We are very delighted that you have shown interest in our enterprise. Data protection is of a
particularly high priority for the management of the Yoga with Paulina. The use of the Internet pages
of the Yoga with Paulina is possible without any indication of personal data; however, if a data subject
wants to use special enterprise services via our website, processing of personal data could become
necessary. If the processing of personal data is necessary and there is no statutory basis for such
processing, we generally obtain consent from the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of
a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in
accordance with the country-specific data protection regulations applicable to the Yoga with Paulina.
By means of this data protection declaration, our enterprise would like to inform the general public of
the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data
subjects are informed, by means of this data protection declaration, of the rights to which they are
entitled.
As the controller, Yoga with Paulina has implemented numerous technical and organisational
measures to ensure the most complete protection of personal data processed through this website.
However, Internet-based data transmissions may in principle have security gaps, so absolute
protection may not be guaranteed. For this reason, every data subject is free to transfer personal data
to us via alternative means, e.g. by telephone.

1. Definitions
The data protection declaration of the Yoga with Paulina is based on the terms used by the European
legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection
declaration should be legible and understandable for the general public, as well as our customers and
business partners. To ensure this, we would like to first explain the terminology used.
In this data protection declaration, we use, inter alia, the following terms:

● a) Personal data
Personal data means any information relating to an identified or identifiable natural person
(“data subject”). An identifiable natural person is one who can be identified, directly or
indirectly, in particular by reference to an identifier such as a name, an identification number,
location data, an online identifier or to one or more factors specific to the physical,
physiological, genetic, mental, economic, cultural or social identity of that natural person.
● b) Data subject
Data subject is any identified or identifiable natural person, whose personal data is processed
by the controller responsible for the processing.
● c) Processing
Processing is any operation or set of operations which is performed on personal data or on
sets of personal data, whether or not by automated means, such as collection, recording,
organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use,
disclosure by transmission, dissemination or otherwise making available, alignment or
combination, restriction, erasure or destruction.

● d) Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their
processing in the future.
● e) Profiling
Profiling means any form of automated processing of personal data consisting of the use of
personal data to evaluate certain personal aspects relating to a natural person, in particular to
analyse or predict aspects concerning that natural person’s performance at work, economic
situation, health, personal preferences, interests, reliability, behaviour, location or movements.
● f) Pseudonymisation
Pseudonymisation is the processing of personal data in such a manner that the personal data
can no longer be attributed to a specific data subject without the use of additional information,
provided that such additional information is kept separately and is subject to technical and
organisational measures to ensure that the personal data are not attributed to an identified or
identifiable natural person.
● g) Controller or controller responsible for the processing
Controller or controller responsible for the processing is the natural or legal person, public
authority, agency or other body which, alone or jointly with others, determines the purposes
and means of the processing of personal data; where the purposes and means of such
processing are determined by Union or Member State law, the controller or the specific
criteria for its nomination may be provided for by Union or Member State law.
● h) Processor
Processor is a natural or legal person, public authority, agency or other body which processes
personal data on behalf of the controller.
● i) Recipient
Recipient is a natural or legal person, public authority, agency or another body, to which the
personal data are disclosed, whether a third party or not. However, public authorities which
may receive personal data in the framework of a particular inquiry in accordance with Union
or Member State law shall not be regarded as recipients; the processing of that data by those
public authorities shall be in compliance with the applicable data protection rules according to
the purposes of the processing.
● j) Third party
Third party is a natural or legal person, public authority, agency or body other than the data
subject, controller, processor and persons who, under the direct authority of the controller or
processor, are authorised to process personal data.
● k) Consent
Consent of the data subject is any freely given, specific, informed and unambiguous indication
of the data subject’s wishes by which he or she, by a statement or by a clear affirmative
action, signifies agreement to the processing of personal data relating to him or her.

