The responsible party within the meaning of the General Data Protection Regulation and other national data protection laws of the Member States and other data protection provisions is the:
MySecondEar Audiology Group GmbH
Regensburger Straße 5, 10777 Berlin
Tel: 030 81474953
Types of data processed:
- Inventory data (e.g., names, addresses). Contact data (e.g., email, phone numbers).
- Meta/communication data (e.g., device information, IP addresses)
- Content data (e.g., text input, photographs, videos).
- Payment data (e.g., bank details, payment history). Usage data (e.g., web pages visited, interest in content, access times).
- Contract data (e.g., subject matter of contract, term, customer category).
Processing of special categories of data (Article 9(1) of the GDPR):
Health-related data (e.g. hearing test, hearing history, data relating to the hearing organ) Categories of data subjects:
- Customers, prospective customers, visitors and users of the online offer, business partners.
- Visitors and users of the online offer.
Following, we also refer to the data subjects collectively as "Users"
Determination of processing
- Adjustment and fitting of hearing instruments. Provision of the online offer, its contents and store functions.
- Marketing, advertising and market research.
- Security measures.
- Providing contractual services, service and customer care.
- Adjustment and fitting of hearing instruments.
- Responding to contact requests and communicating with users.
1. Terms used
1.1 "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie. e.g. cookie) or to one or more special characteristics that are an expression of the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
1.2 Processing means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data.
1.3 "Controller" means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
2. Relevant legal basis
4. Security measures
4.1 We take security measures in accordance with Art. 32 DSGVO, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, appropriate technical and organizational measures to ensure a level of protection appropriate to the risk; The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access concerning you, input, disclosure, ensuring availability and their separation. Furthermore, we have established procedures to ensure the exercise of data subject rights, deletion of data and response to data compromise. Furthermore, we take into account the protection of personal data already in the development, or selection of hardware, software as well as procedures, in accordance with the principle of data protection by design of technology and by data protection-friendly default settings considered (Art. 25 DSGVO).
4.2. security measures include, in particular, the encrypted transmission of data between your browser and our server.
5. Disclosure and transmission of data
5.1. If we disclose data to other persons and companies (processors or third parties) in the course of our processing, you transmit to them or otherwise grant them access to the data, this is done only on the basis of a legal permission (eg if a transfer of data to third parties, such as payment service providers, according to Art. 6 para 1 lit. b DSGVO is necessary for the performance of the contract), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, hosting providers, tax, business and legal advisors, customer care, accounting, billing and similar services that allow us to efficiently and effectively fulfill our contractual obligations, administrative tasks and duties).
5.2 Insofar as we entrust third parties with the processing of data on the basis of a so-called "order processing agreement", this is done on the basis of Art. 28 DSGVO.
6. Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or do so in the context of using third-party services or disclosing, or transferring data to third parties, this will only be done if it is done in order to fulfill our (pre)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or allow the processing of data in a third country only if the special requirements of Art. 44 et seq. DSGVO are met. I.e. the processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").
7. Users' rights
7.1 You have the right to request confirmation as to whether data in question is being processed and to be informed about this data and to receive further information and a copy of the data in accordance with Art. 15 DSGVO.
7.2. you have according to. Art. 16 DSGVO the right to request the completion of the data concerning you or the correction of inaccurate data concerning you.
7.3. you have, in accordance with Art. 17 DSGVO, the right to request that data concerning you be deleted without undue delay, or alternatively, in accordance with Art. 18 DSGVO, to request restriction of the processing of the data.
7.4. you have the right to request that the data concerning you that you have provided to us be received in accordance with Article 20 of the GDPR and to request that it be transferred to other data controllers.
7.5. you also have the right to lodge a complaint with the competent supervisory authority pursuant to Art. 77 of the GDPR.
8. Right of withdrawal
You have the right to revoke given consents according to Art. 7 para. 3 DSGVO with effect for the future.
9. Right of objection
You may object at any time to the future processing of data concerning you in accordance with Article 21 of the GDPR. The objection may be made in particular against the processing for purposes of direct marketing.
10. Cookies and right to object to direct marketing
Cookies are small files that are stored on users' computers. Within the cookies, different information can be stored. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his visit within an online offer. More about our processing of cookies and your right to object can be found here.
