Data protection: EU-GDPR compliant handwritten CRM campaigns

The protection of personal data and data privacy are very important issues for PENSAKI. For this reason, too, we rely exclusively on handwriting by robots, as this greatly limits the group of people with access to personal data. We have adjusted all processes accordingly and made them GDPR-compliant.

The data processing contract (dpa) is a central component of the General Data Protection Regulation (“GDPR”). This contract regulates the cooperation between the client and the processor when processing personal data. The contract defines the duties and responsibilities of both parties to ensure that the data is protected in accordance with the requirements of the GDPR.

In this case, the processor (i.e. PENSAKI) is obliged to process the data only within the framework of the client’s instructions and to take the necessary technical and organizational measures to protect the data. You conclude the Data Processing Agreement (DPA) with PENSAKI directly online as part of your order. In your customer area, you can view and download the DPA at any time.

With PENSAKI, you can also delete all personal data from your order after shipping. The order history is retained, only the salutations and addresses are removed. To do this, simply click on “Anonymization”. The process is also confirmed by e-mail. Privacy Policy

Disclaimer: This text is a convenience translation of our German Privacy-policy. In case of any discrepancies, the German version of our Privacy policy (Datenschutzerklärung) is relevant, i.e. only the German version is the controlling version and shall be the only relevant version when a provision is to be interpreted. Our online privacy policy is to respect and protect the privacy of our users. We want our Internet users to be comfortable using our services at all time. This policy statement tells you how we collect information from you and how we use it. The following policy applies to online activities on the website.

1. Scope

This data protection declaration is intended to inform you as a user of about the type, scope and purposes of the collection and use of personal data by Pensaki GmbH, Reilsheimer Straße 15, 69245 Bammental (hereinafter referred to as “Pensaki”). This data protection declaration explains to you the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the associated websites, functions and contents as well as external online presences, e.g. our social media profile. (hereinafter jointly referred to as “online offer”). With regard to the terms used, such as “personal data” or their “processing”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Our details:
Company: Pensaki GmbH
Street Reilsheimer Straße 15
Zipt City: 69245 Bammental, Deutschland
Company registration: HRB 720335 , AG Mannheim
Managing Director: Antonio Brissa
Phone: +496223805005
E-Mail: privacy (sa)

2. How we use personal data

Pensaki collects and uses personal data only to the extent necessary for the use and billing of They are only used for other purposes if this is permitted by the provisions of the Telemedia Act or by another applicable legal provision or if the user has consented. User is any natural person using

Personal data are individual details about personal and factual circumstances. With regard to personal data, a distinction is made between inventory data and usage data.

  • Inventory data are data that are collected and used for the creation, content design or amendment of the user contract between Pensaki and the user (e.g. first and last name when registering for The inventory data includes the logon data and the invoice data.
  • Usage data is data that enables the use of and the billing of usage.

Types of data processed:

 Inventory data (e.g., names, addresses)
 Contact details (e.g., e-mail, phone numbers)
 Content data (e.g., text input, text templates, drafts)
 Contract data (e.g., subject matter of the contract, duration, customer category)
 Payment data (e.g., bank details, payment history)
 Usage data (e.g., visited websites, interest in content, access times)
 Meta/communication data (e.g., device information, IP addresses).

Processing of special categories of personal data (Art. 9 GDPR)

 No special categories of data are processed.

Categories of data subjects:

 Visitors and users of the online offer.

In the following, we will also summarise the persons concerned as “users”.

Purpose of data processing

 Provision of the online offer, its contents and functions.
 Provision of contractual services, service and customer care.
 Answering of contact inquiries and communication with users.
 Marketing, advertising and market research.
 Security measures.

inventory data

When registering with, the following personal data is collected:

Credentials: E-mail address and password.
Invoice data: Company name, name and postal address, VAT number.

The e-mail address is used for correspondence between Pensaki and the customer in connection with the execution of the user agreement, as well as for sending information on other offers from Pensaki. The user can object to the latter at any time. The objection is to be addressed to the contact option mentioned below.

The user name for the customer account consists of the user’s e-mail address. Pensaki will send the user an e-mail with the activation link for his customer account in case of successful registration for the creation of a customer account. The user follows the activation link and sets a password according to the requirements to activate his customer account. The user should treat the password confidentially and change his password from time to time for security reasons. To do this, click on “Change password” in the “My account” area. The change can then be made in the form that opens.

