Privacy Statement and Consents
Table of contents
- Objective setting and responsible body
- Basic data processing information
- Personal Data Processing
- access data collection
- Cookies & range measurement
- Google Analytics
- Facebook Social Plugins
- Facebook Remarketing
- integration of services and content of third parties
- user rights and deletion
1. objective and responsible body
The provider of the online offer and the data protection officer is Vatansever Investment, Wollmatingerstr. 50,78467 Konstanz, Germany (hereinafter referred to as “provider”, “we” or “us”). For the contact possibilities we refer to our imprint.
The term “user” covers all customers and visitors of our online offer. The terms used, such as “user”, are to be understood as gender-neutral.
2. Basic data processing information
We process users’ personal data only in compliance with the relevant data protection regulations in accordance with the principles of data economy and data avoidance. This means that the user’s data will only be processed if legal permission has been obtained, in particular if the data is required for the provision of our contractual services and online services, or is prescribed by law, or if consent has been obtained.
We take organisational, contractual and technical security measures in accordance with the state of the art to ensure that the provisions of data protection laws are complied with and to protect the data processed by us against accidental or intentional manipulation, loss, destruction or against access by unauthorised persons.
If contents, tools or other means from other providers (hereinafter jointly referred to as “third party providers”) are used within the scope of this data protection declaration and their registered office is abroad, it is to be assumed that a data transfer to the registered office states of the third party providers takes place. The transfer of data to third countries is carried out either on the basis of a legal permit, user consent or special contractual clauses which guarantee the security of the data required by law.
3. Processing of personal data
In addition to the use expressly stated in this data protection declaration, personal data will be processed for the following purposes on the basis of legal permissions or user consents:
- The provision, execution, maintenance, optimization and safeguarding of our services and users;
- The guarantee of effective customer service and technical support.
We only transfer user data to third parties if this is necessary for billing purposes (e.g. to a payment service provider) or for other purposes if these are necessary to fulfil our contractual obligations towards users (e.g. address communication to suppliers).
When contacting us (via contact form or email), the user’s details are stored for the purpose of processing the enquiry and in the event that follow-up questions arise.
Personal data will be deleted as long as they have fulfilled their intended use and there are no storage obligations to prevent deletion.
4. access data collection
We collect data about each access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
We use the protocol data without allocation to the person of the user or other profile creation according to the legal regulations only for statistical evaluations for the purpose of the operation, the security and the optimization of our online offer. However, we reserve the right to subsequently check the log data if there is a justified suspicion of illegal use on the basis of concrete indications.
5. cookies & range measurement
The viewing of this online offer is also possible under exclusion of cookies. If users do not wish cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
It is possible to manage many online ad cookies from companies via the US American site https://www.aboutads.info/choices or the EU site https://www.youronlinechoices.com/uk/your-ad-choices/.
6. Google Analytics
Google will use this information on our behalf to evaluate the use of our website by users, to compile reports on activities within this website and to provide us with other services relating to the use of this website and the Internet. Pseudonymous user profiles can be created from the processed data.
We use Google Analytics only with activated IP anonymisation. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.
Further information on the use of data for advertising purposes by Google, setting and objection options can be found on the Google web pages: https://www.google.com/intl/de/policies/privacy/partners (“Use of data by Google when using the websites or apps of our partners”), https://www.google.com/policies/technologies/ads (“Use of Data for Advertising Purposes”), https://www.google.de/settings/ads (“Manage Information Google Uses to Show You Advertising”) and https://www.google.com/ads/preferences (“Determine Which Advertising Google Shows You”).
We use the marketing and remarketing services (“Google Marketing Services”) of Google Ireland Ltd, Gordon House, 4 Barrow St,Dublin, D04 E5W5, Ireland, (“Google”).
