OUR Privacy Policy

1. INFORMATION ON THE COLLECTION OF PERSONAL DATA AND PROVIDER IDENTIFICATION

(1) Thank you for visiting our website and for your interest in our company and its range of services. The protection of personal data is an important concern for us. All web activities of Winebuddys GmbH und Co. KG are carried out in accordance with the applicable legal provisions on the protection of personal data and data security, in particular the DS-GVO (EU Data Protection Regulation / EU General Data Protection Regulation GDPR). This privacy notice tells you how information collected during your visit to this website is handled. Personal data is all data that can be related to you personally, e.g. name, address, e-mail addresses and user behavior. For the sake of simplicity, both male and female users will be referred to as “users” in the following.

(2) As regards the service provider and responsible party in the sense of data protection law, we refer to the company and contact details in the imprint of our website www.dievision.de.

2. COLLECTION OF PERSONAL DATA FOR INFORMATIONAL USE

(1) Personal data is information that can be used to identify a person, such as name and e-mail address, but also surfing behavior on the Internet. In the case of merely informational use of the website, i.e. if you do not log in to use the website, register or otherwise transmit information to us, we do not collect any personal data, with the exception of the data that your browser transmits to enable you to visit the website (so-called log files, legal basis Art. 6 (1) 1 f) DS-GVO). Log files are technically necessary for us so that the website you called up can be sent to your computer and displayed to you. They are deleted within 7 days after calling up the website. Log files are:

– IP adress

– Date and time of the request

– Time zone difference from Greenwich Mean Time (GMT)

– Content of the request (specific page)

– Access status/HTTP status code

– Amount of data transferred in each case

– Website from which the request comes

– browser

– Operating system and its interface

– Language and version of the browser software.

(2) The log files are also used for statistical evaluations and to improve the website (legal basis Art. 6 (1) 1 f) DS-GVO). In this way, we can, for example, identify possible errors such as faulty links. In connection with your use of the website, among other things, the IP address of the computer you are using is recorded. It may be possible to identify users of the website via the IP address. However, we do not evaluate the IP addresses recorded in accordance with paragraph (1). The evaluation of the IP addresses takes place solely on a statistical basis in anonymized form.

3. USE OF FUNCTIONS OF OUR WEBSITE

(1) In addition to the purely informational use of our website, we offer various services that you can use if you are interested. For this purpose, you will usually have to provide additional personal data, which we use to provide the respective service. If additional voluntary information is possible, it is marked accordingly.

(2) Personal data is only collected if you provide it to us of your own accord when filling out contact forms or sending e-mails, in the context of ordering products or services, making inquiries or requesting material. We then record the information that comes about in the course of contacting you. This includes in particular names and transmitted contact data, date and reason for contact. We will use the personal data collected from you only for the purpose of providing you with the requested products or services (legal basis Art. 6 (1) 1 b) DS-GVO), or for other purposes for which you have given your consent (legal basis Art. 6 (1) 1 a) DS-GVO) and which are described in this privacy policy. Your consent, for example for the setting of cookies by third-party providers or for web tracking by them, can also be given in the appropriate technical settings of your browser.

(3) When contacting us, your information will be stored for the purpose of processing the request and in the event that follow-up questions arise, for the duration of the statutory retention obligations (ten years upon conclusion of the contract, otherwise six years) (legal basis Art. 6 (1) 1 c) DS-GVO) and then deleted in accordance with Section 4 (1) of this Privacy Policy.

4. USE OF OUR FEE-BASED OFFERS, DISCLOSURE OF DATA

(1) If you wish to use our paid offers and order something, it is necessary for the conclusion of the contract that you provide your personal data, which we need for the processing of your order. Mandatory data necessary for the processing of contracts are marked separately, other data are voluntary. We process the data you provide to process your order (legal basis Art. 6 (1) 1 b) DS-GVO). The address, payment and order data will be stored after processing of the contract for the duration of the tax and commercial law retention obligations of ten years (legal basis Art. 6 (1) 1 c) DS-GVO) and then deleted, unless you have consented to a storage beyond this or the further processing of the data for the assertion, exercise or defense of legal claims or a promotional contact (see also No. 5 (1) of this Privacy Policy) is required. We check the latter in each case at the end of the third calendar year beginning with the calendar year following the first storage.

(2) In order to process your order, we may pass on your data to our house bank, as well as to logistics service providers and payment service providers selected by you (legal basis Art. 6 (1) 1 b) DS-GVO). Our service providers may process or use your data only for the purpose for the fulfillment of which they were transmitted to them if necessary. The data is accessible to you at all times. Insofar as data is passed on to external service providers, we have taken technical and organizational measures to ensure that the data protection regulations are observed. We may also pass on personal data for collection purposes (legal basis Art. 6 (1) 1 f) DS-GVO).

