We take the issue of data protection very seriously. Therefore, we only access personal data that is necessary to evaluate user flows, visit duration, entry and exit sources. The collected data is only stored as long as it is necessary for the purposes for which it is processed and is not sold to third parties.
As one of a few site operators, we respect the “do not track” function. With this, you as a user inform all page operators that you object to the creation of automatic user profiles. However, page operators do not have to comply with this request – The Salvation Army does this voluntarily.
1 Basic information on data processing and legal basis
1.1 This data protection declaration informs you about the type, scope and purpose of the processing of personal data within our online offer and the websites, functions and content connected to it (hereinafter jointly referred to as “online offer” or “website”). The data protection declaration applies irrespective of the domains, systems, platforms and devices (e.g. desktop or mobile) used to run the online offer.
1.2 The terms used, such as “personal data” or their “processing”, we refer to the definitions in Art. 4 of the Data Protection Regulation (DSGVO).
1.3 The personal data of users processed within the scope of this online offer includes inventory data (e.g., names and addresses of customers), contract data (e.g., services used), usage data (e.g., the websites visited on our online offer, interest in our products) and content data (e.g., entries in the contact form).
1.4 The term “user” includes all categories of persons affected by the data processing. They include our business partners, customers, interested parties and other visitors to our online offer. The terms used, such as “user”, are to be understood as gender-neutral.
1.5 We process users’ personal data only in compliance with the relevant data protection regulations. This means that the user’s data will only be processed if legal permission has been granted. I.e., in particular if the data processing is necessary for the provision of our contractual services (e.g. processing of orders) as well as online services, or is required by law, or if the users have given their consent, as well as on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation and security of our online offer within the meaning of Art. 6 Para. 1 lit. f. DSGVO, in particular in measuring reach, creating profiles for advertising and marketing purposes as well as collecting access data and using the services of third-party providers).
1.6 We would like to point out that the legal basis for the consents is Art. 6 para. 1 lit. a. and Art. 7 DSGVO, the legal basis for the processing for the fulfilment of our services and implementation of contractual measures is Art. 6 para. 1 lit. b. DSGVO, the legal basis for processing to fulfil our legal obligations Art. 6 para. 1 lit. c. DSGVO, and the legal basis for processing to protect our legitimate interests Art. 6 para. 1 lit. f. DSGVO is.
2. security measures
2.1 We take organisational, contractual and technical security measures in accordance with the state of the art to ensure that the provisions of the data protection laws are complied with and thus to protect the data processed by us against accidental or intentional manipulation, loss, destruction or against access by unauthorised persons.
2.2 The security measures include in particular the encrypted transmission of data between your browser and our server.
3. transfer of data to third parties and third-party providers
3.1 Data is only passed on to third parties within the framework of legal requirements. We only pass on users’ data to third parties if this is necessary, for example, on the basis of Art. 6 Para. 1 lit. b) DSGVO for contractual purposes or on the basis of legitimate interests pursuant to Art. 6 Para. 1 lit. f. DSGVO in the economic and effective operation of our business operations.
3.2 If we use subcontractors to provide our services, we take appropriate legal precautions and corresponding technical and organisational measures to ensure the protection of personal data in accordance with the relevant statutory provisions.
3.3 If content, tools or other means from other providers (hereinafter collectively referred to as “third party providers”) are used within the scope of this data protection declaration and their named registered office is located in a third country, it is to be assumed that a data transfer to the third party providers’ countries of domicile takes place. Third countries are countries in which the GDPR is not directly applicable law, i.e. basically countries outside the EU or the European Economic Area. The transfer of data to third countries takes place either if there is an adequate level of data protection, user consent or otherwise legal permission.
4 Provision of contractual services
4.1 We process inventory data (e.g., names and addresses as well as contact data of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services pursuant to Art. 6 para. 1 lit b. DSGVO.
4.2 In the context of registration and 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 the users in protection against misuse and other unauthorised use. In principle, this data is not passed on to third parties unless it is necessary for the pursuit of our claims or there is a legal obligation to do so in accordance with Art. 6 Para. 1 lit. c DSGVO.