11. Deletion of data
11.2. Germany: According to legal requirements, the storage takes place in particular for 6 years in accordance with § 257 para. 1 HGB (commercial books, inventories, opening balances, annual financial statements, commercial letters, accounting vouchers, etc.) and for 10 years in accordance with § 147 para. 1 AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc
12. Order processing in the online store and customer account
12.1 We process the data of our customers in the context of the ordering processes in our online store to enable them to select and order the selected products and services, as well as their payment and delivery, or execution.
12.2 The processed data includes inventory data, communication data, contract data, payment data and the data subjects are our customers, prospective customers and other business partners. The processing is carried out for the purpose of providing contractual services in the context of operating an online store, billing, delivery and customer services. Here we use session cookies for storing the shopping cart contents and permanent cookies for storing the login status.
12.3 The processing is based on Art. 6 para. 1 lit. b (execution of order transactions) and c (legally required archiving) DSGVO. In this context, the information marked as required is necessary for the justification and fulfillment of the contract. We disclose the data to third parties only in the context of delivery, payment or in the context of legal permissions and obligations to legal advisors and authorities. The data will be processed in third countries only if this is necessary for the performance of the contract (eg at the request of the customer for delivery or payment).
12.4 Users can create a user account, in particular by viewing their orders. As part of the registration process, the required mandatory information will be provided to users. User accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data with regard to the user account will be deleted, subject to their retention is necessary for commercial or tax reasons in accordance with Art. 6 para. 1 lit. c DSGVO. Information in the customer account remains until its deletion with subsequent archiving in the event of a legal obligation. It is incumbent on users to secure their data in the event of termination before the end of the contract.
12.5. In the context of registration and renewed registrations as well as use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as those of users in protection against abuse and other unauthorized use. A transfer 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 in accordance with Art. 6 para 1 lit. c DSGVO.
12.6. deletion takes place after the expiry of legal warranty and comparable obligations, the necessity of keeping the data is reviewed every three years; in the case of legal archiving obligations, deletion takes place after their expiry (end of commercial law (6 years) and tax law (10 years) retention obligation); information in the customer account remains until its deletion.
13. Business analyses and market research
13.1 In order to operate our business economically, to be able to recognize market trends, customer and user wishes, we analyze the data we have on business transactions, contracts, inquiries, etc.. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. DSGVO, whereby the data subjects include customers, interested parties, business partners, visitors and users of the online offer. The analyses are carried out for the purpose of business management evaluations, marketing and market research. In doing so, we may take into account the profiles of registered users with details of, for example, their purchase transactions. The analyses serve us for the increase of the user friendliness, the optimization of our offer and the business management. The analyses serve us alone and are not disclosed externally, unless it is anonymous analyses with aggregated values.
13.2 If these analyses or profiles are personal, they will be deleted or anonymized upon termination of the users, otherwise after two years from the conclusion of the contract. In all other respects, the overall business analyses and general tendency determinations are created anonymously whenever possible.
14. Credit assessment
14.1. If we step into advance performance (eg purchase on account), we reserve the right to safeguard the legitimate interests of an identity and credit information for the purpose of assessing the credit risk on the basis of mathematical-statistical methods of specialized service companies (credit agencies) to obtain.
14.2. in the context of the credit report, we transmit the following personal data of the customer (name, postal address, date of birth, information on the type of contract, bank details to the following credit agencies:
14.3 We process the information received from the credit agencies about the statistical probability of a payment default within the framework of an appropriate discretionary decision on the establishment, implementation and termination of the contractual relationship. We reserve the right, in the case of a negative result of the credit check, to refuse payment on account or other advance performance.
14.4 The decision as to whether we provide advance performance is made in accordance with Art. 22 DSGVO solely on the basis of an automated decision in individual cases, which our software makes on the basis of the information from the credit agency.
14.5. If we obtain explicit consent from you, the legal basis for the credit report and the transmission of the customer's data to the credit bureaus is the consent pursuant to Art. 6 para. 1 lit. a, 7 DSGVO. If no consent is obtained, our legitimate interests in the default security of their payment claim is the legal basis gem. Art. 6 para. 1 lit. f. DSGVO.
Checking the creditworthiness of a customer is permissible if there is otherwise a risk of non-payment, i.e. if the goods are delivered without payment having been received (i.e. if the customer chooses to purchase on account). No payment default threatens, however, if the customer chooses, for example, the prepayment option or the payment through third-party providers, such as Paypal.
14.6. On this website we use HubSpot for our online marketing activities. HubSpot is a software company from the USA with a branch in Ireland. Contact: HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, Phone: +353 1 5187500.