2. Name and Address of the controller
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection
laws applicable in Member states of the European Union and other provisions related to data
protection is:
Yoga with Paulina

Munich

Germany
Phone: +4917621967646
Email: withpaulina@gmail.com
Website: www.withpaulina.com

3. Cookies
The Internet pages of the Yoga with Paulina use cookies. Cookies are text files that are stored in a
computer system via an Internet browser.
Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID
is a unique identifier of the cookie. It consists of a character string through which Internet pages and
servers can be assigned to the specific Internet browser in which the cookie was stored. This allows
visited Internet sites and servers to differentiate the individual browser of the data subject from other
Internet browsers that contain other cookies. A specific Internet browser can be recognized and
identified using the unique cookie ID.
Through the use of cookies, Yoga with Paulina can provide the users of this website with more
user-friendly services that would not be possible without the cookie setting.
By means of a cookie, the information and offers on our website can be optimised with the user in
mind. Cookies allow us, as previously mentioned, to recognize our website users. The purpose of this
recognition is to make it easier for users to utilise our website. The website user that uses cookies,
e.g. does not have to enter access data each time the website is accessed, because this is taken over
by the website, and the cookie is thus stored on the user’s computer system. Another example is the
cookie of a shopping cart in an online shop. The online store remembers the articles that a customer
has placed in the virtual shopping cart via a cookie.
The data subject may, at any time, prevent the setting of cookies through our website by means of a
corresponding setting of the Internet browser used, and may thus permanently deny the setting of
cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other
software programs. This is possible in all popular Internet browsers. If the data subject deactivates the
setting of cookies in the Internet browser used, not all functions of our website may be entirely usable.

4. Collection of general data and information
The website of the Yoga with Paulina collects a series of general data and information when a data
subject or automated system calls up the website. This general data and information are stored in the
server log files. Collected may be (1) the browser types and versions used, (2) the operating system
used by the accessing system, (3) the website from which an accessing system reaches our website
(so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an
Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and
(8) any other similar data and information that may be used in the event of attacks on our information
technology systems.

When using these general data and information, the Yoga with Paulina does not draw any conclusions
about the data subject. Rather, this information is needed to (1) deliver the content of our website
correctly, (2) optimise the content of our website as well as its advertisement, (3) ensure the long-term
viability of our information technology systems and website technology, and (4) provide law
enforcement authorities with the information necessary for criminal prosecution in case of a
cyber-attack. Therefore, the Yoga with Paulina analyses anonymously collected data and information
statistically, with the aim of increasing the data protection and data security of our enterprise, and to
ensure an optimal level of protection for the personal data we process. The anonymous data of the
server log files are stored separately from all personal data provided by a data subject.

5. Registration on our website
The data subject has the possibility to register on the website of the controller with the indication of
personal data. Which personal data are transmitted to the controller is determined by the respective
input mask used for the registration. The personal data entered by the data subject are collected and
stored exclusively for internal use by the controller, and for his own purposes. The controller may
request transfer to one or more processors (e.g. a parcel service) that also uses personal data for an
internal purpose which is attributable to the controller.
By registering on the website of the controller, the IP address—assigned by the Internet service
provider (ISP) and used by the data subject—date, and time of the registration are also stored. The
storage of this data takes place against the background that this is the only way to prevent the misuse
of our services, and, if necessary, to make it possible to investigate committed offences. Insofar, the
storage of this data is necessary to secure the controller. This data is not passed on to third parties
unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal
prosecution.
The registration of the data subject, with the voluntary indication of personal data, is intended to
enable the controller to offer the data subject contents or services that may only be offered to
registered users due to the nature of the matter in question. Registered persons are free to change
the personal data specified during the registration at any time, or to have them completely deleted
from the data stock of the controller.
The data controller shall, at any time, provide information upon request to each data subject as to
what personal data are stored about the data subject. In addition, the data controller shall correct or
erase personal data at the request or indication of the data subject, insofar as there are no statutory
storage obligations. The entirety of the controller’s employees are available to the data subject in this
respect as contact persons.

6. Subscription to our newsletters
On the website of Yoga with Paulina, users are given the opportunity to subscribe to our enterprise’s
newsletter. The input mask used for this purpose determines what personal data are transmitted, as
well as when the newsletter is ordered from the controller.
The Yoga with Paulina informs its customers and business partners regularly by means of a
newsletter about enterprise offers. The enterprise’s newsletter may only be received by the data
subject if (1) the data subject has a valid e-mail address and (2) the data subject registers for the