Google’s marketing services allow us to display advertisements for and on our website in a more targeted manner to show users only ads that potentially match their interests. For example, if users see ads for products they are interested in on other websites, this is referred to as “remarketing. For these purposes, when you visit our and other web pages where Google marketing services are active, Google directly executes a Google code and incorporates (re)marketing tags (invisible graphics or code, also known as “web beacons”) into the web page. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). Cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com and googleadservices.com. In this file it is noted which websites the user visits, which contents he is interested in and which offers he has clicked, furthermore technical information about the browser and operating system, referring websites, visiting time as well as further information about the use of the online offer. The IP address of the user is also recorded, whereby we inform within the scope of Google Analytics that the IP address within member states of the European Union or in other contracting states of the Agreement on the European Economic Area is shortened and only in exceptional cases completely transferred to a Google server in the USA and shortened there. The IP address is not merged with user data within other Google services. The above information may also be linked to such information from other sources. If the user subsequently visits other websites, advertisements tailored to the user’s interests may be displayed.
User data is processed pseudonymously within the framework of Google Marketing Services. This means, for example, that Google does not store and process the name or e-mail address of the user, but processes the relevant data cookie-related within pseudonymous user profiles. This means that, from Google’s point of view, the ads are not administered and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymisation. The information DoubleClick collects about users is transmitted to Google and stored on Google’s servers in the United States.
One of the Google marketing services we use is the online advertising program “Google AdWords”. In the case of Google AdWords, each AdWords customer receives a different “conversion cookie”. Cookies can therefore not be tracked via the websites of AdWords customers. The information collected through the cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers learn the total number of users who clicked on their ad and were directed to a page tagged with a conversion tracking tag. However, you will not receive any information that personally identifies users.
Another Google marketing service we use is the “Google Tag Manager”, which can be used to integrate other Google analysis and marketing services into our website (e.g. “AdWords”, “DoubleClick” or “Google Analytics”).
If you wish to opt out of Google’s marketing services, you may use the settings and opt-outs provided by Google: https://www.google.com/ads/preferences.
8th Facebook Social Plugins
Our online offer uses social plugins (“Plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The plugins can be recognized by one of the Facebook logos (white “f” on a blue tile, the terms “like”, “like” or a “thumbs up” sign) or by the addition “Facebook Social Plugin”. The list and appearance of the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
When a user calls a function of this online service that contains such a plugin, his device establishes a direct connection with the Facebook servers. The content of the plugin is transmitted directly from Facebook to the user’s device and integrated into the online service by the user. User profiles can be created from the processed data. We therefore have no influence on the extent of the data that Facebook collects with the help of this plugin and therefore inform the user according to our state of knowledge.
By integrating the plugins, Facebook receives the information that a user has called up the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to his Facebook account. When users interact with the plugins, for example by clicking the Like button or commenting, the corresponding information is transferred directly from your device to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to find out his IP address and save it. According to Facebook, only an anonymous IP address is stored in Germany.
The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the related rights and setting options to protect the privacy of users, can be found in Facebook’s data protection information: https://www.facebook.com/about/privacy/.
If a user is a Facebook member and does not want Facebook to collect information about him or her via this online service and link it to his or her member data stored on Facebook, he or she must log out of Facebook and delete his or her cookies before using our online service. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US site https://www.aboutads.info/choices/ or the EU site https://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
9th Facebook Remarketing
Within our online offer, so-called “Facebook pixels” of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are resident in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), are used. Using the Facebook pixel, Facebook is able to determine the visitors of our offer as a target group for the display of ads, so-called “Facebook ads”. Accordingly, we use the Facebook pixel to display the Facebook ads we have placed only to those Facebook users who have shown interest in our website. This means that with the help of the Facebook pixel we want to ensure that our Facebook ads correspond to the potential interest of the users and do not appear annoying. The Facebook pixel also enables us to track the effectiveness of Facebook ads for statistical and market research purposes by seeing if users were directed to our website after clicking on a Facebook ad.
The Facebook pixel is integrated directly by Facebook when our web pages are accessed and can store a so-called cookie, i.e. a small file, on your device. If you then log in to Facebook or visit Facebook when logged in, the visit to our offer is noted in your profile. The data collected about you is anonymous to us and does not give us any information about the identity of the user. However, the data is stored and processed by Facebook so that a connection to the respective user profile is possible. Facebook processes the data in accordance with Facebook’s data usage guidelines. Accordingly, you will receive further information on how the remarketing pixel works and generally on how Facebook ads are displayed in the Facebook Data Usage Policy: https://www.facebook.com/policy.php.
