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Privacy policy

Introduction

With the following privacy policy, 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, mobile devices, and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).

The terms used are not gender-specific.

Status: 15.10.2025

Table of contents

Responsible party

heinrichs weikamp gmbh
Managing Director: Matthias Heinrichs
Adlerstr. 7
79098 Freiburg
Germany

E-mail address: info@hwdiving.com

Overview of processing operations

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

Types of data processed

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

Purposes of processing

  • Assessment of creditworthiness.
  • Provision of our online offer and user-friendliness.
  • Visit action evaluation.
  • Office and organizational procedures.
  • Cross-device tracking (cross-device processing of user data for marketing purposes).
  • Direct marketing (e.g. by e-mail or post).
  • Interest-based and behavioral marketing.
  • Contact requests and communication.
  • Conversion measurement (measuring the effectiveness of marketing measures).
  • Profiling (creation of user profiles).
  • Remarketing.
  • Reach measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures.
  • Tracking (e.g. interest-/behavior-related profiling, use of cookies).
  • Provision of contractual services and customer service.
  • Administration and answering of inquiries.
  • Target group formation (determination of target groups relevant for marketing purposes or other output of content).

Automated individual decisions

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

Relevant legal bases

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

  • Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR) – The data subject has given their consent to the processing of personal data relating to them for a specific purpose or several specific purposes.
  • Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR) – Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.

Security measures

In accordance with legal requirements, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access relating to it, input, disclosure, ensuring availability and its separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and reactions to data threats. Furthermore, we already consider the protection of personal data during the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

SSL encryption (https): We use SSL encryption to protect your data transmitted via our online offer. You can recognize connections encrypted in this way by the prefix https:// in the address bar of your browser.

Transmission and disclosure of personal data

As part of our processing of personal data, it may happen that the data is transmitted to other bodies, companies, legally independent organizational units or persons or disclosed to them. The recipients of this data may include, for example, payment institutions as part of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we observe the legal requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect 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 the disclosure or transfer of data to other persons, bodies or companies, this only takes place in accordance with the legal requirements.

Subject to express consent or transfer required by contract or law, we only process or have the data processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

As part of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection as secure for certain companies from the USA as part of the adequacy decision of 10.07.2023. The list of certified companies as well as further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). We will inform you in the data protection information which of our service providers are certified under the Data Privacy Framework.

Use of cookies

Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. E.g. 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 the functionality, security and convenience of online offers as well as for the creation of analyses of visitor flows.

Notes on consent: We use cookies in accordance with the legal requirements. Therefore, we obtain prior consent from users, unless this is not required by law. In particular, consent is not necessary if the storage and reading of information, including cookies, is absolutely necessary to provide users with a telemedia service (i.e. our online offer) expressly requested by them. The revocable consent is clearly communicated to the users and contains the information on the respective cookie usage.

Notes on data protection legal bases: Which data protection legal basis we use to process the personal data of users with the help of cookies depends on whether we ask users for consent. If the users consent, the legal basis for processing their data is the declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in an economic operation of our online offer and improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations. We will clarify for what purposes the cookies are processed by us in the course of this privacy policy or in the context of our consent and processing processes.

Storage period: With regard to the storage period, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user leaves an online offer and closes their end device (e.g. browser or mobile application).
  • 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, the data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information on the type and storage period of cookies (e.g. as part of obtaining consent), users should assume that cookies are permanent and the storage period can be up to two years.

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

Commercial and business services

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

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

We inform the contractual partners which data is required for the aforementioned purposes before or in the context of the data collection, e.g. in online forms, by means of special labeling (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. generally after the expiry of 4 years, unless the data is stored in a customer account, e.g. as long as it must be kept for archiving for legal reasons (e.g. for tax purposes, usually 10 years). If a period does not expressly begin on a specific date and is at least one year, it automatically starts at the end of the calendar year in which the event triggering the period occurred. In the case of ongoing contractual relationships in which data is stored, the event triggering the period is the point in time at which the termination or other termination of the legal relationship becomes effective. We delete data that has been disclosed to us by the contractual partner as part of an order in accordance with the specifications of the order, generally after the end of the order.

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

Shop and e-commerce: We process the data of our customers in order 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 marked as such in the context of the order or comparable purchase process and includes the information required for delivery or provision and billing as well as contact information in order to be able to hold any consultation.