newsletter shipping. A confirmation email will be sent to the e-mail address registered by a data
subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This
confirmation email is used to prove whether the owner of the e-mail address as the data subject is
authorised to receive the newsletter.
During the registration for the newsletter, we also store the IP address of the computer system
assigned by the Internet service provider (ISP) and used by the data subject at the time of the
registration, as well as the date and time of the registration. The collection of this data is necessary in
order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it
therefore serves the aim of the legal protection of the controller.
The personal data collected as part of a registration for the newsletter will only be used to send our
newsletter. In addition, subscribers to the newsletter may be informed by email, as long as this is
necessary for the operation of the newsletter service or a registration in question, as this could be the
case in the event of modifications to the newsletter offer, or in the event of a change in technical
circumstances. There will be no transfer of personal data collected by the newsletter service to third
parties. The subscription to our newsletter may be terminated by the data subject at any time. The
consent to the storage of personal data, which the data subject has given for shipping the newsletter,
may be revoked at any time. For the purpose of revocation of consent, a corresponding link is found in
each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the
website of the controller, or to communicate this to the controller in a different way.

7. Newsletter-Tracking
The newsletter of the Yoga with Paulina contains so-called tracking pixels. A tracking pixel is a
miniature graphic embedded in such emails, which are sent in HTML format to enable log file
recording and analysis. This allows a statistical analysis of the success or failure of online marketing
campaigns. Based on the embedded tracking pixel, the Yoga with Paulina may see if and when an
email was opened by a data subject, and which links in the email were called up by data subjects.
Such personal data collected in the tracking pixels contained in the newsletters are stored and
analysed by the controller in order to optimise the shipping of the newsletter, as well as to adapt the
content of future newsletters even better to the interests of the data subject. These personal data will
not be passed on to third parties. Data subjects are at any time entitled to revoke the respective
separate declaration of consent issued by means of the double-opt-in procedure. After a revocation,
these personal data will be deleted by the controller. The Yoga with Paulina automatically regards a
withdrawal from the receipt of the newsletter as a revocation.

8. Contact possibility via the website
The website of the Yoga with Paulina contains information that enables a quick electronic contact to
our enterprise, as well as direct communication with us, which also includes a general address of the
so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a
contact form, the personal data transmitted by the data subject are automatically stored. Such
personal data transmitted on a voluntary basis by a data subject to the data controller are stored for
the purpose of processing or contacting the data subject. There is no transfer of this personal data to
third parties.

9. Comments function in the blog on the website
The Yoga with Paulina offers users the possibility to leave individual comments on individual blog
contributions on a blog, which is on the website of the controller. A blog is a web-based,
publicly-accessible portal, through which one or more people called bloggers or web-bloggers may
post articles or write down thoughts in so-called blog posts. Blog Posts may usually be commented by
third parties.
If a data subject leaves a comment on the blog published on this website, the comments made by the
data subject are also stored and published, as well as information on the date of the commentary and
on the user’s (pseudonym) chosen by the data subject. In addition, the IP address assigned by the
Internet service provider (ISP) to the data subject is also logged. This storage of the IP address takes
place for security reasons, and in case the data subject violates the rights of third parties, or posts
illegal content through a given comment. The storage of these personal data is, therefore, in the own
interest of the data controller, so that he can exculpate in the event of an infringement. This collected
personal data will not be passed to third parties, unless such a transfer is required by law or serves
the aim of the defence of the data controller.

10. Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the data subject only for the period
necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or
other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or
another competent legislator expires, the personal data are routinely blocked or erased in accordance
with legal requirements.

11. Rights of the data subject

● a) Right of confirmation
Each data subject shall have the right granted by the European legislator to obtain from the
controller the confirmation as to whether or not personal data concerning him or her are being
processed. If a data subject wishes to avail himself of this right of confirmation, he or she
may, at any time, contact any employee of the controller.
● b) Right of access
Each data subject shall have the right granted by the European legislator to obtain from the
controller free information about his or her personal data stored at any time and a copy of this
information. Furthermore, the European directives and regulations grant the data subject
access to the following information:
○ the purposes of the processing;
○ the categories of personal data concerned;
○ the recipients or categories of recipients to whom the personal data have been or will
be disclosed, in particular recipients in third countries or international organisations;
○ where possible, the envisaged period for which the personal data will be stored, or, if
not possible, the criteria used to determine that period;

○ the existence of the right to request from the controller rectification or erasure of
personal data, or restriction of processing of personal data concerning the data
subject, or to object to such processing;
○ the existence of the right to lodge a complaint with a supervisory authority;
○ where the personal data are not collected from the data subject, any available
information as to their source;
○ the existence of automated decision-making, including profiling, referred to in Article
22(1) and (4) of the GDPR and, at least in those cases, meaningful information about
the logic involved, as well as the significance and envisaged consequences of such
processing for the data subject.