You may opt out of Facebook pixel collection and use of your information to display Facebook ads. To do this, you can go to the page set up by Facebook and follow the instructions on the settings for usage-based advertising: https://www.facebook.com/settings? tab=ads or the objection about the US-American page https://www.aboutads.info/choices/ or the EU page https://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
The following information will inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures and your rights of objection. By subscribing to our newsletter, you declare your agreement with the receipt and the described procedures.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter “newsletter”) only with the consent of the recipient or a legal permission. If the contents of the newsletter are specifically described within the scope of registration, they are decisive for the consent of the user. In addition, our newsletters contain the following information: our products, offers, promotions and our company.
Double-Opt-In and logging: The registration to our newsletter takes place in a so-called Double-Opt-In procedure. I.e. after registration you will receive an e-mail in which you will be asked to confirm your registration. This confirmation is necessary so that nobody can register with external 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 of your data stored with the Versanddienstleister are logged.
Dispatch service provider: The newsletter is sent by “” (hereinafter referred to as “dispatch service provider”). You can view the data protection regulations of the shipping service provider here: “No Newsletter included now”.
The e-mail addresses of our newsletter recipients, as well as their further data described in the context of these notes, are stored on the servers of the dispatch service provider. The shipping service provider uses this information to send and evaluate the newsletter on our behalf. Furthermore, according to its own information, the shipping service provider can use this data to optimise or improve its own services, e.g. for the technical optimisation of the dispatch and the presentation of the newsletter or for economic purposes in order to determine from which countries the recipients come. However, the shipping service provider does not use the data of our newsletter recipients to write to them itself or pass them on to third parties.
Registration data: To subscribe to the newsletter, it is sufficient for you to enter your e-mail address.
Statistical survey and analyses – The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file which is retrieved from the server of the mail-order service when the newsletter is opened. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval are first collected. This information is used for the technical improvement of the services on the basis of the technical data or the target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or the access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our nor the shipping service provider’s intention to monitor individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our contents to them or to send different contents according to the interests of our users.
Cancellation/revocation – You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. At the same time, your consent to its dispatch by the dispatch service provider and the statistical analyses expire. A separate revocation of the shipment by the shipping service provider or the statistical analysis is unfortunately not possible. You will find a link to cancel the newsletter at the end of each newsletter.
11. integration of services and content of third parties
It may happen that content or services of third party providers, such as city maps or fonts from other websites, are integrated within our online offering. The integration of content from third-party providers always requires that the third-party providers perceive the IP address of the users, since they would not be able to send the content to the user’s browser without the IP address. The IP address is therefore required for the presentation of this content. Furthermore, the providers of the third-party content can set their own cookies and process the user data for their own purposes. User profiles can be created from the processed data. We will use these contents as data-savingly and data-avoidably as possible and select reliable third-party providers with regard to data security.
The following presentation provides an overview of third-party providers and their content, together with links to their data protection declarations, which contain further information on the processing of data and, in some cases already mentioned here, possible objections (so-called opt-out):
12. rights of users and deletion of data
Users have the right, upon request and free of charge, to obtain information about the personal data we have stored about them.
In addition, users have the right to have incorrect data corrected, their consent revoked, their personal data blocked or deleted and they have the right to lodge a complaint with the competent supervisory authority in the event that unlawful data processing is assumed.
The data stored by us will be deleted as soon as they are no longer required for their intended purpose and there are no legal obligations to retain them.
13. amendments to the data protection declaration
We reserve the right to change the data protection declaration in order to adapt it to changed legal situations or in the event of changes to the service or data processing. However, this only applies to declarations on data processing. If the user’s consent is required or if elements of the data protection declaration contain provisions governing the contractual relationship with the user, the changes will only be made with the user’s consent.
Users are requested to inform themselves regularly about the content of the data protection declaration.