4.3 We process usage data (e.g. the web pages visited on our online offer, interest in our products) and content data (e.g. entries in the contact form or user profile) for advertising purposes in a user profile, e.g. in order to display product information to users based on the services they have used to date.
5.1 When contacting us (via contact form or e-mail), the user’s details are processed for the purpose of handling the contact request and its processing in accordance with Art. 6 Para. 1 lit. b) DSGVO.
5.2 The user’s details may be stored in our customer relationship management system (“CRM system”) or comparable enquiry organisation.
5.3 We use the CRM system “OM”, from the provider Creativ Software AG, Unterdorfstrasse 83, 9443 Widnau, CH on the basis of our legitimate interests (efficient and fast processing of user enquiries). For this purpose, we have concluded a contract with Creativ Software AG with so-called standard contractual clauses, in which Creativ Software AG undertakes to process user data only in accordance with our instructions and to comply with the EU data protection level.
6. comments and contributions
6.1 When users leave comments or other contributions, their IP addresses are stored for 7 days on the basis of our legitimate interests as defined in Art. 6 Para. 1 lit. f. DSGVO are stored for 7 days.
6.2 This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.
7. collection of access data and log files
7.1 We collect data on every access to our website on the basis of our legitimate interests within the meaning of Art. 6 Para. 1 lit. f. DSGVO, we collect data on every 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 access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
7.2 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 is exempt from deletion until the respective incident has been finally clarified.
8 Cookies & Reach Measurement
8.1 Cookies are pieces of information that are transmitted from our web server or third-party web servers to the users’ web browsers and stored there for later retrieval. Cookies may be small files or other types of information storage.
8.2 We use “session cookies”, which are only stored for the duration of the current visit to our online presence. A randomly generated unique identification number, a so-called session ID, is stored in a session cookie. In addition, a cookie contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when you have finished using our online offer and close the browser.
8.4 If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
9 Google Analytics
9.2 Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
9.3 Google will use this information on our behalf for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. In doing so, pseudonymous user profiles of the users can be created from the processed data.
9.4 We use Google Analytics to display the advertisements placed within Google’s advertising services and those of its partners only to 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), which we transmit to Google (so-called “Remarketing Audiences” or “Google Analytics Audiences”). With the help of Remarketing Audiences, we also want to ensure that our advertisements correspond to the potential interest of the users and do not have a harassing effect.
9.5 We only use Google Analytics with IP anonymisation activated. This means that the IP address of users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
9.6 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 setting their browser software accordingly; users can also prevent the collection of the data generated by the cookie and related to their use of the online offer to Google as well as the processing of this data by Google by downloading and installing the browser plugin available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
9.7 You can find out more information about Google’s use of data, setting and objection options on Google’s websites: https://www.google.com/intl/de/policies/privacy/partners (“Data use by Google when you use our partners’ websites or apps”), http://www.google.com/policies/technologies/ads (“Data use for advertising purposes”), http://www.google.de/settings/ads (“Manage information Google uses to show you ads”).
10 Google Re/Marketing Services
10.1 We use on the basis of our legitimate interests (i.e. interest in the analysis, optimisation 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 Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).
10.2 Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
10.3 Google’s marketing services allow us to target advertisements for and on our website in order to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products in which he or she has shown interest 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 or she is interested in and which offers he or she 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 transmitted in full to a Google server in the USA and shortened there. The IP address will not be merged with user data within other Google offerings. The aforementioned information may also be combined by Google with such information from other sources. If the user subsequently visits other websites, he or she may be shown ads tailored to his or her interests.
10.4 The user’s data will be processed pseudonymously as part of the Google marketing services. This means that Google does not store and process the name or email address of the user, for example, but processes the relevant data in a cookie-related manner within pseudonymous user profiles. This means that from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymisation. The information collected by Google marketing services about users is transmitted to Google and stored on Google’s servers in the USA.