● Furthermore, the data subject shall have a right to obtain information as to whether personal
data are transferred to a third country or to an international organisation. Where this is the
case, the data subject shall have the right to be informed of the appropriate safeguards
relating to the transfer.
If a data subject wishes to avail himself of this right of access, he or she may, at any time,
contact any employee of the controller.
● c) Right to rectification
Each data subject shall have the right granted by the European legislator to obtain from the
controller without undue delay the rectification of inaccurate personal data concerning him or
her. Taking into account the purposes of the processing, the data subject shall have the right
to have incomplete personal data completed, including by means of providing a
supplementary statement.
If a data subject wishes to exercise this right to rectification, he or she may, at any time,
contact any employee of the controller.
● d) Right to erasure (Right to be forgotten)
Each data subject shall have the right granted by the European legislator to obtain from the
controller the erasure of personal data concerning him or her without undue delay, and the
controller shall have the obligation to erase personal data without undue delay where one of
the following grounds applies, as long as the processing is not necessary:
○ The personal data are no longer necessary in relation to the purposes for which they
were collected or otherwise processed.
○ The data subject withdraws consent to which the processing is based according to
point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and
where there is no other legal ground for the processing.
○ The data subject objects to the processing pursuant to Article 21(1) of the GDPR and
there are no overriding legitimate grounds for the processing, or the data subject
objects to the processing pursuant to Article 21(2) of the GDPR.
○ The personal data have been unlawfully processed.
○ The personal data must be erased for compliance with a legal obligation in Union or
Member State law to which the controller is subject.
○ The personal data have been collected in relation to the offer of information society
services referred to in Article 8(1) of the GDPR.

● If one of the aforementioned reasons applies, and a data subject wishes to request the
erasure of personal data stored by the Yoga with Paulina, he or she may, at any time, contact
any employee of the controller. An employee of Yoga with Paulina shall promptly ensure that
the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to
erase the personal data, the controller, taking account of available technology and the cost of
implementation, shall take reasonable steps, including technical measures, to inform other
controllers processing the personal data that the data subject has requested erasure by such
controllers of any links to, or copy or replication of, those personal data, as far as processing

is not required. An employee of the Yoga with Paulina will arrange the necessary measures in
individual cases.
● e) Right of restriction of processing
Each data subject shall have the right granted by the European legislator to obtain from the
controller restriction of processing where one of the following applies:
○ The accuracy of the personal data is contested by the data subject, for a period
enabling the controller to verify the accuracy of the personal data.
○ The processing is unlawful and the data subject opposes the erasure of the personal
data and requests the restriction of their use instead.
○ The controller no longer needs the personal data for the purposes of the processing,
but they are required by the data subject for the establishment, exercise or defence of
legal claims.
○ The data subject has objected to processing pursuant to Article 21(1) of the GDPR
pending the verification whether the legitimate grounds of the controller override
those of the data subject.

● If one of the aforementioned conditions is met, and a data subject wishes to request the
restriction of the processing of personal data stored by the Yoga with Paulina, he or she may
at any time contact any employee of the controller. The employee of the Yoga with Paulina will
arrange the restriction of the processing.
● f) Right to data portability
Each data subject shall have the right granted by the European legislator, to receive the
personal data concerning him or her, which was provided to a controller, in a structured,
commonly used and machine-readable format. He or she shall have the right to transmit
those data to another controller without hindrance from the controller to which the personal
data have been provided, as long as the processing is based on consent pursuant to point (a)
of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant
to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated
means, as long as the processing is not necessary for the performance of a task carried out in
the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the
GDPR, the data subject shall have the right to have personal data transmitted directly from
one controller to another, where technically feasible and when doing so does not adversely
affect the rights and freedoms of others.
In order to assert the right to data portability, the data subject may at any time contact any
employee of the Yoga with Paulina.
● g) Right to object
Each data subject shall have the right granted by the European legislator to object, on
grounds relating to his or her particular situation, at any time, to processing of personal data
concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also
applies to profiling based on these provisions.
The Yoga with Paulina shall no longer process the personal data in the event of the objection,
unless we can demonstrate compelling legitimate grounds for the processing which override
the interests, rights and freedoms of the data subject, or for the establishment, exercise or
defence of legal claims.
If the Yoga with Paulina processes personal data for direct marketing purposes, the data
subject shall have the right to object at any time to processing of personal data concerning
him or her for such marketing. This applies to profiling to the extent that it is related to such
direct marketing. If the data subject objects to the Yoga with Paulina to the processing for
direct marketing purposes, the Yoga with Paulina will no longer process the personal data for
these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation,
to object to processing of personal data concerning him or her by the Yoga with Paulina for

scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of
the GDPR, unless the processing is necessary for the performance of a task carried out for
reasons of public interest.
In order to exercise the right to object, the data subject may contact any employee of the
Yoga with Paulina. In addition, the data subject is free in the context of the use of information
society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object
by automated means using technical specifications.
● h) Automated individual decision-making, including profiling
Each data subject shall have the right granted by the European legislator not to be subject to
a decision based solely on automated processing, including profiling, which produces legal
effects concerning him or her, or similarly significantly affects him or her, as long as the
decision (1) is not is necessary for entering into, or the performance of, a contract between
the data subject and a data controller, or (2) is not authorised by Union or Member State law
to which the controller is subject and which also lays down suitable measures to safeguard
the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data
subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the
data subject and a data controller, or (2) it is based on the data subject’s explicit consent, the
Yoga with Paulina shall implement suitable measures to safeguard the data subject’s rights
and freedoms and legitimate interests, at least the right to obtain human intervention on the
part of the controller, to express his or her point of view and contest the decision.
If the data subject wishes to exercise the rights concerning automated individual
decision-making, he or she may, at any time, contact any employee of the Yoga with Paulina.
● i) Right to withdraw data protection consent
Each data subject shall have the right granted by the European legislator to withdraw his or
her consent to processing of his or her personal data at any time.
If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any
time, contact any employee of the Yoga with Paulina.

12. Data protection provisions about the application and use of Facebook
On this website, the controller has integrated components of the enterprise Facebook. Facebook is a
social network.
A social network is a place for social meetings on the Internet, an online community, which usually
allows users to communicate with each other and interact in a virtual space. A social network may
serve as a platform for the exchange of opinions and experiences, or enable the Internet community
to provide personal or business-related information. Facebook allows social network users to include
the creation of private profiles, upload photos, and network through friend requests.
The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United
States. If a person lives outside of the United States or Canada, the controller is Facebook Ireland
Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
With each call-up to one of the individual pages of this Internet website, which is operated by the
controller and into which a Facebook component (Facebook plug-ins) was integrated, the web
browser on the information technology system of the data subject is automatically prompted to
download display of the corresponding Facebook component from Facebook through the Facebook
component. An overview of all the Facebook Plug-ins may be accessed under

https://developers.facebook.com/docs/plugins/. During the course of this technical procedure,
Facebook is made aware of what specific subsite of our website was visited by the data subject.
If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to
our website by the data subject—and for the entire duration of their stay on our Internet site—which
specific subsite of our Internet page was visited by the data subject. This information is collected
through the Facebook component and associated with the respective Facebook account of the data
subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g. the
“Like” button, or if the data subject submits a comment, then Facebook matches this information with
the personal Facebook user account of the data subject and stores the personal data.
Facebook always receives, through the Facebook component, information about a visit to our website
by the data subject, whenever the data subject is logged in at the same time on Facebook during the
time of the call-up to our website. This occurs regardless of whether the data subject clicks on the
Facebook component or not. If such a transmission of information to Facebook is not desirable for the
data subject, then he or she may prevent this by logging off from their Facebook account before a
call-up to our website is made.
The data protection guideline published by Facebook, which is available at
https://facebook.com/about/privacy/, provides information about the collection, processing and use of
personal data by Facebook. In addition, it is explained there what setting options Facebook offers to
protect the privacy of the data subject. In addition, different configuration options are made available
to allow the elimination of data transmission to Facebook. These applications may be used by the
data subject to eliminate a data transmission to Facebook.