(3) If we make advance payments in connection with an order, for example in the case of partial payments or purchase on account, we may have the identity and creditworthiness of customers checked by a service provider, e.g. a credit agency (legal basis Art. 6 (1) 1 f) DS-GVO). Furthermore, we do not exclude the transmission of anonymized usage data for market research purposes.

(4) We would like to point out that we are entitled to provide information about data in individual cases by order of the competent authority, insofar as this is necessary for the purposes of criminal prosecution, to avert danger by the police authorities of the federal states, to fulfill the statutory tasks of the federal and state authorities for the protection of the constitution, the Federal Intelligence Service or the Military Counter-Intelligence Service or to enforce intellectual property rights (legal basis Art. 6 (1) 1 c) DS-GVO).

(5) There is no intention to transfer your data to a third country or an international organization. For the possibility of your data being known by web tracking or social media providers in the USA, please refer to sections 9. to 12. of this data protection declaration.

5. ADVERTISING NOTICE TO OUR CUSTOMERS

After the sale of a product or service, we reserve the right to send you advertising for our agency offers at the e-mail address you have provided. The same applies to the use of your address data for the advertising of our own offers as well as the recommendation advertising for goods and service offers of third parties from this area by letter. The legal basis is Art. 6 (1) 1 f) and ErwG (47) DS-GVO. You have the right to object to advertising at any time (see item 6 (1) of this declaration).

6. RIGHT OF OBJECTION

(1) You may object to the processing of your personal data for advertising purposes (legal basis Art. 6 (1) 1 f) and ErwG (47) DS-GVO) at any time with effect for the future. This also applies to an evaluation of certain characteristics based on this, as in the case of a data analysis. An advertising objection is possible informally; it can be made, for example, via a link in the newsletter or directly to us at the contact details given in the imprint.

(2) In addition, you have the right to object on grounds arising from your particular situation to processing for other purposes based on a balancing of interests (Art. 6 (1) 1 f) DS-GVO). This may be the case if, in particular, the processing is not necessary for the performance of a contract with you. When exercising such an objection, we ask you to explain the reasons why we should not process your personal data as we have done. In the event of your justified objection, we will review the factual situation and either discontinue or adapt the data processing or show you our compelling legitimate grounds on the basis of which we will continue the processing.

7. DATA SECURITY

(1) We take state-of-the-art precautions to protect your data from loss, destruction, falsification, manipulation and unauthorized access. Insofar as your data is collected and recorded by us, it is stored on specially protected servers. These are protected by technical and organizational measures against loss, destruction, access, modification or distribution of your data by unauthorized persons. Access to your data is only possible for a few authorized persons. These are responsible for the technical, commercial or editorial support of the servers. All our employees are bound to confidentiality.

(2) We have commissioned a service provider for the technical operation (hosting) of the website. This service provider carries out the data processing on our behalf. The collection, processing and use of your data by the service provider is carried out exclusively within the framework of our instructions. The statements of this data protection declaration also apply to him in the same way..

8. Cookies

(1) When using the website, cookies are stored on your computer. Cookies are small text files that are stored on your hard drive associated with the browser you are using and through which the entity that sets the cookie (in this case, us) receives certain information. Cookies cannot execute programs or transfer viruses to your computer. They are used to make the Internet offer as a whole more user-friendly and effective. We may use cookies to identify you for subsequent visits if you have an account with us. Otherwise, you would have to log in again for each visit.

(2) This website uses cookies to the following extent:

– Transient cookies (temporary use)

– Persistent cookies (temporary use)

– Third-party cookies (from third-party providers according to separate information).

(3) Transient cookies (legal basis Art. 6 (1) 1 f) DS-GVO) are automatically deleted when you close the browser. These include in particular the session cookies. These store a so-called session ID, with which various requests of your browser can be assigned to the common session. This allows your computer to be recognized when you return to the website. The session cookies are deleted when you close the browser.

(4) Persistent cookies are used exclusively in connection with the web analytics services we use (legal basis Art. 6 (1) 1 f) DS-GVO) and are used only as long as the purpose requires; they have a maximum life of two years. You can delete the cookies from the hard drive of your computer at any time using the privacy functions of your browser. In this case, the functions and user-friendliness of the offer could be restricted.