During login, user name and password are transmitted https-encrypted. Pensaki stores the password in encrypted form so that it cannot be read even by Pensaki employees. No Pensaki employee will ask the user to disclose the password. If the user still receives such a request, it is probably a phishing attack. In such a case Pensaki asks to be notified.

usage data

Every time a page is called up, the user’s access data required to use this service and to bill for its use are stored on the Pensaki server in a log file (log file). The following data is stored: IP address of the computer requesting the page; the website from which the user may have accessed the requested page; date and time of the page request; file accessed; amount of files transmitted; product and version information of the browser used by the user.

The log file is stored for the following purposes: Checking for use contrary to contract or otherwise illegal, if there are actual indications for this; optimisation of Pensaki’s offer; technical protective measures (recognition, limitation or elimination of faults or errors on the websites).

Bammental May 1st  2018

1. authoritative legal bases

In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consents is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing for the performance of our services and performance of contractual measures as well as for answering inquiries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing to fulfil our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR. In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) GDPR serves as the legal basis.

2 Changes and Updates to the Privacy Policy

We ask you to inform yourself regularly about the contents of our data protection declaration. We will adapt the data protection declaration 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 your cooperation (e.g. consent) or other individual notification.

3. security measures

We shall take appropriate technical and organizational1 measures to ensure a level of protection appropriate to the risk, in accordance with Article 32 GDPR, taking into account the state of the art, implementation costs and the nature, scope, circumstances and purposes of processing and the different likelihood and severity of the risk to the rights and freedoms of natural persons; the measures shall include in particular safeguarding the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as the access, input, transmission, security of availability and its separation. Furthermore, we have established procedures that guarantee the exercise of data subject rights, deletion of data and reaction to data risks. 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 data protection-friendly settings (Art. 25 GDPR). The security measures include in particular the encrypted transmission of data between your browser and our server.

4. cooperation with contract processors and third parties

4.1 If we disclose data to other persons and companies (contract processors or third parties) within the scope of our processing, transmit it to them or otherwise grant them access to the data, this shall only take place on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as payment service providers, pursuant to Art. 6 para. 1 lit. b GDPR is required for contract fulfilment), if you have consented, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

4.2 If we commission third parties with the processing of data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 GDPR.

5. transfers to third countries (NO-EU)

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this only takes place if it occurs for the fulfilment of our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or leave the data in a third country only if the special requirements of Art. 44 ff. Process GDPR. This means, for example, the processing is carried out on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to the EU (e.g. for the USA by the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).

6. rights of data subjects

6.1 You have the right to request confirmation as to whether the data concerned are being processed and to request information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.
6.2 You have accordingly. In accordance with Art. 16 GDPR, you have the right to request the completion of the data concerning you or the correction of inaccurate data concerning you.
6.3 In accordance with Art. 17 GDPR, you have the right to demand that relevant data be deleted immediately or, alternatively, to demand a restriction of the processing of the data in accordance with Art. 18 GDPR.
6.4 You have the right to request that the data concerning you which you have provided to us be received in accordance with Art. 20 GDPR and to request its transmission to other persons responsible.
6.5 In accordance with Art. 77 GDPR, you also have the right to file a complaint with the competent supervisory authority.

7. right of revocation

You have the right to revoke granted consents according to Art. 7 para. 3 GDPR with effect for the future.

8. Right of objection

You can object to the future processing of the data concerning you in accordance with Art. 21 GDPR at any time. The objection may be lodged in particular against processing for direct marketing purposes.

9 Cookies and right of objection in direct mail

We use temporary and permanent cookies, i.e. small files that are stored on the user’s devices (explanation of the term and function, see last section of this data protection declaration). In part, cookies serve security purposes or are required for the operation of our online offer (e.g., for the presentation of the website) or to save the user’s decision when confirming the cookie banner. In addition, we or our technology partners use cookies to measure reach and for marketing purposes, about which the users will be informed in the course of the data protection declaration.

A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US site or the EU site << Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that in this case not all functions of this online offer can be used.

10. deletion of data

10.1 The data processed by us will be deleted or its processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory storage obligations. If the data are not deleted because they are necessary for other and legally permissible purposes, their processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons. Pensaki will keep your personal data for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.  Every user has the possibility to delete the personal data of his mailings at any time. < You can delete your customer account and all personal data stored there at any time by activating the option “Delete user account” in the user account.