10.5 The Google marketing services we use include the online advertising programme “Google AdWords”. In the case of Google AdWords, each AdWords customer receives a different “conversion cookie”. Cookies can therefore not be tracked via the websites of AdWords customers. The information obtained with the help of the cookie is used to create conversion statistics for AdWords customers who have opted for conversion tracking. The 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, they do not receive any information with which users can be personally identified.
10.6 We may also use the “Google Optimizer” service. Google Optimizer allows us to track the effects of various changes to a website (e.g. changes to the input fields, design, etc.) as part of so-called “A/B testing”. For these testing purposes, cookies are placed on the users’ devices. Only pseudonymous data of the users will be processed.
10.7 Furthermore, we may use the “Google Tag Manager” to integrate and manage the Google analysis and marketing services on our website.
10.9 If you wish to object to interest-based advertising by Google marketing services, you can use the settings and opt-out options provided by Google: http://www.google.com/ads/preferences.
11 Facebook Social Plugins
11.1 We use social plugins based on our legitimate interests (i.e. interest in the analysis, optimisation 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 recognisable by one of the Facebook logos (white “f” on a 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/.
11.2 Facebook is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
11.3 When a user calls up a function of this online offer that contains such a plugin, his or her device establishes a direct connection with Facebook’s servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated into the online offer by the latter. In the process, user profiles 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 inform users according to our level of knowledge.
11.4 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 or her 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 their device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will find out and store his or her IP address. According to Facebook, only an anonymised IP address is stored in Germany.
11.6 If a user is a Facebook member and does not want Facebook to collect data about him or her via this online offer and link it to his or her membership data stored on Facebook, he or she must log out of Facebook and delete his or her 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 platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
12 Facebook, Custom Audiences and Facebook Marketing Services
12.1 Within our online offer, 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 due to our legitimate interests in the analysis, optimisation and economic operation of our online offer and for these purposes.
12.2 Facebook is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
12.3 With the help of the Facebook pixel, it is possible for Facebook 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 the users and do not have a harassing effect. With the help of the Facebook pixel, we can also track the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook ad (so-called “conversion”). 12.4.
12.4 The Facebook pixel is directly integrated by Facebook when our website is accessed and can save a so-called cookie, i.e. a small file, on your device. If you subsequently log in to Facebook or visit Facebook while logged in, your visit to our online offering will be noted in your profile. The data collected about you is anonymous for us, so it does not allow us to draw any conclusions about the identity of the user. However, the data is stored and processed by Facebook so that a connection to the respective user profile is possible and can be used by Facebook and for its own market research and advertising purposes. If we transmit data to Facebook for matching purposes, this data is encrypted locally on the browser and only then sent to Facebook via a secure https connection. This is done solely for the purpose of matching the data with the data encrypted in the same way by Facebook.
12.5 The processing of data by Facebook is carried out within the framework of Facebook’s data usage policy. Accordingly, general information 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 can be found in Facebook’s help section: https://www.facebook.com/business/help/651294705016616.
12.6 You can object to the collection by the Facebook Pixel and use of your data to display Facebook Ads. To adjust which types of ads are displayed to you within Facebook, you can go to the page set up by Facebook and follow the instructions there on the settings for usage-based advertising: https://www.facebook.com/settings?tab=ads. The settings are platform independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
13.1 The following information explains the contents of our newsletter and the registration, dispatch and statistical evaluation procedure as well as your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.
13.2 Content of the newsletter: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter “newsletter”) only with the consent of the recipients 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. In addition, our newsletters contain information about our products, offers, promotions and our company.
13.3 Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with the legal requirements. This includes the storage of the registration and confirmation time as well as the IP address. Any changes to your data stored with the dispatch service provider are also logged.
13.5 Furthermore, according to its own information, the dispatch service provider may use this data in pseudonymous form, i.e. without assigning it to a user, to optimise or improve its own services, e.g. to technically optimise the dispatch and presentation of the newsletter or for statistical purposes to determine which countries the recipients come from. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass it on to third parties.