(5) Cookies that are not technically necessary for the provision of our service are only set with your consent, which you can revoke at any time (legal basis Art. 6 (1) 1 a) DS-GVO). By continuing to use the website with the appropriate browser setting, you consent to the use of cookies within the scope of this privacy policy. You can thus give us your consent by setting your browser, for example, by specifying that you will be informed about the setting of cookies and that their acceptance will only take place if you expressly confirm this. You can also specify in this way that you allow the acceptance of cookies for certain cases or generally. You can configure your browser settings according to your wishes and, for example, control the acceptance or rejection of third-party cookies or all cookies. However, we would like to point out that you may then not be able to use all functions of this website.

Cookie-Einstellungen verwalten

Manage cookie settings

9. Google Analytics

(1) This website uses Google Analytics, a web analytics service provided by Google Inc, 1600 Amphitheater Parkway, Mountainview, California 94043, USA (“Google”). Google Analytics uses cookies, which are text files placed on your computer, to help the website analyze how users use the site (for more information, see section 8 of this privacy policy). The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. In the event that IP anonymization is activated on this website, however, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.

(2) The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google.

(3) The storage of cookies only takes place due to an appropriate setting of your internet access software. You may therefore refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website.

(4) You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) and the processing of this data by Google by downloading and installing the browser plug-in provided by Google at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

(5) This website uses Google Analytics with the extension “_anonymizeIp()”. This means that IP addresses are processed in abbreviated form, which means that personal references can be ruled out. Insofar as the data collected about you has a personal reference, this is therefore immediately excluded and the personal data is deleted immediately.

(6) We use Google Analytics to analyze and regularly improve the use of our website. The statistics obtained enable us to improve our offer and make it more interesting for you as a user. For the exceptional cases in which personal data is transferred to the USA, Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework. The legal basis for the use of Google Analytics is Art. 6 (1) 1 f) DS-GVO.

(7) Third Party Provider Information: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Terms of Use: https://www.google.de/intl/de/policies/terms/regional.html, Data protection overview: http://www.google.com/intl/de/analytics/learn/privacy.html, as well as the privacy policy: https://www.google.de/intl/de/policies/privacy/.

10. WEB TRACKING THROUGH THE USE OF FACEBOOK CUSTOM AUDIENCE VIA PIXEL

(1) Within our website (Italy), we use the “Facebook Custom Audience via Pixel” procedure of Facebook Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA (“Facebook”). With the help of this pixel, the behavior of users can be tracked, even across numerous websites, after they have been redirected to our website by clicking on a Facebook ad. This allows us to record the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, which means that we do not see the personal data of individual users. However, this data is stored and processed by Facebook, about which we inform you according to our level of knowledge. Facebook may associate this data with your Facebook account and also use it for its own advertising purposes, in particular those based on profiling, in accordance with the Facebook Data Policy https://www.facebook.com/about/privacy/. You have the option to prohibit Facebook as well as their partners from placing advertisements. You can edit the settings for Facebook ads at the following link: https://www.facebook.com/ads/website_custom_audiences/.

(2) The third party provider is registered under the EU-US Privacy Shield data transfer agreement: https://www.privacyshield.gov/list. The legal basis for the use of the procedure is Art. 6 (1) 1 f) DS-GVO.

11. WEB TRACKING THROUGH THE USE OF TWITTER CONVERSION TRACKING FOR WEBSITES VIA WEBSITE TAG

(1) Within our website, we use the “Conversion Tracking for Websites via Website Tag” procedure of Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, California 94103, USA (“Twitter”). With the help of this website tag (i.e. pixels) placed on our pages, the behavior of users can be tracked, even across numerous websites, after they have seen or clicked on a Twitter advertisement. This allows us to record the effectiveness of the Twitter ads for statistical and market research purposes. The data collected in this way is anonymous to us, so we cannot draw any conclusions about the identity of individual users. However, this data is stored and processed by Twitter, about which we inform you according to our state of knowledge. By using Twitter and the “Re-Tweet” function, Twitter can link this data, such as the websites you visit, to your Twitter account, disclose it to other users and also use it for its own advertising purposes in accordance with Twitter’s privacy policy (https://twitter.com/de/privacy). Twitter as well as its advertising partners can thus serve profiling-based advertisements on and off Twitter. You have the option to change your privacy settings and consents in your Twitter account at http://twitter.com/account/settings.

(2) The third-party provider is registered under the EU-US Privacy Shield data transfer agreement: https://www.privacyshield.gov/list. The legal basis for the use of the procedure is Art. 6 (1) 1 f) DS-GVO.