This is an integrated software solution that we use to cover various aspects of our online marketing. These include, among others:
Email marketing (newsletters as well as automated mailings, e.g. to provide downloads), social media publishing & reporting, reporting (e.g. traffic sources, accesses, etc.), contact management (e.g. user segmentation & CRM), landing pages and contact forms.
Further, to improve the user experience on our website, we use HubSpot's live chat service "Messages" (round chat icon at the bottom right of the screen) for sending and receiving messages on some subpages. Upon consent and use of this feature, the following data will be transmitted to HubSpot's servers:
- Content of all chat messages sent and received
- Context information (e.g. page where chat was used)
- Optional: e-mail address of the user (if provided by the user via chat function) The legal basis for the use of the services of Hubspot is Art. 6 I f DS-GVO - legitimate interest. Our legitimate interest in the use of this service is the optimization of our marketing measures and the improvement of our service quality on the website.
More information from HubSpot regarding EU data protection regulations"
If you generally do not want HubSpot to collect data, you can prevent cookies from being stored at any time by changing your browser settings accordingly or by using the following opt-out link: Opt-Out Link.
15. Contact Us and Customer Servic
15.1. When contacting us (via contact form or e-mail), the user's details are processed for the purpose of processing the contact request and its handling in accordance with Art. 6 para. 1 lit. b) DSGVO.
15.2. the user's details may be stored in our Customer Relationship Management System ("CRM System") or comparable inquiry organization.
15.3. the user's details are stored in the Amparex software (Amparex GmbH, Max-Lang-Straße 24, 70771 Leinfelden-Echterdingen).
15.3 We delete the requests if they are no longer necessary. We review the necessity every two years; requests from customers who have a customer account, we store permanently and refer to the information on the customer account for deletion. Furthermore, the statutory archiving obligations apply.
16. Collection of access data and log files
16.1 We collect on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO data about each access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful retrieval, browser type and version, the operating system of the user, referrer URL (the previously visited page), IP address and the requesting provider.
16.2 Log file information is stored for security reasons (e.g. for the clarification of abuse or fraud) for a maximum of seven days and then deleted. Data whose further storage is required for evidentiary purposes are excluded from deletion until the final clarification of the respective incident.
17. Online presences in social media
17.1 We maintain on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO online presences within social networks and platforms in order to communicate with the customers, prospects and users active there and to be able to inform them about our services there. When calling the respective networks and platforms, the terms and conditions and data processing policies of their respective operators.
17.2. we use Google Analytics to display the ads placed by within advertising services of Google and its partners, only to those users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the visited web pages), which we transmit to Google (so-called "Remarketing Audiences", 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 do not have a harassing effect.
18. Google Analytics
18.2 Google will use this information on our behalf for the purpose of evaluating the use of our online offer by users, compiling reports on the activities within this online offer and providing other services relating to the use of this online offer and internet usage to us. Thereby, pseudonymous usage profiles of the users can be created from the processed data.
18.3 We use Google Analytics only with IP anonymization enabled. This means that the IP address of users is shortened by Google within Member States of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address is transmitted to a Google server in the U.S. and shortened there.
18.4 The IP address transmitted by the user's browser will not be merged with other data from Google. Users can prevent the storage of cookies by selecting the appropriate settings on their browser software; users can also prevent the collection of data generated by the cookie and related to their use of the online offer to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
18.5. For more information about Google's data usage, settings and opt-out options, please visit Google's websites: https://www.google.com/intl/de/policies/privacy/partners ("Data usage by Google when you use our partners' websites or apps"), https://policies.google.com/technologies/ads ("Data use for advertising purposes"), https://adssettings.google.com/authenticated ("Manage information Google uses to serve ads to you").
19th Google Re/Marketing Services and LinkedIn Insight Tag
19.1. We use 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. DSGVO) the marketing and remarketing services (in short "Google marketing services") of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, ("Google").
19.2 Google marketing services allow us to display advertisements for and on our website in a more targeted manner in order to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products he or she was interested in on other websites, this is referred to as "remarketing". For these purposes, when our website and other websites on which Google marketing services are active are called up, a code is executed directly by Google and so-called (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). The cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which websites the user has visited, which content he is interested in and which offers he has clicked on, as well as technical information on the browser and operating system, referring websites, time of visit and other information on the use of the online offer. The IP address of the user is also recorded, whereby we inform Google Analytics that the IP address is shortened within Member States of the European Union or in other contracting states to the Agreement on the European Economic Area and only in exceptional cases is transferred in full to a Google server in the USA and shortened there. The IP address will not be merged with data of the user within other offers of Google. The aforementioned information may also be linked on the part of Google with such information from other sources. If the user subsequently visits other websites, the ads tailored to him can be displayed according to his interests.