10.2 In accordance with statutory requirements, the records shall be kept in particular for 6 years in accordance with § 257 (1) HGB (trading books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting documents, etc.) and for 10 years in accordance with § 147 (1) AO (books, records, management reports, accounting documents, commercial and business letters, documents relevant to taxation, etc.).

11. performance of contractual services

11.1 We process inventory data (e.g., names and addresses as well as contact data of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services pursuant to Art. 6 para. 1 lit b. GDPR. The entries marked as obligatory in online forms are required for the conclusion of the contract.

11.2 To use, all users must create a user account where they can view their designs, text templates and orders. During the registration process, the required information will be communicated to the users. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to their retention is necessary for commercial or tax reasons according to Art. 6 para. 1 lit. c GDPR. It is up to the users to save their data before the end of the contract if they have given notice of termination. We are entitled to irretrievably delete all user data stored during the term of the contract.

11.3 When registering and re-registering and using our online services, we store the IP address and the time of the respective user action. The data is stored on the basis of our legitimate interests as well as the user’s protection against misuse and other unauthorized use. A passing on of this data to third parties does not take place in principle, unless it is necessary for the pursuit of our claims or there is a legal obligation according to Art. 6 Abs. 1 lit. c GDPR.

11.4 We process usage data (e.g., the visited websites of our online offer, interest in our products) and content data (e.g., entries in the contact form or user profile) for advertising purposes in a user profile in order to show the user e.g. product information based on their previously used services.

11.5 Deletion takes place after the expiry of statutory warranty and comparable obligations, the necessity of data storage is checked every three years; in the case of statutory archiving obligations, deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) storage obligation); details in the customer account remain until they are deleted.

12. establishment of contact

12.1 When contacting us (via contact form or e-mail), the user’s details are processed for processing the contact enquiry and its handling in accordance with Art. 6 Para. 1 lit. b) GDPR.

12.2 User information can be stored in our Customer Relationship Management System (“CRM System”) or similar request organization.

12.3 We use the CRM system “Zoho CRM” from Zoho Corporation (4141 Hacienda Drive, Pleasanton, CA 94588, USA) based on our legitimate interests (efficient and fast processing of user requests). For this purpose, we have concluded a contract with Zoho CRM with so-called standard contract clauses in which Zoho CRM undertakes to process user data only in accordance with our instructions and to comply with the EU data protection level. Zoho CRM is also certified under the Privacy Shield Agreement and thus offers an additional guarantee to comply with European data protection law (

12.4 We delete the requests if they are no longer required. We review the requirement every two years; requests from customers who have a customer account are stored permanently and are linked to the customer account details for deletion. In the case of statutory archiving obligations, the deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) storage obligation).

13. comments and contributions

13.1 If users leave comments or other contributions, their IP addresses will be used on the basis of our legitimate interests within the meaning of Art. 6 para. 1 letter f. GDPR for 7 days.

13.2 This is for our safety if someone leaves illegal contents in comments and contributions (insults, forbidden political propaganda, etc.). In this case, we can be prosecuted for the comment or contribution and are therefore interested in the identity of the author.

14. collection of access data and log files

14.1 On the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR data about each access to the server on which this service is located (so-called server log files). Access data includes the name of the accessed website, file, 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), IP address and the requesting provider.

14.2 Log file information is stored for a maximum of seven days and then deleted for security reasons (e.g. to investigate misuse or fraud). Data whose further storage is required for evidentiary purposes are excluded from deletion until the respective incident has been finally clarified.

15. online presence in social media

15.1 We maintain online presence within social networks and platforms in order to communicate with active customers, interested parties and users and to inform them about our services there. When accessing the respective networks and platforms, the terms and conditions and the data processing guidelines of their respective operators apply.

15.2 Unless otherwise stated in our privacy policy, we will process the data of users who communicate with us within social networks and platforms, e.g. post on our websites or send us messages.

16. cookies & range measurement

16.1 Cookies are information that is transferred from our web server or third-party web servers to the user’s web browser and stored there for later retrieval. Cookies can be small files or other types of information storage.

16.2 We use “session cookies”, which are only stored on our website for the duration of the current visit (e.g. to enable the storage of your login status or the shopping basket function and thus the use of our online offer at all). A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. A cookie also contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using our online offer and log out or close your browser, for example.

16.3 Users are informed about the use of cookies in the context of pseudonymous range measurement in this data protection declaration.

16.4 If users do not want 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. However, the exclusion of cookies can lead to functional restrictions of this online offer.