  • Processed data types: 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 the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Interested parties, business and contractual partners, customers.
  • Purposes of processing: Provision of contractual services and customer service, contact requests and communication, office and organizational procedures, administration and answering of inquiries, security measures, visit action evaluation, interest-based and behavioral marketing, profiling (creation of user profiles).
  • Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legal obligation (Art. 6 para. 1 sentence 1 lit. c. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Payment service providers

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

The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. This information is required to carry out the transactions. However, the data entered is only processed and stored by the payment service providers. This means that we do not receive any account or credit card-related information, but only information confirming or negatively acknowledging the payment. Under certain circumstances, the data may be transmitted by the payment service providers to credit agencies. This transmission is for the purpose of identity and credit checks. In this regard, we refer to the terms and conditions and the data protection notices of the payment service providers.

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

  • Processed data types: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of the contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Customers, prospective customers.
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services and service providers used:

Provision of the online offer and web hosting

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

The data processed in connection with the provision of the hosting offer may include all information relating to users of our online offer that is generated in the context of use and communication. This regularly includes the IP address, which is necessary to deliver the content of online offers to browsers, and all entries made within our online offer or from websites.

E-mail sending and hosting: The web hosting services we use also include the sending, receiving and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the e-mail dispatch (e.g. the providers involved) as well as the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of detecting SPAM. Please note that e-mails are generally not sent in encrypted form on the Internet. As a rule, e-mails are encrypted during transport, but not on the servers from which they are sent and received (unless a so-called end-to-end encryption method is used). We can therefore not assume any responsibility for the transmission path of e-mails between the sender and the recipient on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files may include the address and name of the accessed web pages and files, date and time of access, transferred data volume, 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 can be used on the one hand for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the utilization of the servers and their stability.

  • Processed data types: 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).
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Contacting us

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

The answering of contact requests in the context of contractual or pre-contractual relationships takes place to fulfill our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interests in answering the inquiries.

  • Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Communication partners, prospective customers.
  • Purposes of processing: Contact requests and communication, administration and answering of inquiries.
  • Legal bases: Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services and service providers used:

  • None

Web analysis, monitoring and optimization

Web analysis (also referred to as “reach measurement”) serves to evaluate the visitor flows of our online offer and can include behavior, interests or demographic information on the 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 to reuse. We can also understand which areas need optimization.

In addition to web analysis, we can also use testing methods to test and optimize, for example, different versions of our online offer or its components.

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

The IP addresses of the users are also collected. However, we use an IP masking procedure (i.e. pseudonymization by shortening the IP address) to protect the users. In general, no clear data of the users (such as e-mail addresses or names) are stored within the scope of web analysis, A/B testing and optimization, but pseudonyms. This means that neither we nor the providers of the software used know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, the data of users is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Processed data types: 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: Reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest-/behavior-related profiling, use of cookies), visit action evaluation, profiling (creation of user profiles).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services and service providers used:

  • None

Presences in social networks (social media)

We maintain online presences within social networks and process data of users in this context in order to communicate with the users active there or to offer information about us.

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

Furthermore, the data of users within social networks are generally processed for market research and advertising purposes. For example, user profiles can be created on the basis of the usage behavior and the resulting interests of users. The user profiles can in turn be used to, for example, place advertisements within and outside the networks that are likely to correspond to the interests of the users. For these purposes, cookies are generally stored on the computers of the users, in which the usage behavior and the interests of the users are stored. Furthermore, data independent of the devices used by the users can also be stored in the user profiles (in particular, 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 possibilities of objection (opt-out), we refer to the data protection declarations and information of the operators of the respective networks.

Also in the case of requests for information and the assertion of data subject rights, we would like to point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. Should you nevertheless need help, you can contact us.

  • Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Data subjects: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Contact requests and communication, tracking (e.g. interest-/behavior-related profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).

Services and service providers used:

  • Instagram: Social network, enables the sharing of photos and videos, commenting and favoriting posts, sending messages, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/; Basis for third country transfers: Data Privacy Framework (DPF).
  • Facebook pages: Profiles within the social network Facebook – We are jointly responsible with Meta Platforms Ireland Limited for the collection (but not the further processing) of data from visitors to our Facebook page (so-called “fan page”). This data includes information about the types of content that users view or interact with, or the actions they take (see “Things you and others do and provide” in the Facebook Data Policy: https://www.facebook.com/privacy/policy/), as well as information about the devices used by users (e.g. IP addresses, operating system, browser type, language settings, cookie data; see “Device Information” in the Facebook Data Policy: https://www.facebook.com/privacy/policy/). As explained in the Facebook Data Policy under “How do we use this information?”, Facebook also collects and uses information to provide analytics services, so-called “Page Insights”, for page operators so that they can gain insights into how people interact with their pages and the content associated with them. We have entered into a special agreement with Facebook (“Information about Page Insights”, https://www.facebook.com/legal/terms/page_controller_addendum), which in particular regulates which security measures Facebook must observe and in which Facebook has agreed to fulfill the rights of data subjects (i.e. users can, for example, address requests for information or deletion 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 about Page Insights” (https://www.facebook.com/legal/terms/information_about_page_insights_data). The joint responsibility is limited to the collection by and transmission of data to Meta Platforms Ireland Limited, a company based in the EU. The further processing of the data is the sole responsibility of Meta Platforms Ireland Limited, which in particular concerns the transmission of the data to the parent company Meta Platforms, Inc. in the USA; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/; Basis for third country transfers: Data Privacy Framework (DPF).

Plugins and embedded functions and content

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

The integration always presupposes that the third-party providers of this content process the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content or functions. We endeavor 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 evaluate 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 the operating system, referring websites, the time of the visit and other information on the use of our online offer as well as be linked to such information from other sources.

Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, the data of users is processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (e.g., visited websites, interest in content, access times), Meta/communication data (e.g., device information, IP addresses), Location data (information on the geographical position of a device or person), Content data (e.g., entries in online forms), Inventory data (e.g., names, addresses), Contact data (e.g., email, phone numbers).
  • Data subjects: Users (e.g., website visitors, users of online services), communication partners.
  • Purposes of processing: Provision of our online offering and user-friendliness, provision of contractual services and customer service, contact inquiries and communication, tracking (e.g., interest/behavior-based profiling, use of cookies), interest-based and behavioral marketing, profiling (creation of user profiles), security measures, management and response to inquiries.
  • Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR), Consent (Art. 6 para. 1 sentence 1 lit. a GDPR), Performance of contract and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR).

Services used and service providers:

  • Google Fonts (retrieval from Google Server): Retrieval of fonts (and symbols) for the purpose of technically secure, maintenance-free, and efficient use of fonts and symbols with regard to up-to-dateness and loading times, their uniform display, and consideration of possible licensing restrictions. The user’s IP address is communicated to the font provider so that the fonts can be made available in the user’s browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted, which are necessary for the provision of the fonts depending on the devices used and the technical environment. This data can be processed on a server of the font provider in the USA – When visiting our online offering, users’ browsers send their browser HTTP requests to the Google Fonts Web API (i.e., a software interface for retrieving fonts). The Google Fonts Web API provides users with Google Fonts’ Cascading Style Sheets (CSS) and then the fonts specified in the CSS. These HTTP requests include (1) the IP address used by the respective user to access the internet, (2) the requested URL on the Google server, and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of the website visitors, as well as the referrer URL (i.e., the website where the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and are not analyzed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent, and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wants to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must adapt the font generated for the respective browser type. The user agent is primarily logged for debugging and used to generate aggregated usage statistics that measure the popularity of font families. These aggregated usage statistics are published on the “Analytics” page of Google Fonts. Finally, the referrer URL is logged so that the data can be used for production maintenance and an aggregated report on top integrations based on the number of font requests can be generated. According to its own statements, Google does not use any information collected by Google Fonts to create profiles of end-users or to display targeted advertisements; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR); Website: https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; Basis for third-country transfers: Data Privacy Framework (DPF); Further information: https://developers.google.com/fonts/faq/privacy?hl=de.

Deletion of Data

The data processed by us will be deleted in accordance with legal requirements as soon as the consents granted for their processing are revoked or other permissions cease to apply (e.g., if the purpose of processing this data has ceased or they are no longer required for the purpose).

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

Further information on the deletion of personal data may also be provided within the individual privacy notices of this privacy policy.

Amendment and Update of the Privacy Policy

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

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that the addresses may change over time, and we ask you to check the information before contacting them.

Rights of Data Subjects

As data subjects, you have various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:

  • Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for the purpose of such marketing; this also applies to profiling to the extent that it is related to such direct marketing.
  • Right to withdraw consent: You have the right to withdraw granted consents at any time.
  • Right of access: You have the right to request confirmation as to whether data concerning you are being processed and to access information about these data, as well as further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: In accordance with legal requirements, you have the right to demand the completion of data concerning you or the rectification of inaccurate data concerning you.
  • Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to demand that data concerning you be erased without undue delay, or alternatively, in accordance with legal requirements, to demand the restriction of the processing of the data.
  • Right to data portability: In accordance with legal requirements, you have the right to receive data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format or to demand their transmission to another controller.
  • Right to lodge a complaint with a supervisory authority: Furthermore, in accordance with legal requirements, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work, or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Definitions

In this section, you will find an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are primarily defined in Art. 4 GDPR. The legal definitions are binding. The following explanations, however, are primarily intended to aid understanding. The terms are sorted alphabetically.

