Data
Protection
Introduction
Table of contents
– Introduction
– Responsible
– Overview of the processing operations
– Relevant legal bases
– Transmission and disclosure of personal data
– Data processing in third countries
– Use of cookies
– Contact
– Provision of the online offer and web hosting
– Online marketing
– Presence in social networks
– deletion of data
– Amendment and update of the privacy policy
– Rights of data subjects
Responsible
Authorized representatives: Maximilian Grönemeyer
E-mail address: services@campo.group
Legal notice: https://www.campo.group/imprint/
Overview of the processing operations
The following overview summarises 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. text entries, photographs, videos).
– 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).
Categories of data subjects
– Interested parties. – Communication partners.
– Users (e.g. website visitors, users of online services).
Purposes of processing
– Visitor Action Evaluation. – 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).
– Tracking (e.g. interest/behavioural profiling, use of cookies).
Relevant legal bases
In the following, we provide the legal basis of the basic data protection regulation (DSGVO), on the basis of which we process personal data. Please note that in addition to the regulations of the DSGVO, national data protection regulations may apply in your or our country of residence and domicile. If, in addition, more specific legal bases are applicable in individual cases, we will inform you of these in the data protection declaration.
– Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO) – The data subject has given his or her consent to the processing of personal data relating to him or her for one or more specific purposes.
– Fulfilment of a contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. FADP) – Processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject.
– Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. FADP) – Processing is necessary to safeguard the legitimate interests of the controller or of a third party unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data prevail.
National data protection regulations in Germany: In addition to the data protection regulations of the basic data protection regulation, national regulations on data protection apply in Germany. These include in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act – BDSG). In particular, the BDSG contains special regulations on the right to information, the right to deletion, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision making in individual cases including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.
Transmission and disclosure of personal data
Within the scope of our processing of personal data, it happens that the data is transferred to other bodies, companies, legally independent organisational units or persons or that it is disclosed to them. The recipients of this data may include, for example, payment institutions in the context 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 appropriate contracts or agreements with the recipients of your data which 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 if the processing takes place in the context of the use of services provided by third parties or the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with the legal requirements. Subject to express consent or to contractual or legally required transfers, we process or allow the data to be processed only in third countries with a recognised level of data protection, including the US processors certified under the Privacy Shield, or on the basis of special guarantees, such as contractual obligations under so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).
Use of cookies
Cookies are text files that contain data from websites or domains visited and are stored by a browser on the user’s computer. A cookie is primarily used to store information about a user during or after his visit within an online offer. The stored information may include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was viewed. The term „cookies“ also includes other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also known as „user IDs“).
The following cookie types and functions are distinguished:
– Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user leaves an online offer and closes his browser.
– Permanent cookies: Permanent cookies remain stored even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. The interests of users used for reach measurement or marketing purposes can also be stored in such a cookie.
– First-party cookies: First-party cookies are set by ourselves.
– Third party cookies: Third party cookies are mainly used by advertisers (so-called third parties) to process user information.
– Necessary (also: essential or imperative) cookies: Cookies can be absolutely necessary for the operation of a website (e.g. to store logins or other user input or for security reasons).
– Statistical, marketing and personalization cookies: Furthermore, cookies are usually also used in the context of range measurement as well as when the interests of a user or his or her behavior (e.g. viewing certain content, using functions, etc.) on individual web pages are stored in a user profile. Such profiles are used to show users e.g. content that corresponds to their potential interests. This procedure is also known as „tracking“, i.e., following the potential interests of users. . If we use cookies or „tracking“ technologies, we will inform you separately in our data protection declaration or when obtaining your consent.
Notes on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask you for your consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is the declared consent. Otherwise, the data processed with the aid of cookies will be processed on the basis of our legitimate interests (e.g. in the business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfil our contractual obligations.
General notes on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the possibility 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 initially declare your objection by means of the settings of your browser, e.g. by deactivating the use of cookies (although this may also restrict the functionality of our online service). An objection to the use of cookies for online marketing purposes can also be declared 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 receive further notices of objection in the context of the information on the service providers and cookies used.
Processing of cookie data based on consent: Before we process data within the scope of the use of cookies or have them processed, we ask users for their consent, which can be revoked at any time. Before consent has not been given, cookies are used if necessary, which are necessary for the operation of our online offer. Their use is based on our interest and the interest of the users in the expected functionality of our online offer.
– Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
– Persons concerned: Users (e.g. website visitors, users of online services).
– Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Contact
When contacting us (e.g. via contact form, e-mail, telephone or social media), the data of the inquiring persons will be processed to the extent necessary to answer the contact inquiries and any requested measures. The answering of contact inquiries within the scope of contractual or pre-contractual relations is carried out in order to fulfil our contractual obligations or to answer (pre)contractual inquiries and otherwise on the basis of the legitimate interest 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. text entries, photographs, videos).
– Persons concerned: communication partners.
– Purposes of processing: contact requests and communication.
– Legal basis: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Provision of the online offer and web hosting
In order to provide our online services securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online services can be accessed. For these purposes we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance services.
The data processed within the scope of providing the hosting offer may include all data concerning the users of our online offer, which are generated within the scope of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.
E-mail dispatch and hosting: The web hosting services we use also include the dispatch, receipt 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) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for the purpose of SPAM detection. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception 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). Server log files may include the address and name of the web pages and files accessed, date and time of access, data volume transferred, 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 for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the capacity utilisation of the servers and their stability.
– Processed data types: Content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
Persons concerned: Users (e.g. website visitors, users of online services).
– Legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Online marketing
We process personal data for online marketing purposes, which may include, in particular, the marketing of advertising space or the display of advertising and other content (collectively referred to as „Content“) based on the potential interests of users and the measurement of their effectiveness.
For these purposes, so-called user profiles are created and stored in a file (so-called „cookie“) or similar procedures are used, by means of which the user information relevant for the presentation of the aforementioned content is stored. This information may include, for example, the content viewed, web pages visited, online networks used, but also communication partners 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 may also be processed. The IP addresses of users are also stored. However, we use available IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect the users. In general, the online marketing procedure does not store any clear user data (such as e-mail addresses or names), but pseudonyms. This means that we as well as the providers of the online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.
As a rule, the information in the profiles is stored in the cookies or by means of similar procedures. These cookies can later be read out and analysed for the purpose of presenting content on other websites that use the same online marketing procedure, and can also be supplemented with additional data and stored on the server of the online marketing procedure provider.
As an exception, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing procedure we use and the network links the user profiles with the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.
As a matter of principle, we only obtain access to summarized information on the success of our advertisements. However, we can check in the context of so-called conversion measurements which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures. Unless otherwise stated, we ask you to assume that cookies used are stored for a period of two years.
Notes on legal bases: If we ask users to give their consent to the use of third parties, the legal basis for processing data is consent. Otherwise, the users‘ data will be 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 types of data: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
– Affected persons: Users (e.g. website visitors, users of online services), interested parties.
– Purposes of processing: Tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, visitor action analysis, interest-based and behavioural marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors)
– security measures: IP-Masking (pseudonymisation of the IP address).
– Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
– Possibility of objection (Opt-Out): We refer to the data protection information of the respective providers and the possibilities of objection stated for the providers (so-called \“Opt-Out\“). If no explicit opt-out option has been specified, it is possible to switch off cookies in the settings of your browser. However, this can restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary form for the respective areas: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-regional: https://optout.aboutads.info.
Services used and service providers:
– Google Analytics: online marketing and web analytics; service providers: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com/intl/de/about/analytics/; privacy policy: https://policies.google.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active; Opt-out: Opt-out plug-in: https://tools.google.com/dlpage/gaoptout?hl=de, Settings for the display of advertising: https://adssettings.google.com/authenticated.
– Google Ads and Conversion Measurement: We use the online marketing process „Google Ads“ to place ads in the Google advertising network (e.g., in search results, in videos, on web pages, etc.) so that they are displayed to users who have a presumed interest in the ads. We also measure the conversion of the ads. However, we only know the total number of anonymous users who clicked on our ad and were redirected to a page with a so-called „conversion tracking tag“. We do not receive any information that can be used to identify users. Service Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://marketingplatform.google.com; Privacy Policy: https://policies.google.com/privacy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
– Salesforce.com is an international provider of cloud computing solutions for businesses. Headquartered in San Francisco, the company delivers business applications for enterprises over the Internet. With the connection to Salesforce, contact data is collected in a CRM system to improve customer service in a future-oriented manner.
Presence in social networks
We maintain online presences within social networks in order to communicate with the users active there or to offer information about us there. Please note that user data may be processed outside the European Union. This can result in risks for the users, because the enforcement of the users‘ rights could be made more difficult. With regard to US providers that are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we would like to point out that they thereby undertake to comply with the data protection standards of the EU. Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users‘ computers, in which the usage behaviour and interests of the users are stored. Furthermore, data may also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to these). For a detailed description of the respective forms of processing and the possibilities of objection (opt-out), please refer to the data protection declarations and information provided by 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 most effectively be asserted with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information directly. Should you nevertheless require assistance, please contact us.
– Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
– Persons concerned: Users (e.g. website visitors, users of online services). Purposes of processing: contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing. Legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
Services used and service providers:
– Instagram : Social network; Service provider: Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA; website: https://www.instagram.com; privacy policy: https://instagram.com/about/legal/privacy.
– LinkedIn: Social Network; Service Provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; website: https://www.linkedin.com; privacy policy: https://www.linkedin.com/legal/privacy-policy; Privacy Shield (ensuring the level of data protection when processing data in the USA): https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active; opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as their consent permitted for processing is revoked or other permissions cease to apply (e.g. if the purpose for processing these data ceases to apply or if they are not necessary for the purpose). Unless the data are deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose retention is necessary for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person.
Further information on the deletion of personal data can also be provided in the individual data protection notes of this data protection declaration.
Amendment and updating of the data protection declaration
We ask you to inform yourself regularly about the content 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 make it necessary for you to cooperate (e.g. consent) or to receive other individual notification. If we provide addresses and contact information of companies and organisations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.
Rights of data subjects
As data subjects, they are entitled to various rights under the DSGVO, which result in particular from Art. 15 to 18 and 21 DSGVO:
– Right of objection: You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data relating to you which is carried out on the basis of Art. 6 paragraph 1 letter e or f FADP; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing, including profiling, insofar as it is linked to such direct marketing.
– Right to withdraw consent: You have the right to withdraw any consent given at any time.
– Right of access: You have the right to obtain confirmation as to whether data in question is being processed and to obtain information about such data and to obtain further information and copies of the data in accordance with the law.
– Right of rectification: You have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you in accordance with the law.
Right to erasure and restriction of processing: You have the right to request that data concerning you be erased immediately or, alternatively, to request a restriction of processing of the data in accordance with the law.
– Right to data transferability: You have the right to receive data concerning you that you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements or to request that it be transferred to another responsible party.
– Complaints to the supervisory authority: You also have the right, in accordance with the statutory provisions, 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 believe that the processing of personal data relating to you is in breach of the DPA.
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