19.3. the data of the users are processed pseudonymously within the Google marketing services. I.e. Google does not store and process, for example, the name or email address of the users, but processes the relevant data cookie-related within pseudonymous user profiles. I.e. from Google's perspective, 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 allowed 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.
19.4. The Google marketing services we use include, among others, the online advertising program "Google AdWords". In the case of Google AdWords, each AdWords customer receives a different "conversion cookie". Cookies can therefore not be tracked across the websites of AdWords customers. The information obtained using the cookie is used to create conversion statistics for AdWords customers who have opted in to conversion tracking. AdWords customers learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, you will not receive any information that personally identifies users.
19.7. Likewise, we may use the service "Google Optimizer". Google Optimizer allows us to track how various changes to a website (e.g. changes to the input fields, design, etc.) as part of so-called "A/B testing". Cookies are placed on users' devices for these testing purposes. Only pseudonymous data of the users are processed.
19.8. Furthermore, we may use the "Google Tag Manager" to integrate and manage Google analytics and marketing services into our website.
19.10. If you want to object to interest-based advertising by Google marketing services, you can use the settings and opt-out options provided by Google: https://adssettings.google.com/authenticated.
20. Facebook, Custom Audiences, and Facebook Marketing Services
20.1. Within our online offer, due to our legitimate interests in 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 a resident of the EU, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"), is used.
20.2 With the help of the Facebook pixel, it is possible for Facebook, on the one hand, to determine the visitors to our online offer as a target group for the display of advertisements (so-called "Facebook ads"). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Facebook (so-called "Custom Audiences"). With the help of the Facebook pixel, we also want to ensure that our Facebook ads correspond to the potential interest of users and do not have a harassing effect. With the help of the Facebook pixel, we can further track the effectiveness of the Facebook ads for statistical and market research purposes, in which we see whether users were redirected to our website after clicking on a Facebook ad (so-called "conversion").
20.3 The processing of data by Facebook takes place within the framework of Facebook's data use policy. Accordingly, general guidance on the display of Facebook ads, in Facebook's data usage policy: https://www.facebook.com/policy.php. Specific information and details about the Facebook pixel and how it works you can get in the help section of Facebook: https://www.facebook.com/business/help/651294705016616.
20.4 You can object to the collection by Facebook Pixel and the 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 there for the settings of usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are done in a platform-independent manner, which means that they are applied to all devices, such as desktop computers or mobile devices.
21. Facebook Social Plugins
21.1. We use 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. DSGVO) social plugins ("plugins") of the social network facebook.com, 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 recognizable 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 appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
21.2 When a user calls up a function of this online offer that contains such a plugin, his device establishes a direct connection with the servers of Facebook. The content of the plugin is transmitted by Facebook directly to the user's device and integrated by the latter into the online offer. In the process, usage profiles of the users can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore informs users according to our level of knowledge.
21.3 By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged into Facebook, Facebook can assign the visit to his Facebook account. If users interact with the plugins, for example by clicking the Like button or posting a comment, the corresponding information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will learn and store his or her IP address. According to Facebook, only an anonymized IP address is stored in Germany.
21.4. purpose and scope of data collection and further processing and use of data by Facebook, as well as the relevant rights and settings options to protect the privacy of users, can be found in the privacy notices of Facebook: https://www.facebook.com/about/privacy/.
21.5. 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 membership 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: https://www.facebook.com/settings?tab=ads or via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are made platform-independent, ie they are adopted for all devices, such as desktop computers or mobile devices.
22. Communication via mail, e-mail, fax or telephone
22.1 We use means of remote communication, such as mail, telephone or e-mail, for business processing and marketing purposes. In doing so, we process inventory data, address and contact data as well as contract data of customers, participants, interested parties and communication partners.
22.2 The processing is based on Art. 6 para. 1 lit. a, Art. 7 DSGVO, Art. 6 para. 1 lit. f DSGVO in conjunction with legal requirements for promotional communications. Contact is made only with the consent of the contact partners or within the scope of legal permissions and the processed data will be deleted as soon as they are not necessary and otherwise with objection / revocation or discontinuation of the authorization bases or legal archiving obligations.