16.5 You can disable the use of cookies for range measurement and advertising purposes from the opt-out page of the network advertising initiative (< and additionally the US-American website (< or the European website (<

17. Google Analytics

17.1 We make no representations or warranties as to the accuracy, completeness or timeliness of the information provided on this website based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online services within the meaning of Art. 6 para. 1 lit. f. GDPR) Google Analytics, a web analysis service of Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by users is generally transferred to a Google server in the USA and stored there.

17.2 Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (

17.3 Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services associated with the use of this online offer and the use of the Internet. Pseudonymous user profiles can be created from the processed data.

17.4 We use Google Analytics to display ads placed by Google and its partners within advertising services only to users who have shown an interest in our online offering or who have certain characteristics (e.g. interests in certain topics or products that are determined by the web pages visited) that we send to Google (so-called “remarketing” or “Google Analytics Audiences”). With the help of remarketing audiences we would also like to ensure that our ads correspond to the potential interest of the users and are not annoying.

17.5 We only use Google Analytics with IP anonymization enabled. This means that Google will reduce the IP address of users within Member States of the European Union or in other states party 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.

17.6 The IP address transmitted by the user’s browser is not merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online offer and processing this data by Google by downloading and installing the browser plug-in available under the following link:>.

17.7 You can find out more information about data usage by Google, setting and objection options on Google’s web pages: < (“Data usage by Google when using our partners’ websites or apps”) << (“Use of data for advertising purposes”), < (“Manage information Google uses to show you advertising”).

18. Google-Re/Marketing-Services

18.1 On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) the marketing and remarketing services (“Google Marketing Services” for short) of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).

18.2 Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (

18.3 Google marketing services allow us to target ads for and on our site to show users only ads that potentially match their interests. For example, if a user sees ads for products he has been interested in on other websites, this is referred to as “remarketing”. For these purposes, when our and other websites on which Google marketing services are active are accessed, Google directly executes a code from Google and (re)marketing tags (invisible graphics or code, also known as “web beacons”) are integrated into the website. 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,,,, or In this file it is noted which websites the user visits, which contents he is interested in and which offers he has clicked on, 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 users is also recorded, whereby we inform within the framework of Google Analytics that the IP address is shortened within member states of the European Union or in other signatory states of the European Economic Area Agreement and only in exceptional cases completely transmitted to a Google server in the USA and shortened there. The IP address is not combined with the user’s data within other Google offers. The above information may also be linked by Google to such information from other sources. If the user then visits other websites, the ads tailored to his interests can be displayed.

18.4 User data is processed pseudonymously within the framework of Google marketing services. This means that Google does not store and process, for example, the names or e-mail addresses of users, but processes the relevant data cookie-related within pseudonymous user profiles. This means from Google’s point of view, the ads are not managed 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 pseudonymization. The information collected by Google marketing services about users is transmitted to Google and stored on Google’s servers in the USA.

18.5 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 cannot therefore be traced through the websites of AdWords customers. The information collected by the cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers see the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, you will not receive any information that personally identifies users.

18.6 We may use the Google Marketing Service “DoubleClick” to include third-party ads. DoubleClick uses cookies to enable Google and its partner sites to serve ads based on users’ visits to this site or other sites on the Internet.

18.7 We may include third-party ads based on the AdSense Google marketing service. AdSense uses cookies, with

19. Facebook-, Custom Audiences und Facebook-Marketing-Dienste

19.1 Due to our legitimate interests in the analysis, optimization and economic operation of our online offer and for these purposes, the so-called “Facebook pixel” of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), is used within our online offer.

19.2 Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (<

19.3 With the help of the Facebook pixel, Facebook is able to determine the visitors of our online offer as a target group for the presentation of ads (so-called “Facebook ads”). Accordingly, we use the Facebook pixel to display the Facebook ads we post only to Facebook users who have also shown an interest in our online offering or who have certain features (e.g. interests in certain topics or products that are determined by the websites visited) that we transmit to Facebook (so-called “custom audiences”). We also want to use the Facebook pixel to ensure that our Facebook ads meet the potential interest of users and are not a nuisance. The Facebook pixel also helps us understand the effectiveness of Facebook ads for statistical and market research purposes by showing whether users have been redirected to our website after clicking on a Facebook ad (so-called “conversion”).