13.6 Registration data: To register for the newsletter, it is sufficient to enter your e-mail address.
13.7 Statistical collection and analyses – The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file which is retrieved from the server of the dispatch service provider when the newsletter is opened. Within the scope of this retrieval, technical information, such as information on the browser and your system, as well as your IP address and the time of the retrieval are initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behaviour based on their 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 the individual newsletter recipients. However, it is neither our intention nor that of the dispatch service provider to observe individual users. The analyses serve us much more to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
13.8 The use of the dispatch service provider, the performance of the statistical surveys and analyses as well as the logging of the registration process are based on our legitimate interests pursuant to Art. 6 Para. 1 lit. f DSGVO. We are interested in the use of a user-friendly and secure newsletter system that serves our business interests and meets the expectations of the users.
13.9 Cancellation/revocation – You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. At the same time, your consent to the dispatch of the newsletter by the dispatch service provider and the statistical analyses will expire. Unfortunately, it is not possible to separately cancel the dispatch by the dispatch service provider or the statistical analysis. A link to cancel the newsletter can be found at the end of each newsletter. If users have only subscribed to the newsletter and cancelled this subscription, their personal data will be deleted.
14.1 Recording of user interaction by ConvertFlow
14.2 Collection of contact information via form through ConvertFlow.
Your contact data from the forms provided by ConvertFlow will be stored by ConvertFlow for the purpose of processing your request and in case of follow-up questions. The processing of the data entered by you in the form by ConvertFlow is thus exclusively based on your consent (Art. 6 para. 1 lit. a DSGVO).
14.3 You may revoke this consent at any time. For this purpose, an informal communication by e-mail to email@example.com is sufficient.
14.4 The legality of the data processing operations carried out until the revocation remains unaffected by the revocation. The data entered by you in the ConvertFlow forms will remain with The Salvation Army until you request us to delete it, revoke your consent to store it or the purpose for storing the data no longer applies (e.g. after processing your enquiry has been completed). Mandatory legal provisions – in particular retention periods – remain unaffected.
14.5 For the deletion of contact data that you have provided to us via a form provided by ConvertFlow, please read section the “Collection of contact data via form via ConvertFlow”.
15. integration of services and contents of third parties
15.1 We use content or service providers within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimisation 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, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content. We endeavour to use only such content whose respective providers only use the IP address to deliver 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 also be stored in cookies on the user’s device and may contain, among other things, technical information on the browser and operating system, referring websites, time of visit and other information on the use of our online offer, as well as being linked to such information from other sources.
15.2 The following presentation provides an overview of third-party providers and their content, together with links to their data protection declarations, which contain further information on the processing of data and, in part already mentioned here, options for objection (so-called opt-out):
If our customers use the payment services of third parties (e.g. PayPal or Sofortüberweisung), the terms and conditions and the data protection notices of the respective third party providers apply, which can be accessed within the respective websites or transaction applications.
16. rights of the users
16.1 Users have the right to obtain, on request and free of charge, information about the personal data we hold about them.
16.2 In addition, users have the right to rectify inaccurate data, restrict processing and delete their personal data, where applicable, to assert their rights to data portability and, in the event of the assumption of unlawful data processing, to lodge a complaint with the competent supervisory authority.
16.3 Users can also withdraw their consent, in principle with effect for the future.
17. deletion of data
The data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the user data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to user data that must be retained for reasons of commercial or tax law.
18 Right of objection
Users may object to the future processing of their personal data in accordance with the legal requirements at any time. The objection can be made in particular against the processing for purposes of direct advertising.
19 Changes to the data protection declaration
19.1 We reserve the right to change the data protection declaration in order to adapt it to changed legal situations or in the event of changes to the service and data processing. However, this only applies with regard to declarations on data processing. Insofar as user consent is required or components of the data protection declaration contain provisions of the contractual relationship with the users, the changes will only be made with the consent of the users.
19.2 Users are requested to inform themselves regularly about the content of the data protection declaration.