13. Data protection provisions about the application and use of Google Analytics (with
anonymization function)
On this website, the controller has integrated the component of Google Analytics (with the anonymizer
function). Google Analytics is a web analytics service. Web analytics is the collection, gathering, and
analysis of data about the behaviour of visitors to websites. A web analysis service collects, inter alia,
data about the website from which a person has come (the so-called referrer), which sub-pages were
visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for
the optimization of a website and in order to carry out a cost-benefit analysis of Internet advertising.
The operator of the Google Analytics component is Google Ireland Limited, Gordon House, Barrow
Street, Dublin, D04 E5W5, Ireland.
For the web analytics through Google Analytics the controller uses the application “_gat.
_anonymizeIp”. By means of this application the IP address of the Internet connection of the data
subject is abridged by Google and anonymised when accessing our websites from a Member State of
the European Union or another Contracting State to the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyse the traffic on our website. Google uses
the collected data and information, inter alia, to evaluate the use of our website and to provide online
reports, which show the activities on our websites, and to provide other services concerning the use of
our Internet site for us.

Google Analytics places a cookie on the information technology system of the data subject. The
definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyse
the use of our website. With each call-up to one of the individual pages of this Internet site, which is
operated by the controller and into which a Google Analytics component was integrated, the Internet
browser on the information technology system of the data subject will automatically submit data
through the Google Analytics component for the purpose of online advertising and the settlement of
commissions to Google. During the course of this technical procedure, the enterprise Google gains
knowledge of personal information, such as the IP address of the data subject, which serves Google,
inter alia, to understand the origin of visitors and clicks, and subsequently create commission
settlements.
The cookie is used to store personal information, such as the access time, the location from which the
access was made, and the frequency of visits to our website by the data subject. With each visit to our
Internet site, such personal data, including the IP address of the Internet access used by the data
subject, will be transmitted to Google in the United States of America. These personal data are stored
by Google in the United States of America. Google may pass these personal data collected through
the technical procedure to third parties.
The data subject may, as stated above, prevent the setting of cookies through our website at any time
by means of a corresponding adjustment of the web browser used and thus permanently deny the
setting of cookies. Such an adjustment to the Internet browser used would also prevent Google
Analytics from setting a cookie on the information technology system of the data subject. In addition,
cookies already in use by Google Analytics may be deleted at any time via a web browser or other
software programs.
In addition, the data subject has the possibility of objecting to a collection of data that is generated by
Google Analytics, which is related to the use of this website, as well as the processing of this data by
Google and the chance to preclude any such. For this purpose, the data subject must download a
browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser
add-on tells Google Analytics through a JavaScript, that any data and information about the visits of
Internet pages may not be transmitted to Google Analytics. The installation of the browser add-ons is
considered an objection by Google. If the information technology system of the data subject is later
deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to
disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other
person who is attributable to their sphere of competence, or is disabled, it is possible to execute the
reinstallation or reactivation of the browser add-ons.
Further information and the applicable data protection provisions of Google may be retrieved under
https://www.google.com/intl/en/policies/privacy/ and under
http://www.google.com/analytics/terms/us.html. Google Analytics is further explained under the
following Link https://www.google.com/analytics/.

14. Data protection provisions about the application and use of Google-AdWords
On this website, the controller has integrated Google AdWords. Google AdWords is a service for
Internet advertising that allows the advertiser to place ads in Google search engine results and the
Google advertising network. Google AdWords allows an advertiser to pre-define specific keywords
with the help of which an ad on Google’s search results is only then displayed, when the user utilises
the search engine to retrieve a keyword-relevant search result. In the Google Advertising Network, the

ads are distributed on relevant web pages using an automatic algorithm, taking into account the
previously defined keywords.
The operating company of Google AdWords is Google Ireland Limited, Gordon House, Barrow Street,
Dublin, D04 E5W5, Ireland.
The purpose of Google AdWords is the promotion of our website by the inclusion of relevant
advertising on the websites of third parties and in the search engine results of the search engine
Google and an insertion of third-party advertising on our website.
If a data subject reaches our website via a Google ad, a conversion cookie is filed on the information
technology system of the data subject through Google. The definition of cookies is explained above. A
conversion cookie loses its validity after 30 days and is not used to identify the data subject. If the
cookie has not expired, the conversion cookie is used to check whether certain sub-pages, e.g, the
shopping cart from an online shop system, were called up on our website. Through the conversion
cookie, both Google and the controller can understand whether a person who reached an AdWords
ad on our website generated sales, that is, executed or cancelled a sale of goods.
The data and information collected through the use of the conversion cookie is used by Google to
create visit statistics for our website. These visit statistics are used in order to determine the total
number of users who have been served through AdWords ads to ascertain the success or failure of
each AdWords ad and to optimise our AdWords ads in the future. Neither our company nor other
Google AdWords advertisers receive information from Google that could identify the data subject.
The conversion cookie stores personal information, e.g. the Internet pages visited by the data subject.
Each time we visit our Internet pages, personal data, including the IP address of the Internet access
used by the data subject, is transmitted to Google in the United States of America. These personal
data are stored by Google in the United States of America. Google may pass these personal data
collected through the technical procedure to third parties.
The data subject may, at any time, prevent the setting of cookies by our website, as stated above, by
means of a corresponding setting of the Internet browser used and thus permanently deny the setting
of cookies. Such a setting of the Internet browser used would also prevent Google from placing a
conversion cookie on the information technology system of the data subject. In addition, a cookie set
by Google AdWords may be deleted at any time via the Internet browser or other software programs.
The data subject has a possibility of objecting to the interest based advertisement of Google.
Therefore, the data subject must access from each of the browsers in use the link
www.google.de/settings/ads and set the desired settings.
Further information and the applicable data protection provisions of Google may be retrieved under
https://www.google.com/intl/en/policies/privacy/.