19.4 Facebook processes the data in accordance with Facebook’s Data Usage Policy. Accordingly, general information on the display of Facebook ads is contained in Facebook’s Data Usage Policy: < For specific information and details about the Facebook Pixel and how it works, visit the Facebook Help section: <

19.5 You can object to the collection by the Facebook pixel and use of your data to display Facebook ads. To set what types of ads are displayed to you within Facebook, you can visit the page set up by Facebook and follow the instructions for use-based advertising settings: < The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.

19.6 To prevent your data from being collected via the Facebook pixel on our website, please click the following link: Facebook-Opt-OutNote: When you click the link, an “Opt-Out” cookie is stored on your device. If you delete the cookies in this browser, you must click the link again. Furthermore, the opt-out only applies within the browser you use and only within our web domain on which the link was clicked.

19.6 You can also use cookies to measure reach and for advertising purposes via the deactivation page of the network advertising initiative ( and additionally the US-American website (< or the European website (<

20. Facebook Social Plugins

20.1 On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) Social Plugins (“Plugins”) of the social network, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”). The plugins can display interaction elements or content (e.g. videos, graphics or text contributions) and are identified by one of the Facebook logos (white “f” on blue tile, the terms “like”, “like” or a “thumbs up” sign) or are marked with the addition “Facebook Social Plugin”. The list and the appearance of the Facebook Social Plugins can be viewed here: <

20.2 Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (<

20.3 When a user calls a feature of this online service that contains such a plugin, his device establishes a direct connection to the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated into the online offer. The processed data can be used to create user profiles. We, therefore, have no influence on the amount of data Facebook collects with the help of this plugin and therefore inform users according to our level of knowledge.

20.4 By integrating the plugins Facebook receives the information that a user has called 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, such as pressing the Like button or posting a comment, the information is sent 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 obtain and store their IP address. According to Facebook, only an anonymized IP address is stored in Germany.

20.5 The purpose and scope of data collection and further processing and use of the data by Facebook and the rights and setting options for protecting users’ privacy can be found in Facebook’s privacy policy: <

20.6 If a user is a Facebook member and does not want Facebook to collect data about him via this online offer and link it to his member data stored on Facebook, he must log out of Facebook and delete his cookies before using our online offer. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: or via the US page or the EU page < The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.

21. Newsletter

21.1 With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter you agree to the receipt and the described procedures.

21.2 Newsletter content: We send newsletters, e-mails and other electronic notifications containing promotional information (hereinafter “newsletters”) only with the consent of the recipients or legal permission. If the contents of a newsletter are specifically described within the scope of a registration, they are decisive for the consent of the users. In addition, our newsletters contain information about our products, offers, promotions, and our company.

21.3 Double opt-in and logging: The subscription to our newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can log in with other e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes the storage of the login and confirmation time, as well as the IP address. The changes to your data stored with the shipping service provider are also logged.

21.4 Shipping service provider: The newsletter is sent by CleverReach GmbH & Co. KG, Mühlenstr. 43, 26180 Rastede, hereinafter referred to as “shipping service provider”. The data protection regulations of the shipping service provider can be viewed here:

21.5 Furthermore, the shipping service provider can use this data in pseudonymous form, i.e. without assignment to a user, to optimize or improve its own services, e.g. to technically optimize the sending and presentation of the newsletter or for statistical purposes to determine from which countries the recipients come. However, the shipping service does not use the data of our newsletter recipients to write them down or pass them on to third parties.

21.6 Credentials: To subscribe to the newsletter, simply enter your e-mail address. Optionally, we ask you to enter a name in the newsletter in order to address us personally.

21.7 Success measurement – The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from the server of the shipping 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 initially collected. This information is used to technically improve the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or 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 not our intention, nor that of the shipping service provider, to observe 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.

21.8 The dispatch of the newsletter and the performance measurement are based on the recipients’ consent pursuant to Art. 6 para. 1 lit. a, Art. 7 GDPR in conjunction with § 7 para. 2 no. 3 UWG or on the basis of the legal permission pursuant to § 7 para. 3 UWG.

21.9 The registration procedure is logged on the basis of our legitimate interests pursuant to Art. 6 para. 1 letter f GDPR and serves as proof of consent to the receipt of the newsletter.

21.10 Termination/Revocation – You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. If users have only subscribed to the newsletter and canceled their subscription, their personal data will be deleted.