12. USE OF SOCIAL MEDIA PLUG-INS

(1) We currently use the following social media plug-ins: Facebook, Instagram, Twitter, LinkedIn and Xing. We use the so-called two-click solution. This means that when you visit our site, no personal data is initially passed on to the providers of the plug-ins. You can recognize the provider of the plug-in by the mark on the box above its initial letter or logo. We open up the possibility for you to communicate directly with the provider of the plug-in via the button. Only if you click on the marked box and thereby activate it, the plug-in provider receives the information that you have called up the corresponding website of our online offer. In addition, the log files mentioned under item 2 (1) of this declaration are transmitted. In the case of Facebook and XING, according to the provider in Germany, the IP address is anonymized immediately after collection. By activating the plug-in, personal data is therefore transmitted from you to the respective plug-in provider and stored there (in the case of US providers in the USA). Since the plug-in provider collects the data in particular via cookies, we recommend that you delete all cookies via your browser’s security settings before clicking on the grayed-out box.

(2) We have no influence on the collected data and data processing operations, nor are we aware of the full scope of data collection, the purposes of processing, the storage periods. We also have no information on the deletion of the collected data by the plug-in provider.

(3) The plug-in provider stores the data collected about you as usage profiles and uses them for purposes of advertising, market research and/or demand-oriented design of its website. Such an evaluation is carried out in particular (also for users who are not logged in) for the display of needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact the respective plug-in provider to exercise this right. Via the plug-ins, we offer you the opportunity to interact with the social networks and other users, so that we can improve our offer and make it more interesting for you as a user. The legal basis for the use of the plug-ins is Art. 6 (1) 1 f) DS-GVO.

(4) The data transfer takes place regardless of whether you have an account with the plug-in provider and are logged in there. If you are logged in to the plug-in provider, your data collected from us will be directly assigned to your account with the plug-in provider. If you click the activated button and link to the page, for example, the plug-in provider also saves this information in your user account and shares it publicly with your contacts. We recommend that you log out regularly after using a social network, but especially before activating the button, as this allows you to avoid an assignment to your profile with the plug-in provider.

(5) For further information on the purpose and scope of data collection and processing by the plug-in provider, please refer to the data protection declarations of these providers provided below. There you will also receive further information on your rights in this regard and setting options for protecting your privacy.

(6) Addresses of the respective providers and URL with their privacy notices:

a) Facebook Inc, 1601 S California Ave, Palo Alto, California 94304, USA; http://www.facebook.com/policy.php; further information on data collection: http://www.facebook.com/help/186325668085084, http://www.facebook.com/about/privacy/your-info-on-other applications and http://www.facebook.com/about/privacy/your-info everyoneinfo. Facebook has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

b) Instagram, operator: Facebook Inc, 1601 S. California Ave, Palo Alto, California 94304, USA; http://instagram.com/about/legal/privacy. Facebook has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

(c) Twitter Inc, 1355 Market Street, Suite 900, San Francisco, California 94103, USA; https://twitter.com/privacy. Twitter has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

d) LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; http://www.linkedin.com/legal/privacy-policy.

e) Xing AG, Gänsemarkt 43, 20354 Hamburg, DE; http://www.xing.com/privacy.

13. EXTERNAL LINKS

This privacy statement applies solely to this website. For your optimal information, you will find links on our pages that refer to pages of third parties. Insofar as this is not obviously recognizable, we point out that it is an external link. This privacy policy does not extend to these other providers. When you leave this website, it is recommended that you first carefully read the privacy policy of each website.

14. FURTHER INFORMATION ACCORDING TO ART. 13 DS-GVO

(1) The responsible party for the processing of your personal data is Dievision Agentur für Kommunikation GmbH, Robert-Koch-Platz 10, 30173 Hannover. For further contact details, please refer to the imprint of our website www.dievision.de.

(2) You can request information from us regarding the personal data concerning you and have the right to correct incorrect data, to restrict processing and a right to deletion, insofar as this does not conflict with a retention obligation. There is no right to erasure if further processing is necessary for the assertion, exercise or defense of legal claims, such as compliance with an advertising objection. With regard to the personal data concerning you that you have provided to us, for example in an input mask or a contact form, on the basis of consent or for the performance of a contract existing between us, you have a right to data portability in a structured, common and machine-readable format.

(3) You have the right to lodge a complaint with a data protection supervisory authority, for example with the State Commissioner for Data Protection of Lower Saxony, Prinzenstraße 5, 30159 Hannover, Germany, poststelle@lfd.niedersachsen.de, which is responsible for us.

(4) Insofar as the processing of your data is based on consent (legal basis Art. 6 (1) 1 a) DS-GVO), you have the right to revoke the consent at any time without affecting the lawfulness of the processing carried out on the basis of the consent until revocation. Legal permissions remain unaffected by a revocation of consent.

(5) We have appointed a data protection officer. He can be reached under our contact details.

14. CHANGES TO THE PRIVACY POLICY

We will update this statement as necessary to adapt it to changes in the content of the website and to legal changes in general.

Status: April 2018