  • Visit Action Evaluation: “Visit Action Evaluation” (English “Conversion Tracking”) refers to a process by which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users’ devices within the websites where the marketing measures take place and then retrieved again on the target website. For example, we can thus track whether the advertisements we placed on other websites were successful).
  • Creditworthiness Information: Automated decisions are based on automatic data processing without human intervention (e.g., in the case of an automatic rejection of a purchase on account, an online loan application, or an online application process without any human intervention. Such automated decisions are only permissible under Art. 22 GDPR if data subjects consent, if they are necessary for the performance of a contract, or if national laws permit these decisions.
  • Cross-Device Tracking: Cross-device tracking is a form of tracking in which users’ behavioral and interest information is collected across devices in so-called profiles by assigning an online identifier to users. This allows user information to be analyzed, usually for marketing purposes, regardless of the browsers or devices used (e.g., mobile phones or desktop computers). The online identifier is not linked to clear data, such as names, postal addresses, or email addresses, by most providers.
  • IP Masking: “IP masking” refers to a method in which the last octet, i.e., the last two numbers of an IP address, is deleted so that the IP address can no longer serve to uniquely identify a person. Therefore, IP masking is a means of pseudonymization of processing procedures, especially in online marketing.
  • Interest-based and Behavioral Marketing: Interest-based and/or behavioral marketing refers to the process where potential interests of users in advertisements and other content are determined as precisely as possible. This is done based on information about their past behavior (e.g., visiting certain websites and staying on them, purchasing behavior, or interaction with other users), which is stored in a so-called profile. For these purposes, cookies are usually used.
  • Conversion Measurement: Conversion measurement is a process by which the effectiveness of marketing measures can be determined. For this purpose, a cookie is usually stored on the users’ devices within the websites where the marketing measures take place and then retrieved again on the target website. For example, we can thus track whether the advertisements we placed on other websites were successful.
  • Personal Data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Profiling: “Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person (depending on the type of profiling, this includes information concerning age, gender, location data and movement data, interaction with websites and their content, purchasing behavior, social interactions with other people) to analyze, assess or predict them (e.g., interests in certain content or products, click behavior on a website, or location). For profiling purposes, cookies and web beacons are frequently used.
  • Reach Measurement: Reach measurement (also referred to as Web Analytics) serves to evaluate the visitor flows of an online offering and can include the behavior or interests of visitors in certain information, such as website content. With the help of reach analysis, website owners can, for example, recognize at what time visitors visit their website and what content they are interested in. This allows them, for example, to better adapt the website content to the needs of their visitors. For the purpose of reach analysis, pseudonymous cookies and web beacons are often used to recognize returning visitors and thus obtain more accurate analyses of the use of an online offering.
  • Remarketing: “Remarketing” or “Retargeting” refers to when, for example, for advertising purposes, it is noted which products a user has shown interest in on a website, in order to remind the user of these products on other websites, e.g., in advertisements.
  • Location Data: Location data is generated when a mobile device (or another device with the technical prerequisites for location determination) connects to a radio cell, Wi-Fi, or similar technical intermediaries and location determination functions. Location data serves to indicate the geographically determinable position on Earth where the respective device is located. Location data can, for example, be used to display map functions or other location-dependent information.
  • Tracking: “Tracking” refers to when user behavior can be traced across multiple online offerings. As a rule, behavioral and interest information regarding the online offerings used is stored in cookies or on the servers of the providers of tracking technologies (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
  • Controller: A “controller” means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and practically covers any handling of data, be it collection, evaluation, storage, transmission, or deletion.
  • Audience Formation: Audience formation (or “Custom Audiences”) refers to when target groups are determined for advertising purposes, e.g., displaying advertisements. For example, based on a user’s interest in certain products or topics on the internet, it can be concluded that this user is interested in advertisements for similar products or the online shop where they viewed the products. “Lookalike Audiences” (or similar target groups) refers to when content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. For the purpose of forming Custom Audiences and Lookalike Audiences, cookies and web beacons are usually used.