privacy policy
This privacy policy explains the type, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online offering and the associated websites, functions and content as well as external online presences, such as our social media profiles (hereinafter jointly referred to as "online offering"). With regard to the terms used, such as "processing" or "controller", we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
responsible person
A Bowl of Compassion eV Michael Saatkamp Emkraft 5 44319 Dortmund Michael-saatkamp@gmx.de
Types of data processed:
– Inventory data (e.g. names, addresses). – Contact data (e.g. email, telephone numbers). – Content data (e.g. text entries, photographs, videos). – Usage data (e.g. websites visited, interest in content, access times). – Meta/communication data (e.g. device information, IP addresses).
categories of data subjects
Visitors and users of the online offer (hereinafter we refer to the data subjects collectively as “users”). Purpose of processing
– Provision of the online offer, its functions and contents. – Answering contact requests and communicating with users. – Security measures. – Reach measurement/marketing
Terms used
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “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. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and covers practically any handling of data.
‘Pseudonymisation’ means 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.
‘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.
The “controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others decides on the purposes and means of the processing of personal data.
"Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller. Relevant legal bases
In accordance with Art. 13 GDPR, we will inform you of the legal basis for our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 Para. 1 lit. a and Art. 7 GDPR, the legal basis for processing to fulfill our services and carry out contractual measures as well as answering inquiries is Art. 6 Para. 1 lit. b GDPR, the legal basis for processing to fulfill our legal obligations is Art. 6 Para. 1 lit. c GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 Para. 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 Para. 1 lit. d GDPR serves as the legal basis.
security measures
In accordance with Art. 32 GDPR, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk, 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.
The measures include in particular ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to it, input, transfer, ensuring availability and separation. Furthermore, we have set up procedures that ensure the exercise of data subject rights, deletion of data and response to data threats. Furthermore, we take the protection of personal data into account when developing or selecting hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings (Article 25 GDPR).
cooperation with processors and third parties
If, as part of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as payment service providers, is necessary to fulfill the contract in accordance with Art. 6 Para. 1 lit. b GDPR), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we commission third parties to process data on the basis of a so-called “order processing agreement”, this is done on the basis of Art. 28 GDPR.
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 if this occurs as part of the use of third-party services or disclosure or transmission of data to third parties, this will only occur if it is necessary to fulfil 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 only process or have data processed in a third country if the special requirements of Art. 44 ff. GDPR are met. This means that the processing takes place, for example, on the basis of special guarantees, such as the officially recognised determination of a data protection level corresponding to that of the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).
rights of the data subjects
You have the right to request confirmation as to whether or not data concerning you is being processed and to request information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.
According to Art. 16 GDPR, you have the right to request that the data concerning you be completed or that inaccurate data concerning you be corrected.
In accordance with Art. 17 GDPR, you have the right to request that the data in question be deleted immediately or, alternatively, to request that the processing of the data be restricted in accordance with Art. 18 GDPR.
You have the right to request that we receive the data concerning you that you have made available to us in accordance with Art. 20 GDPR and to request that it be transmitted to other responsible parties.
You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 GDPR.
right of withdrawal
You have the right to revoke consent granted in accordance with Art. 7 Para. 3 GDPR with effect for the future
right of objection
You can object to the future processing of data concerning you at any time in accordance with Art. 21 GDPR. The objection can be made in particular against processing for direct marketing purposes.
Cookies and the right to object to direct advertising
“Cookies” are small files that are saved on users’ computers. Different information can be saved within cookies. A cookie is primarily used to save information about a user (or the device on which the cookie is saved) during or after their visit to an online service. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes their browser. Such a cookie can store, for example, the contents of a shopping cart in an online shop or a login status. “Permanent” or “persistent” cookies are cookies that remain saved even after the browser is closed. For example, the login status can be saved if the user visits the site several days later. Likewise, the interests of the user can be saved in such a cookie and used for reach measurement or marketing purposes. “Third-party cookies” are cookies that are offered by providers other than the controller who operates the online service (otherwise, if they are only their cookies, they are referred to as “first-party cookies”).
We may use temporary and permanent cookies and explain this in our privacy policy.
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 service.
A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, cookies can be blocked by deactivating them in the browser settings. Please note that in this case, not all functions of this website may be available.
deletion of data
The data we process is deleted or restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this privacy policy, the data stored by us is deleted as soon as it is no longer required for its intended purpose and there are no statutory retention periods that prevent deletion. If the data is not deleted because it is required for other legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
According to legal requirements in Germany, storage takes place in particular for 10 years in accordance with Sections 147 Para. 1 AO, 257 Para. 1 No. 1 and 4, Para. 4 HGB (books, records, management reports, accounting documents, commercial books, documents relevant for taxation, etc.) and 6 years in accordance with Section 257 Para. 1 No. 2 and 3, Para. 4 HGB (commercial letters).
According to legal requirements in Austria, storage takes place in particular for 7 years in accordance with Section 132 Paragraph 1 BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, statements of income and expenditure, etc.), for 22 years in connection with real estate and for 10 years for documents in connection with electronically provided services, telecommunications, radio and television services that are provided to non-entrepreneurs in EU member states and for which the Mini One Stop Shop (MOSS) is used.
provision of our statutory and business-related services
We process the data of our members, supporters, interested parties, customers or other persons in accordance with Art. 6 Para. 1 lit. b. GDPR, provided that we offer them contractual services or act within the framework of an existing business relationship, e.g. with members, or are ourselves recipients of services and donations. In addition, we process the data of data subjects in accordance with Art. 6 Para. 1 lit. f. GDPR on the basis of our legitimate interests, e.g. when it comes to administrative tasks or public relations work.