15. Data protection provisions about the application and use of Instagram
On this website, the controller has integrated components of the service Instagram. Instagram is a
service that may be qualified as an audiovisual platform, which allows users to share photos and
videos, as well as disseminate such data in other social networks.

The operating company of the services offered by Instagram is Facebook Ireland Ltd., 4 Grand Canal
Square, Grand Canal Harbour, Dublin 2 Ireland.
With each call-up to one of the individual pages of this Internet site, which is operated by the controller
and on which an Instagram component (Insta button) was integrated, the Internet browser on the
information technology system of the data subject is automatically prompted to download a display of
the corresponding Instagram component of Instagram. During the course of this technical procedure,
Instagram becomes aware of what specific sub-page of our website was visited by the data subject.
If the data subject is logged in at the same time on Instagram, Instagram detects with every call-up to
our website by the data subject—and for the entire duration of their stay on our Internet site—which
specific sub-page of our Internet page was visited by the data subject. This information is collected
through the Instagram component and is associated with the respective Instagram account of the data
subject. If the data subject clicks on one of the Instagram buttons integrated on our website, then
Instagram matches this information with the personal Instagram user account of the data subject and
stores the personal data.
Instagram receives information via the Instagram component that the data subject has visited our
website provided that the data subject is logged in at Instagram at the time of the call to our website.
This occurs regardless of whether the person clicks on the Instagram button or not. If such a
transmission of information to Instagram is not desirable for the data subject, then he or she can
prevent this by logging off from their Instagram account before a call-up to our website is made.
Further information and the applicable data protection provisions of Instagram may be retrieved under
https://help.instagram.com/155833707900388 and https://www.instagram.com/about/legal/privacy/.

16. Data protection provisions about the application and use of YouTube
On this website, the controller has integrated components of YouTube. YouTube is an Internet video
portal that enables video publishers to set video clips and other users free of charge, which also
provides free viewing, review and commenting on them. YouTube allows you to publish all kinds of
videos, so you can access both full movies and TV broadcasts, as well as music videos, trailers, and
videos made by users via the Internet portal.
The operating company of YouTube is Google Ireland Limited, Gordon House, Barrow Street, Dublin,
D04 E5W5, Ireland.
With each call-up to one of the individual pages of this Internet site, which is operated by the controller
and on which a YouTube component (YouTube video) was integrated, the Internet browser on the
information technology system of the data subject is automatically prompted to download a display of
the corresponding YouTube component. Further information about YouTube may be obtained under
https://www.youtube.com/yt/about/en/. During the course of this technical procedure, YouTube and
Google gain knowledge of what specific sub-page of our website was visited by the data subject.
If the data subject is logged in on YouTube, YouTube recognizes with each call-up to a sub-page that
contains a YouTube video, which specific sub-page of our Internet site was visited by the data subject.
This information is collected by YouTube and Google and assigned to the respective YouTube
account of the data subject.

YouTube and Google will receive information through the YouTube component that the data subject
has visited our website, if the data subject at the time of the call to our website is logged in on
YouTube; this occurs regardless of whether the person clicks on a YouTube video or not. If such a
transmission of this information to YouTube and Google is not desirable for the data subject, the
delivery may be prevented if the data subject logs off from their own YouTube account before a call-up
to our website is made.
YouTube’s data protection provisions, available at https://www.google.com/intl/en/policies/privacy/,
provide information about the collection, processing and use of personal data by YouTube and
Google.