23.1 With the following instructions, we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure as well as your objection rights. By subscribing to our newsletter, you agree to the receipt and the described procedures.
23.2. content of the newsletter: We send newsletters, e-mails and other electronic notifications with promotional information (hereinafter "newsletter") only with the consent of the recipient or a legal permission. Insofar as the contents of the Newsletter are specifically described in the context of a registration, they are decisive for the consent of the users. Incidentally, our newsletters contain information about our products, offers, promotions and our company.
23.3. double opt-in and logging: The registration for our newsletter takes place in a so-called double opt-in procedure. That is, you will receive after registration an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations to the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address. Likewise, the changes to your data stored at the shipping service provider are logged.
23.5. Insofar as we use a shipping service provider, the shipping service provider may, according to its own information, use this data in pseudonymous form, i.e. without attribution to a user, to optimize or improve its own services, e.g. to technically optimize the shipping and display of the newsletter or for statistical purposes to determine from which countries the recipients come. However, the shipping service provider does not use the data of our newsletter recipients to write to them themselves or to pass them on to third parties.
23.6. registration data: To sign up for the newsletter, all you need to do is provide your email address. Optionally, we ask you to specify a name, for the purpose of personal address in the newsletter.
23.7. performance measurement - The newsletter contains a so-called "web-beacon", i.e. a pixel-sized file that is retrieved when opening the newsletter from our server, or if we use a shipping service provider, from its server. In the course of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval are collected. This information is used for the technical improvement of the services based on the technical data or the target groups and your reading behavior based on the retrieval locations (which can be determined with the help of the IP address) or the access times. Statistical surveys also include determining whether newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the dispatch service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to you or to send different content according to the interests of our users.
23.8. Germany: The dispatch of the newsletter and the measurement of success are based on the consent of the recipients according to Art. 6 para. 1 lit. a, Art. 7 DSGVO in conjunction with § 7 para. 2 No. 3 UWG or on the basis of the legal permission according to § 7 para. 3 UWG.
23.9. Austria: The dispatch of the newsletter and the performance measurement are based on a consent of the recipients according to Art. 6 para 1 lit. a, Art. 7 DSGVO i.V.m § 107 para 2 TKG or on the basis of the legal permission according to § 107 para 2 u. 3 TKG.
23.10. The logging of the registration process is based on our legitimate interests pursuant to Art. 6 para 1 lit. f DSGVO and serves as proof of consent to receive the newsletter.
23.11. Newsletter recipients can cancel the receipt of our newsletter at any time, i.e. revoke your consents. You will find a link to cancel the newsletter at the end of each newsletter. At the same time, your consent to the performance measurement will expire. A separate cancellation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled. With the unsubscription from newsletter, the personal data will be deleted, unless their retention is legally required or justified, in which case their processing will be limited only to these exceptional purposes. In particular, we may store unsubscribed email addresses for up to three years based on our legitimate interests before deleting them for newsletter sending purposes, in order to be able to prove consent formerly given. The processing of this data is limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.
24. Integration of services and content of third parties
24.1. We use within our online offer on the basis of our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) to integrate content or services offered by third-party providers, such as videos or fonts (hereinafter uniformly referred to as "content"). This always requires that the third-party providers of this content are aware of the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the display of this content. We endeavor to use only such content whose respective providers use the IP address only for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may further be stored in cookies on the user's device and contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.
24.2 The following presentation provides an overview of third-party providers and their content, along with links to their privacy statements, which contain further information on the processing of data and, partly already mentioned here, objection options (so-called opt-out)
- If our customers use the payment services of third parties (eg PayPal or Sofortüberweisung), the terms and conditions and privacy notices of the respective third party providers, which are available within the respective websites, or transaction applications.
24.3. For remote maintenance of the hearing instruments, the apps and thus functions of the services of the providers listed below are used. Settings such as volume, program selection behavior, use of pre-processing algorithms or equalizer changes can be saved. No personal data is collected or passed on via the app. Non-personal data, such as frequency of use of the app, operating system, etc. are recorded by the manufacturers of the apps.
- Sonova, Business Unit Phonak, Laubisrütistrasse 28, 8712 Stäfa, Switzerland
24.4. personal and health-related data of the users are stored in the software Amparex (Amparex GmbH, Max-Lang-Straße 24, 70771 Leinfelden-Echterdingen).