy statements from the providers.

We want to point out that, depending on the country of the provider mentioned below, the data collected through the platform may be transferred and processed outside the European Union. In this case, the DSGVO-mandated privacy level may not be maintained, and exercising your rights might be difficult.

Data concerned:

Stock and contact data (e.g., name, address, phone number, email address)

Content data (e.g., posts, photos, videos)

Usage data (e.g., access times, clicked websites)

Communication data (e.g., information about the device used, IP address).

Purpose of processing: Communication and marketing, tracking, and analysis of user behavior

Legal basis:

Consent, Article 6(1)(a) GDPR, legitimate interests, Article 6(1)(f) GDPR

Opt-out options:

We refer you to the linked information to the providers below for the respective opposition possibilities (opt-out).

We maintain online presences on the following social networks:

Facebook

Service provider: Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA

EU headquarters: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland

Website

Privacy statement

Privacy statement for Facebook pages

Instagram

Service provider: Instagram Inc., 1601 Willow Road, Menlo Park CA 94025, USA

Parent company: Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA

EU headquarters: Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland

Website

Privacy statement

LinkedIn

Service provider: LinkedIn Corporation, 1000 W Maude, Sunnyvale, CA 94085, USA

Germany office: LinkedIn, Hofstatt 4th Floor, Sendlinger Str. 12, 80331 Munich

Website

Privacy statement

Pinterest

Service provider: Pinterest Inc., 635 High Street, Palo Alto, CA 94301, USA

EU headquarters: Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland

Website

Privacy statement

Twitter

Service provider: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA

Website

Privacy statement

Chat Services

We communicate via online chats and/or chatbots (hereafter referred to as chat services). An online chat means exchanging text messages over the Internet in real-time. Chatbots are computer programs typically used on websites to answer user questions automatically or play notifications to users.

If you use our chat services, we collect your access data. This includes in particular the IP address of the requesting device, the date and time of the request, and your identification number. We also save the contents of the communication via the chat services. Finally, we log your registration and your consent declaration. We use this data to communicate with you via our chat services, address you personally, answer your inquiries, and deliver any requested content.

The service provider(s) listed below have access to the communication's metadata. This includes the time and (depending on settings) location of the communication as well as the device used by you and information on who communicated with whom. The service provider generally accesses the metadata to optimize the service or for security reasons. However, this access can also be used by the service provider for marketing purposes. You can find more detailed information in the service provider’s privacy statement, which we have linked below.

We want to point out that, depending on the service provider's location listed below, the data collected through its platform may be transferred and processed outside the European Union. There is a risk that the required DSGVO-mandated data protection level is not adhered to and that exercising your rights may be difficult or impossible.

Data concerned:

Stock and contact data (e.g., name, phone number, email address)

Content data (e.g., text entries)

Usage data (e.g., access times, interest in content)

Communication data (e.g., information about the device used, IP address).

Purpose of processing:

Communication and marketing

Legal basis:

If we requested your consent before using the respective chat service, this serves as the legal basis, Article 6(1)(a) GDPR. We clarify that we do not transfer your contact data to the service provider without your consent. If we communicate with you as part of contract initiation or within an existing contractual relationship through one of the services listed below, the legal basis lies in fulfilling or preparing the contract, Article 6(1)(b) GDPR. In addition, we base our communication on our legitimate interest in quick and efficient communication and in fulfilling our communication partners' needs regarding the communication through the services listed below, Article 6(1)(f) GDPR.

Opt-out options:

You can withdraw the consent granted to us for the use of the following named services at any time. You can also object to the processing of your data via the chat service we use at any time.

We use the following chat bots and chat features:

HubSpot

Service provider: HubSpot, Inc., 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA

Website

Privacy statement

Security Measures

We take technical and organizational security measures according to the state of the art to comply with data protection laws and protect your data against accidental or intentional manipulation, partial or complete loss, destruction, or unauthorized access by third parties.

Updates and Changes to this Privacy Statement

This privacy statement is current as of September 2021. Due to changed legal or regulatory requirements, it may become necessary to adjust this privacy statement.

This privacy statement was created with the help of SOS Recht's privacy generator. SOS Recht is a service offered by Mueller.legal legal partnership based in Berlin.