17. Payment Method: Data protection provisions about the use of PayPal as a payment
processor
On this website, the controller has integrated components of PayPal. PayPal is an online payment
service provider. Payments are processed via so-called PayPal accounts, which represent virtual
private or business accounts. PayPal is also able to process virtual payments through credit cards
when a user does not have a PayPal account. A PayPal account is managed via an email address,
which is why there are no classic account numbers. PayPal makes it possible to trigger online
payments to third parties or to receive payments. PayPal also accepts trustee functions and offers
buyer protection services.
The European operating company of PayPal is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24
Boulevard Royal L-2449, Luxemburg.
If the data subject chooses “PayPal” as the payment option in the online shop during the ordering
process, we automatically transmit the data of the data subject to PayPal. By selecting this payment
option, the data subject agrees to the transfer of personal data required for payment processing.
The personal data transmitted to PayPal is usually first name, last name, address, email address, IP
address, telephone number, mobile phone number, or other data necessary for payment processing.
The processing of the purchase contract also requires such personal data, which are in connection
with the respective order.
The transmission of the data is aimed at payment processing and fraud prevention. The controller will
transfer personal data to PayPal, in particular, if a legitimate interest in the transmission is given. The
personal data exchanged between PayPal and the controller for the processing of the data will be
transmitted by PayPal to economic credit agencies. This transmission is intended for identity and
creditworthiness checks.
PayPal will, if necessary, pass on personal data to affiliates and service providers or subcontractors to
the extent that this is necessary to fulfil contractual obligations or for data to be processed in the
order.
The data subject has the possibility to revoke consent for the handling of personal data at any time
from PayPal. A revocation shall not have any effect on personal data which must be processed, used
or transmitted in accordance with (contractual) payment processing.

The applicable data protection provisions of PayPal may be retrieved under
https://www.paypal.com/us/webapps/mpp/ua/privacy-full.

18. Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent
for a specific processing purpose. If the processing of personal data is necessary for the performance
of a contract to which the data subject is party, as is the case, for example, when processing
operations are necessary for the supply of goods or to provide any other service, the processing is
based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are
necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning
our products or services. Is our company subject to a legal obligation by which processing of personal
data is required, such as for the fulfilment of tax obligations, the processing is based on Art. 6(1) lit. c
GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests
of the data subject or of another natural person. This would be the case, for example, if a visitor were
injured in our company and his name, age, health insurance data or other vital information would have
to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art.
6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal
basis is used for processing operations which are not covered by any of the abovementioned legal
grounds, if processing is necessary for the purposes of the legitimate interests pursued by our
company or by a third party, except where such interests are overridden by the interests or
fundamental rights and freedoms of the data subject which require protection of personal data. Such
processing operations are particularly permissible because they have been specifically mentioned by
the European legislator. He considered that a legitimate interest could be assumed if the data subject
is a client of the controller (Recital 47 Sentence 2 GDPR).

19. The legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to
carry out our business in favour of the well-being of all our employees and the shareholders.

20. Period for which the personal data will be stored
The criteria used to determine the period of storage of personal data is the respective statutory
retention period. After expiration of that period, the corresponding data is routinely deleted, as long as
it is no longer necessary for the fulfilment of the contract or the initiation of a contract.

21. Provision of personal data as statutory or contractual requirement; Requirement
necessary to enter into a contract; Obligation of the data subject to provide the personal
data; possible consequences of failure to provide such data
We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also
result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be
necessary to conclude a contract that the data subject provides us with personal data, which must

subsequently be processed by us. The data subject is, for example, obliged to provide us with
personal data when our company signs a contract with him or her. The non-provision of the personal
data would have the consequence that the contract with the data subject could not be concluded.
Before personal data is provided by the data subject, the data subject must contact any employee.
The employee clarifies to the data subject whether the provision of the personal data is required by
law or contract or is necessary for the conclusion of the contract, whether there is an obligation to
provide the personal data and the consequences of non-provision of the personal data.

22. Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.
Developed by the specialists for LegalTech at Willing & Able that also developed the system for
contract electronics. The legal texts contained in our privacy policy generator have been provided and
published by Prof. Dr. h.c. Heiko Jonny Maniero from the German Association for Data Protection and
Christian Solmecke from WBS law.