The data processed here, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship. This generally includes inventory and master data of the persons (e.g. name, address, etc.), as well as contact details (e.g. email address, telephone, etc.), contract data (e.g. services used, content and information communicated, names of contact persons) and, if we offer paid services or products, payment data (e.g. bank details, payment history, etc.).
We delete data that is no longer required to fulfill our statutory and business purposes. This is determined according to the respective tasks and contractual relationships. In the case of commercial processing, we retain the data for as long as it may be relevant to the business transaction and with regard to any warranty or liability obligations. The necessity of retaining the data is reviewed every three years; otherwise, the statutory retention periods apply.
newsletter
With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures as well as your right of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.
Content of the newsletter: We only send newsletters, emails and other electronic notifications with advertising information (hereinafter "newsletter") with the consent of the recipient or with legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user's consent. Otherwise, our newsletters contain information about our services and us.
Double opt-in and logging: Registration for our newsletter is carried out using a so-called double opt-in process. This means that after registration you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register using someone else's email address. Registrations for the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation, as well as the IP address. Changes to your data stored by the shipping service provider are also logged.
Registration data: To register for the newsletter, it is sufficient to provide your email address. Optionally, we ask you to provide a name so that we can address you personally in the newsletter.
The newsletter is sent and its associated performance measurement is based on the consent of the recipient in accordance with Art. 6 Para. 1 lit. a, Art. 7 GDPR in conjunction with Section 7 Para. 2 No. 3 UWG or, if consent is not required, on the basis of our legitimate interests in direct marketing in accordance with Art. 6 Para. 1 lit. f. GDPR in conjunction with Section 7 Para. 3 UWG.
The registration process is logged on the basis of our legitimate interests in accordance with Art. 6 (1) (f) GDPR. Our interest is in using a user-friendly and secure newsletter system that serves our business interests and meets the expectations of users and also allows us to provide evidence of consent.
Cancellation/Revocation - You can cancel your subscription to our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We can store the unsubscribed email addresses for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous existence of consent is confirmed at the same time.
online presence in social media
We maintain online presences within social networks and platforms in order to communicate with customers, interested parties and users active there and to inform them about our services. When you access the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.
Unless otherwise stated in our privacy policy, we process users' data if they communicate with us within the social networks and platforms, e.g. by writing posts on our online presence or sending us messages.
Integration of third-party services and content
Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 Para. 1 lit. f. GDPR), we use content or service offerings from third-party providers within our online offering in order to integrate their content and services, such as videos or fonts (hereinafter referred to uniformly as “content”).
This always presupposes that the third-party providers of this content perceive the IP address of the user, since without the IP address they would not be able to send the content to their browser. The IP address is therefore required to display this content. We endeavor to only use 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 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.
YouTube
We embed videos from the “YouTube” platform provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.
Use of Facebook Social Plugins
Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offering within the meaning of Art. 6 Para. 1 lit. f. GDPR), we use social plugins (“plugins”) from 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 a blue tile, the terms “Like” or a “thumbs up” sign) or are marked with the addition “Facebook Social Plugin”. The list and appearance of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
If a user calls up a function of this website that contains such a plugin, their device establishes a direct connection to the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user's device and integrated into the website by the user. User profiles can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects using this plugin and therefore inform users according to our level of knowledge.
By integrating the plug-ins, Facebook receives the information that a user has accessed the corresponding page of the online offering. If the user is logged in to Facebook, Facebook can assign the visit to their Facebook account. When users interact with the plug-ins, for example by clicking the Like button or leaving a comment, the corresponding information is transmitted directly from their device to Facebook and stored there. If a user is not a member of Facebook, it is still possible that Facebook will find out and store their IP address. According to Facebook, only an anonymized IP address is stored in Germany.
The purpose and scope of data collection and the further processing and use of the data by Facebook as well as the related rights and setting options for protecting the privacy of users can be found in Facebook's privacy policy: https://www.facebook.com/about/privacy/.
If a user is a Facebook member and does not want Facebook to collect data about him or her via this online service and link it to his or her member data stored on Facebook, he or she must log out of Facebook and delete his or her cookies before using our online service. 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 website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
Functions and content of the Instagram service, offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, can be integrated into our online offering. This can include content such as images, videos or texts and buttons with which users can share content from this online offering within Instagram. If the users are members of the Instagram platform, Instagram can assign the access to the above-mentioned content and functions to the users' profiles there. Instagram's privacy policy: http://instagram.com/about/legal/privacy/.
Created with Datenschutz-Generator.de by RA Dr. Thomas Schwenke
Real Cookie Banner
We use the consent tool “Real Cookie Banner” to manage the cookies and similar technologies used (tracking pixels, web beacons, etc.) and related consents. You can find details on how “Real Cookie Banner” works at https://devowl.io/de/rcb/datenverarbeitung/.
The legal basis for the processing of personal data in this context is Art. 6 (1) (c) GDPR and Art. 6 (1) (f) GDPR. Our legitimate interest is the management of the cookies and similar technologies used and the related consents.
The provision of personal data is neither contractually required nor necessary for the conclusion of a contract. You are not obliged to provide the personal data. If you do not provide the personal data, we cannot manage your consents.
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