22. integration of third-party services and content

22.1 We set within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) content or service offers of third parties to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”). This always presupposes that the third-party providers of this content perceive the IP address of the users since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content. We make every effort to use only those contents whose respective providers use the IP address only for the delivery of the contents. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. 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 include technical information about the browser and operating system, referring websites, visiting time and other information about the use of our online offer, as well as may be linked to such information from other sources.

22.2 The following presentation provides an overview of third-party providers and their contents, together with links to their data protection declarations, which contain further information on data processing and, in some cases already mentioned here, possibilities of objection (so-called opt-out):

 If our customers use third-party payment services (e.g. PayPal or Stripe), the terms and conditions and privacy policy of the respective third-party providers, which can be accessed within the respective websites or transaction applications, apply.

 External fonts from Google, LLC., (“Google Fonts”). The integration of the Google Fonts takes place via a server call with Google (usually in the USA). Privacy Policy: <, Opt-Out: <

 Maps of the service “Google Maps” of the third party provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy:, Opt-Out:

 Videos of the third-party platform “YouTube” of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: <, Opt-Out: <

 Videos of the third party Vimeo, Inc. 555 West 18th Street, New York, New York 10011LLC. Privacy policy:, Opt-Out:

 Functions of the Google+ service are integrated within our online offer. These features are provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. If you are logged into your Google+ – account you can link the contents of our pages with your Google+ – profile by clicking the Google+ – button. This allows Google to associate the visit to our pages with your account. We would like to point out that we, as the provider of the pages, are not aware of the content of the transmitted data or its use by Google+. Privacy Policy: <, Opt-Out: <

⇨ Functions of the Instagram service are integrated in our online offer. These functions are provided by Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA. If you are logged into your Instagram account you can link the contents of our pages to your Instagram profile by clicking the Instagram button. This allows Instagram to associate the visit to our pages with your user account. We would like to point out that, as the provider of these pages, we are not aware of the content of the übermittelten data or its use by Instagram. Privacy Policy:

⇨ Within our online offer we use the marketing functions (so-called “LinkedIn Insight Tag”) of the network LinkedIn. The provider is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA. Every time you visit one of our pages that contains functions of LinkedIn, a connection to LinkedIn’s servers is established. LinkedIn is informed that you have visited our website with your IP address. With the help of the LinkedIn Insight Tag we can analyse the success of our campaigns within LinkedIn or determine target groups for them based on the interaction of the users with our online offer. If you are registered with LinkedIn, it is possible for LinkedIn to associate your interaction with our online service with your user account. Even if you click on the “Recommend-Button” of LinkedIn and are logged into your LinkedIn account, LinkedIn is able to assign your visit to our website to you and your user account. LinkedIn is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law ( Privacy Policy:, Opt-Out:

⇨ We use social plugins of the social network Pinterest, which is operated by Pinterest Inc. 635 High Street, Palo Alto, CA, 94301, USA (“Pinterest”). When you access a page that contains such a plugin, your browser establishes a direct connection to Pinterest’s servers. The plugin transfers protocol data to Pinterest’s server in the USA. This log information may include your IP address, the address of the sites you visit, which may also include Pinterest features, the type and settings of your browser, the date and time of your request, your use of Pinterest, and cookies. Privacy Policy:

⇨ Functions of the service or the Twitter platform (hereinafter referred to as “Twitter”) may be integrated within our online offer. Twitter is an offer of Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The functions include the presentation of our contributions within Twitter within our online offer, the link to our profile on Twitter as well as the possibility to interact with the contributions and the functions of Twitter and to measure whether users reach our online offer via the advertisements we place on Twitter (so-called conversion measurement). Twitter is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law ( Privacy Policy:, Opt-Out:

⇨ External code of the JavaScript framework “jQuery”, provided by the third-party provider jQuery Foundation,

22. integration of Zoho SalesIQ

When you visit our website, anonymized usage data is collected using Zoho SalesIQ (, a web analytics service provided by Zoho Corporation, 4141 Hacienda Drive, Pleasanton, California 94588, USA. SalesIQ uses so-called “cookies”, which enable an analysis of our website. These cookies also collect information about how visitors use the website, which website the user came from, the number of visits each user made, and how long they stayed on the websites. You can prevent this “tracking” by making appropriate settings in your browser. We store this data exclusively for statistical purposes. IP addresses are shortened by the last digits to ensure anonymity, in accordance with the law.

Zoho is certified under the EU-US Privacy Shield. Please see the following links for Zoho Corporation’s Privacy Policy and Cookie Policy: