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    You are here: Home / Privacy Policy

    Privacy Policy

    Privacy Policy

    We are very delighted that you have shown interest in our enterprise. Data
    protection is of a particularly high priority for the management of the
    Stephens Media Group. The use of the Internet pages of the Stephens Media
    Group is possible without any indication of personal data; however, if a
    data subject wants to use special enterprise services via our website,
    processing of personal data could become necessary. If the processing of
    personal data is necessary and there is no statutory basis for such
    processing, we generally obtain consent from the data subject.

    The processing of personal data, such as the name, address, e-mail address,
    or telephone number of a data subject shall always be in line with the
    General Data Protection Regulation (GDPR), and in accordance with the
    country-specific data protection regulations applicable to the Stephens
    Media Group. By means of this data protection declaration, our enterprise
    would like to inform the general public of the nature, scope, and purpose of
    the personal data we collect, use and process. Furthermore, data subjects
    are informed, by means of this data protection declaration, of the rights to
    which they are entitled.

    As the controller, the Stephens Media Group has implemented numerous
    technical and organizational measures to ensure the most complete protection
    of personal data processed through this website. However, Internet-based
    data transmissions may in principle have security gaps, so absolute
    protection may not be guaranteed. For this reason, every data subject is
    free to transfer personal data to us via alternative means, e.g. by
    telephone.
    1. Definitions

    The data protection declaration of the Stephens Media Group is based on the
    terms used by the European legislator for the adoption of the General Data
    Protection Regulation (GDPR). Our data protection declaration should be
    legible and understandable for the general public, as well as our customers
    and business partners. To ensure this, we would like to first explain the
    terminology used.

    In this data protection declaration, we use, inter alia, the following
    terms:

    a) Personal data

    Personal data means any information relating to an identified or
    identifiable natural person (“data subject”). An identifiable natural person
    is one who can be identified, directly or indirectly, in particular by
    reference to an identifier such as a name, an identification number,
    location data, an online identifier or to one or more factors specific to
    the physical, physiological, genetic, mental, economic, cultural or social
    identity of that natural person.
    b) Data subject

    Data subject is any identified or identifiable natural person, whose
    personal data is processed by the controller responsible for the processing.
    c) Processing

    Processing is any operation or set of operations which is performed on
    personal data or on sets of personal data, whether or not by automated
    means, such as collection, recording, organisation, structuring, storage,
    adaptation or alteration, retrieval, consultation, use, disclosure by
    transmission, dissemination or otherwise making available, alignment or
    combination, restriction, erasure or destruction.
    d) Restriction of processing

    Restriction of processing is the marking of stored personal data with
    the aim of limiting their processing in the future.
    e) Profiling

    Profiling means any form of automated processing of personal data
    consisting of the use of personal data to evaluate certain personal aspects
    relating to a natural person, in particular to analyse or predict aspects
    concerning that natural person’s performance at work, economic situation,
    health, personal preferences, interests, reliability, behaviour, location or
    movements.
    f) Pseudonymisation

    Pseudonymisation is the processing of personal data in such a manner
    that the personal data can no longer be attributed to a specific data
    subject without the use of additional information, provided that such
    additional information is kept separately and is subject to technical and
    organisational measures to ensure that the personal data are not attributed
    to an identified or identifiable natural person.
    g) Controller or controller responsible for the processing

    Controller or controller responsible for the processing is the natural
    or legal person, public authority, agency or other body which, alone or
    jointly with others, determines the purposes and means of the processing of
    personal data; where the purposes and means of such processing are
    determined by Union or Member State law, the controller or the specific
    criteria for its nomination may be provided for by Union or Member State
    law.
    h) Processor

    Processor is a natural or legal person, public authority, agency or
    other body which processes personal data on behalf of the controller.
    i) Recipient

    Recipient is a natural or legal person, public authority, agency or
    another body, to which the personal data are disclosed, whether a third
    party or not. However, public authorities which may receive personal data in
    the framework of a particular inquiry in accordance with Union or Member
    State law shall not be regarded as recipients; the processing of those data
    by those public authorities shall be in compliance with the applicable data
    protection rules according to the purposes of the processing.
    j) Third party

    Third party is a natural or legal person, public authority, agency or
    body other than the data subject, controller, processor and persons who,
    under the direct authority of the controller or processor, are authorised to
    process personal data.
    k) Consent

    Consent of the data subject is any freely given, specific, informed and
    unambiguous indication of the data subject’s wishes by which he or she, by a
    statement or by a clear affirmative action, signifies agreement to the
    processing of personal data relating to him or her.

    2. Name and Address of the controller

    Controller for the purposes of the General Data Protection Regulation
    (GDPR), other data protection laws applicable in Member states of the
    European Union and other provisions related to data protection is:

    Stephens Media Group

    2448 E. 81st Suite 5500

    74137 Tulsa

    USA

    Phone: 9184922660

    Email: support@smgok.com

    Website: smgok.com

    3. Cookies

    The Internet pages of the Stephens Media Group use cookies. Cookies are text
    files that are stored in a computer system via an Internet browser.

    Many Internet sites and servers use cookies. Many cookies contain a
    so-called cookie ID. A cookie ID is a unique identifier of the cookie. It
    consists of a character string through which Internet pages and servers can
    be assigned to the specific Internet browser in which the cookie was stored.
    This allows visited Internet sites and servers to differentiate the
    individual browser of the dats subject from other Internet browsers that
    contain other cookies. A specific Internet browser can be recognized and
    identified using the unique cookie ID.

    Through the use of cookies, the Stephens Media Group can provide the users
    of this website with more user-friendly services that would not be possible
    without the cookie setting.

    By means of a cookie, the information and offers on our website can be
    optimized with the user in mind. Cookies allow us, as previously mentioned,
    to recognize our website users. The purpose of this recognition is to make
    it easier for users to utilize our website. The website user that uses
    cookies, e.g. does not have to enter access data each time the website is
    accessed, because this is taken over by the website, and the cookie is thus
    stored on the user’s computer system. Another example is the cookie of a
    shopping cart in an online shop. The online store remembers the articles
    that a customer has placed in the virtual shopping cart via a cookie.

    The data subject may, at any time, prevent the setting of cookies through
    our website by means of a corresponding setting of the Internet browser
    used, and may thus permanently deny the setting of cookies. Furthermore,
    already set cookies may be deleted at any time via an Internet browser or
    other software programs. This is possible in all popular Internet browsers.
    If the data subject deactivates the setting of cookies in the Internet
    browser used, not all functions of our website may be entirely usable.
    4. Collection of general data and information

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

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

    The data subject has the possibility to register on the website of the
    controller with the indication of personal data. Which personal data are
    transmitted to the controller is determined by the respective input mask
    used for the registration. The personal data entered by the data subject are
    collected and stored exclusively for internal use by the controller, and for
    his own purposes. The controller may request transfer to one or more
    processors (e.g. a parcel service) that also uses personal data for an
    internal purpose which is attributable to the controller.

    By registering on the website of the controller, the IP address—assigned by
    the Internet service provider (ISP) and used by the data subject—date, and
    time of the registration are also stored. The storage of this data takes
    place against the background that this is the only way to prevent the misuse
    of our services, and, if necessary, to make it possible to investigate
    committed offenses. Insofar, the storage of this data is necessary to secure
    the controller. This data is not passed on to third parties unless there is
    a statutory obligation to pass on the data, or if the transfer serves the
    aim of criminal prosecution.

    The registration of the data subject, with the voluntary indication of
    personal data, is intended to enable the controller to offer the data
    subject contents or services that may only be offered to registered users
    due to the nature of the matter in question. Registered persons are free to
    change the personal data specified during the registration at any time, or
    to have them completely deleted from the data stock of the controller.

    The data controller shall, at any time, provide information upon request to
    each data subject as to what personal data are stored about the data
    subject. In addition, the data controller shall correct or erase personal
    data at the request or indication of the data subject, insofar as there are
    no statutory storage obligations. The entirety of the controller’s employees
    are available to the data subject in this respect as contact persons.
    6. Subscription to our newsletters

    On the website of the Stephens Media Group, users are given the opportunity
    to subscribe to our enterprise’s newsletter. The input mask used for this
    purpose determines what personal data are transmitted, as well as when the
    newsletter is ordered from the controller.

    The Stephens Media Group informs its customers and business partners
    regularly by means of a newsletter about enterprise offers. The enterprise’s
    newsletter may only be received by the data subject if (1) the data subject
    has a valid e-mail address and (2) the data subject registers for the
    newsletter shipping. A confirmation e-mail will be sent to the e-mail
    address registered by a data subject for the first time for newsletter
    shipping, for legal reasons, in the double opt-in procedure. This
    confirmation e-mail is used to prove whether the owner of the e-mail address
    as the data subject is authorized to receive the newsletter.

    During the registration for the newsletter, we also store the IP address of
    the computer system assigned by the Internet service provider (ISP) and used
    by the data subject at the time of the registration, as well as the date and
    time of the registration. The collection of this data is necessary in order
    to understand the (possible) misuse of the e-mail address of a data subject
    at a later date, and it therefore serves the aim of the legal protection of
    the controller.

    The personal data collected as part of a registration for the newsletter
    will only be used to send our newsletter. In addition, subscribers to the
    newsletter may be informed by e-mail, as long as this is necessary for the
    operation of the newsletter service or a registration in question, as this
    could be the case in the event of modifications to the newsletter offer, or
    in the event of a change in technical circumstances. There will be no
    transfer of personal data collected by the newsletter service to third
    parties. The subscription to our newsletter may be terminated by the data
    subject at any time. The consent to the storage of personal data, which the
    data subject has given for shipping the newsletter, may be revoked at any
    time. For the purpose of revocation of consent, a corresponding link is
    found in each newsletter. It is also possible to unsubscribe from the
    newsletter at any time directly on the website of the controller, or to
    communicate this to the controller in a different way.
    7. Newsletter-Tracking

    The newsletter of the Stephens Media Group contains so-called tracking
    pixels. A tracking pixel is a miniature graphic embedded in such e-mails,
    which are sent in HTML format to enable log file recording and analysis.
    This allows a statistical analysis of the success or failure of online
    marketing campaigns. Based on the embedded tracking pixel, the Stephens
    Media Group may see if and when an e-mail was opened by a data subject, and
    which links in the e-mail were called up by data subjects.

    Such personal data collected in the tracking pixels contained in the
    newsletters are stored and analyzed by the controller in order to optimize
    the shipping of the newsletter, as well as to adapt the content of future
    newsletters even better to the interests of the data subject. These personal
    data will not be passed on to third parties. Data subjects are at any time
    entitled to revoke the respective separate declaration of consent issued by
    means of the double-opt-in procedure. After a revocation, these personal
    data will be deleted by the controller. The Stephens Media Group
    automatically regards a withdrawal from the receipt of the newsletter as a
    revocation.
    8. Contact possibility via the website

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

    The data controller shall process and store the personal data of the data
    subject only for the period necessary to achieve the purpose of storage, or
    as far as this is granted by the European legislator or other legislators in
    laws or regulations to which the controller is subject to.

    If the storage purpose is not applicable, or if a storage period prescribed
    by the European legislator or another competent legislator expires, the
    personal data are routinely blocked or erased in accordance with legal
    requirements.
    10. Rights of the data subject

    a) Right of confirmation

    Each data subject shall have the right granted by the European
    legislator to obtain from the controller the confirmation as to whether or
    not personal data concerning him or her are being processed. If a data
    subject wishes to avail himself of this right of confirmation, he or she
    may, at any time, contact any employee of the controller.
    b) Right of access

    Each data subject shall have the right granted by the European
    legislator to obtain from the controller free information about his or her
    personal data stored at any time and a copy of this information.
    Furthermore, the European directives and regulations grant the data subject
    access to the following information:
    the purposes of the processing;
    the categories of personal data concerned;
    the recipients or categories of recipients to whom the personal data
    have been or will be disclosed, in particular recipients in third countries
    or international organisations;
    where possible, the envisaged period for which the personal data
    will be stored, or, if not possible, the criteria used to determine that
    period;
    the existence of the right to request from the controller
    rectification or erasure of personal data, or restriction of processing of
    personal data concerning the data subject, or to object to such processing;
    the existence of the right to lodge a complaint with a supervisory
    authority;
    where the personal data are not collected from the data subject, any
    available information as to their source;
    the existence of automated decision-making, including profiling,
    referred to in Article 22(1) and (4) of the GDPR and, at least in those
    cases, meaningful information about the logic involved, as well as the
    significance and envisaged consequences of such processing for the data
    subject.

    Furthermore, the data subject shall have a right to obtain information
    as to whether personal data are transferred to a third country or to an
    international organisation. Where this is the case, the data subject shall
    have the right to be informed of the appropriate safeguards relating to the
    transfer.

    If a data subject wishes to avail himself of this right of access, he or
    she may, at any time, contact any employee of the controller.
    c) Right to rectification

    Each data subject shall have the right granted by the European
    legislator to obtain from the controller without undue delay the
    rectification of inaccurate personal data concerning him or her. Taking into
    account the purposes of the processing, the data subject shall have the
    right to have incomplete personal data completed, including by means of
    providing a supplementary statement.

    If a data subject wishes to exercise this right to rectification, he or
    she may, at any time, contact any employee of the controller.
    d) Right to erasure (Right to be forgotten)

    Each data subject shall have the right granted by the European
    legislator to obtain from the controller the erasure of personal data
    concerning him or her without undue delay, and the controller shall have the
    obligation to erase personal data without undue delay where one of the
    following grounds applies, as long as the processing is not necessary:
    The personal data are no longer necessary in relation to the
    purposes for which they were collected or otherwise processed.
    The data subject withdraws consent to which the processing is based
    according to point (a) of Article 6(1) of the GDPR, or point (a) of Article
    9(2) of the GDPR, and where there is no other legal ground for the
    processing.
    The data subject objects to the processing pursuant to Article 21(1)
    of the GDPR and there are no overriding legitimate grounds for the
    processing, or the data subject objects to the processing pursuant to
    Article 21(2) of the GDPR.
    The personal data have been unlawfully processed.
    The personal data must be erased for compliance with a legal
    obligation in Union or Member State law to which the controller is subject.
    The personal data have been collected in relation to the offer of
    information society services referred to in Article 8(1) of the GDPR.

    If one of the aforementioned reasons applies, and a data subject wishes
    to request the erasure of personal data stored by the Stephens Media Group,
    he or she may, at any time, contact any employee of the controller. An
    employee of Stephens Media Group shall promptly ensure that the erasure
    request is complied with immediately.

    Where the controller has made personal data public and is obliged
    pursuant to Article 17(1) to erase the personal data, the controller, taking
    account of available technology and the cost of implementation, shall take
    reasonable steps, including technical measures, to inform other controllers
    processing the personal data that the data subject has requested erasure by
    such controllers of any links to, or copy or replication of, those personal
    data, as far as processing is not required. An employees of the Stephens
    Media Group will arrange the necessary measures in individual cases.
    e) Right of restriction of processing

    Each data subject shall have the right granted by the European
    legislator to obtain from the controller restriction of processing where one
    of the following applies:
    The accuracy of the personal data is contested by the data subject,
    for a period enabling the controller to verify the accuracy of the personal
    data.
    The processing is unlawful and the data subject opposes the erasure
    of the personal data and requests instead the restriction of their use
    instead.
    The controller no longer needs the personal data for the purposes of
    the processing, but they are required by the data subject for the
    establishment, exercise or defence of legal claims.
    The data subject has objected to processing pursuant to Article
    21(1) of the GDPR pending the verification whether the legitimate grounds of
    the controller override those of the data subject.

    If one of the aforementioned conditions is met, and a data subject
    wishes to request the restriction of the processing of personal data stored
    by the Stephens Media Group, he or she may at any time contact any employee
    of the controller. The employee of the Stephens Media Group will arrange the
    restriction of the processing.
    f) Right to data portability

    Each data subject shall have the right granted by the European
    legislator, to receive the personal data concerning him or her, which was
    provided to a controller, in a structured, commonly used and
    machine-readable format. He or she shall have the right to transmit those
    data to another controller without hindrance from the controller to which
    the personal data have been provided, as long as the processing is based on
    consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of
    Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article
    6(1) of the GDPR, and the processing is carried out by automated means, as
    long as the processing is not necessary for the performance of a task
    carried out in the public interest or in the exercise of official authority
    vested in the controller.

    Furthermore, in exercising his or her right to data portability pursuant
    to Article 20(1) of the GDPR, the data subject shall have the right to have
    personal data transmitted directly from one controller to another, where
    technically feasible and when doing so does not adversely affect the rights
    and freedoms of others.

    In order to assert the right to data portability, the data subject may
    at any time contact any employee of the Stephens Media Group.
    g) Right to object

    Each data subject shall have the right granted by the European
    legislator to object, on grounds relating to his or her particular
    situation, at any time, to processing of personal data concerning him or
    her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This
    also applies to profiling based on these provisions.

    The Stephens Media Group shall no longer process the personal data in
    the event of the objection, unless we can demonstrate compelling legitimate
    grounds for the processing which override the interests, rights and freedoms
    of the data subject, or for the establishment, exercise or defence of legal
    claims.

    If the Stephens Media Group processes personal data for direct marketing
    purposes, the data subject shall have the right to object at any time to
    processing of personal data concerning him or her for such marketing. This
    applies to profiling to the extent that it is related to such direct
    marketing. If the data subject objects to the Stephens Media Group to the
    processing for direct marketing purposes, the Stephens Media Group will no
    longer process the personal data for these purposes.

    In addition, the data subject has the right, on grounds relating to his
    or her particular situation, to object to processing of personal data
    concerning him or her by the Stephens Media Group for scientific or
    historical research purposes, or for statistical purposes pursuant to
    Article 89(1) of the GDPR, unless the processing is necessary for the
    performance of a task carried out for reasons of public interest.

    In order to exercise the right to object, the data subject may contact
    any employee of the Stephens Media Group. In addition, the data subject is
    free in the context of the use of information society services, and
    notwithstanding Directive 2002/58/EC, to use his or her right to object by
    automated means using technical specifications.
    h) Automated individual decision-making, including profiling

    Each data subject shall have the right granted by the European
    legislator not to be subject to a decision based solely on automated
    processing, including profiling, which produces legal effects concerning him
    or her, or similarly significantly affects him or her, as long as the
    decision (1) is not is necessary for entering into, or the performance of, a
    contract between the data subject and a data controller, or (2) is not
    authorised by Union or Member State law to which the controller is subject
    and which also lays down suitable measures to safeguard the data subject’s
    rights and freedoms and legitimate interests, or (3) is not based on the
    data subject’s explicit consent.

    If the decision (1) is necessary for entering into, or the performance
    of, a contract between the data subject and a data controller, or (2) it is
    based on the data subject’s explicit consent, the Stephens Media Group shall
    implement suitable measures to safeguard the data subject’s rights and
    freedoms and legitimate interests, at least the right to obtain human
    intervention on the part of the controller, to express his or her point of
    view and contest the decision.

    If the data subject wishes to exercise the rights concerning automated
    individual decision-making, he or she may, at any time, contact any employee
    of the Stephens Media Group.
    i) Right to withdraw data protection consent

    Each data subject shall have the right granted by the European
    legislator to withdraw his or her consent to processing of his or her
    personal data at any time.

    If the data subject wishes to exercise the right to withdraw the
    consent, he or she may, at any time, contact any employee of the Stephens
    Media Group.

    11. Data protection provisions about the application and use of Facebook

    On this website, the controller has integrated components of the enterprise
    Facebook. Facebook is a social network.

    A social network is a place for social meetings on the Internet, an online
    community, which usually allows users to communicate with each other and
    interact in a virtual space. A social network may serve as a platform for
    the exchange of opinions and experiences, or enable the Internet community
    to provide personal or business-related information. Facebook allows social
    network users to include the creation of private profiles, upload photos,
    and network through friend requests.

    The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo
    Park, CA 94025, United States. If a person lives outside of the United
    States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal
    Square, Grand Canal Harbour, Dublin 2, Ireland.

    With each call-up to one of the individual pages of this Internet website,
    which is operated by the controller and into which a Facebook component
    (Facebook plug-ins) was integrated, the web browser on the information
    technology system of the data subject is automatically prompted to download
    display of the corresponding Facebook component from Facebook through the
    Facebook component. An overview of all the Facebook Plug-ins may be accessed
    under https://developers.facebook.com/docs/plugins/. During the course of
    this technical procedure, Facebook is made aware of what specific sub-site
    of our website was visited by the data subject.

    If the data subject is logged in at the same time on Facebook, Facebook
    detects with every call-up to our website by the data subject—and for the
    entire duration of their stay on our Internet site—which specific sub-site
    of our Internet page was visited by the data subject. This information is
    collected through the Facebook component and associated with the respective
    Facebook account of the data subject. If the data subject clicks on one of
    the Facebook buttons integrated into our website, e.g. the “Like” button, or
    if the data subject submits a comment, then Facebook matches this
    information with the personal Facebook user account of the data subject and
    stores the personal data.

    Facebook always receives, through the Facebook component, information about
    a visit to our website by the data subject, whenever the data subject is
    logged in at the same time on Facebook during the time of the call-up to our
    website. This occurs regardless of whether the data subject clicks on the
    Facebook component or not. If such a transmission of information to Facebook
    is not desirable for the data subject, then he or she may prevent this by
    logging off from their Facebook account before a call-up to our website is
    made.

    The data protection guideline published by Facebook, which is available at
    https://facebook.com/about/privacy/, provides information about the
    collection, processing and use of personal data by Facebook. In addition, it
    is explained there what setting options Facebook offers to protect the
    privacy of the data subject. In addition, different configuration options
    are made available to allow the elimination of data transmission to
    Facebook. These applications may be used by the data subject to eliminate a
    data transmission to Facebook.
    12. Data protection provisions about the application and use of Google
    AdSense

    On this website, the controller has integrated Google AdSense. Google
    AdSense is an online service which allows the placement of advertising on
    third-party sites. Google AdSense is based on an algorithm that selects
    advertisements displayed on third-party sites to match with the content of
    the respective third-party site. Google AdSense allows an interest-based
    targeting of the Internet user, which is implemented by means of generating
    individual user profiles.

    The operating company of Google’s AdSense component is Alphabet Inc., 1600
    Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

    The purpose of Google’s AdSense component is the integration of
    advertisements on our website. Google AdSense places a cookie on the
    information technology system of the data subject. The definition of cookies
    is explained above. With the setting of the cookie, Alphabet Inc. is enabled
    to analyze the use of our website. With each call-up to one of the
    individual pages of this Internet site, which is operated by the controller
    and into which a Google AdSense component is integrated, the Internet
    browser on the information technology system of the data subject will
    automatically submit data through the Google AdSense component for the
    purpose of online advertising and the settlement of commissions to Alphabet
    Inc. During the course of this technical procedure, the enterprise Alphabet
    Inc. gains knowledge of personal data, such as the IP address of the data
    subject, which serves Alphabet Inc., inter alia, to understand the origin of
    visitors and clicks and subsequently create commission settlements.

    The data subject may, as stated above, prevent the setting of cookies
    through our website at any time by means of a corresponding adjustment of
    the web browser used and thus permanently deny the setting of cookies. Such
    an adjustment to the Internet browser used would also prevent Alphabet Inc.
    from setting a cookie on the information technology system of the data
    subject. Additionally, cookies already in use by Alphabet Inc. may be
    deleted at any time via a web browser or other software programs.

    Furthermore, Google AdSense also uses so-called tracking pixels. A tracking
    pixel is a miniature graphic that is embedded in web pages to enable a log
    file recording and a log file analysis through which a statistical analysis
    may be performed. Based on the embedded tracking pixels, Alphabet Inc. is
    able to determine if and when a website was opened by a data subject, and
    which links were clicked on by the data subject. Tracking pixels serve,
    inter alia, to analyze the flow of visitors on a website.

    Through Google AdSense, personal data and information—which also includes
    the IP address, and is necessary for the collection and accounting of the
    displayed advertisements—is transmitted to Alphabet Inc. in the United
    States of America. These personal data will be stored and processed in the
    United States of America. The Alphabet Inc. may disclose the collected
    personal data through this technical procedure to third parties.

    Google AdSense is further explained under the following link
    https://www.google.com/intl/en/adsense/start/.
    13. Data protection provisions about the application and use of Google
    Analytics (with anonymization function)

    On this website, the controller has integrated the component of Google
    Analytics (with the anonymizer function). Google Analytics is a web
    analytics service. Web analytics is the collection, gathering, and analysis
    of data about the behavior of visitors to websites. A web analysis service
    collects, inter alia, data about the website from which a person has come
    (the so-called referrer), which sub-pages were visited, or how often and for
    what duration a sub-page was viewed. Web analytics are mainly used for the
    optimization of a website and in order to carry out a cost-benefit analysis
    of Internet advertising.

    The operator of the Google Analytics component is Google Inc., 1600
    Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States.

    For the web analytics through Google Analytics the controller uses the
    application “_gat. _anonymizeIp”. By means of this application the IP
    address of the Internet connection of the data subject is abridged by Google
    and anonymised when accessing our websites from a Member State of the
    European Union or another Contracting State to the Agreement on the European
    Economic Area.

    The purpose of the Google Analytics component is to analyze the traffic on
    our website. Google uses the collected data and information, inter alia, to
    evaluate the use of our website and to provide online reports, which show
    the activities on our websites, and to provide other services concerning the
    use of our Internet site for us.

    Google Analytics places a cookie on the information technology system of the
    data subject. The definition of cookies is explained above. With the setting
    of the cookie, Google is enabled to analyze the use of our website. With
    each call-up to one of the individual pages of this Internet site, which is
    operated by the controller and into which a Google Analytics component was
    integrated, the Internet browser on the information technology system of the
    data subject will automatically submit data through the Google Analytics
    component for the purpose of online advertising and the settlement of
    commissions to Google. During the course of this technical procedure, the
    enterprise Google gains knowledge of personal information, such as the IP
    address of the data subject, which serves Google, inter alia, to understand
    the origin of visitors and clicks, and subsequently create commission
    settlements.

    The cookie is used to store personal information, such as the access time,
    the location from which the access was made, and the frequency of visits of
    our website by the data subject. With each visit to our Internet site, such
    personal data, including the IP address of the Internet access used by the
    data subject, will be transmitted to Google in the United States of America.
    These personal data are stored by Google in the United States of America.
    Google may pass these personal data collected through the technical
    procedure to third parties.

    The data subject may, as stated above, prevent the setting of cookies
    through our website at any time by means of a corresponding adjustment of
    the web browser used and thus permanently deny the setting of cookies. Such
    an adjustment to the Internet browser used would also prevent Google
    Analytics from setting a cookie on the information technology system of the
    data subject. In addition, cookies already in use by Google Analytics may be
    deleted at any time via a web browser or other software programs.

    In addition, the data subject has the possibility of objecting to a
    collection of data that are generated by Google Analytics, which is related
    to the use of this website, as well as the processing of this data by Google
    and the chance to preclude any such. For this purpose, the data subject must
    download a browser add-on under the link
    https://tools.google.com/dlpage/gaoptout and install it. This browser add-on
    tells Google Analytics through a JavaScript, that any data and information
    about the visits of Internet pages may not be transmitted to Google
    Analytics. The installation of the browser add-ons is considered an
    objection by Google. If the information technology system of the data
    subject is later deleted, formatted, or newly installed, then the data
    subject must reinstall the browser add-ons to disable Google Analytics. If
    the browser add-on was uninstalled by the data subject or any other person
    who is attributable to their sphere of competence, or is disabled, it is
    possible to execute the reinstallation or reactivation of the browser
    add-ons.

    Further information and the applicable data protection provisions of Google
    may be retrieved under https://www.google.com/intl/en/policies/privacy/ and
    under http://www.google.com/analytics/terms/us.html. Google Analytics is
    further explained under the following Link
    https://www.google.com/analytics/.
    14. Data protection provisions about the application and use of
    Google-AdWords

    On this website, the controller has integrated Google AdWords. Google
    AdWords is a service for Internet advertising that allows the advertiser to
    place ads in Google search engine results and the Google advertising
    network. Google AdWords allows an advertiser to pre-define specific keywords
    with the help of which an ad on Google’s search results only then displayed,
    when the user utilizes the search engine to retrieve a keyword-relevant
    search result. In the Google Advertising Network, the ads are distributed on
    relevant web pages using an automatic algorithm, taking into account the
    previously defined keywords.

    The operating company of Google AdWords is Google Inc., 1600 Amphitheatre
    Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

    The purpose of Google AdWords is the promotion of our website by the
    inclusion of relevant advertising on the websites of third parties and in
    the search engine results of the search engine Google and an insertion of
    third-party advertising on our website.

    If a data subject reaches our website via a Google ad, a conversion cookie
    is filed on the information technology system of the data subject through
    Google. The definition of cookies is explained above. A conversion cookie
    loses its validity after 30 days and is not used to identify the data
    subject. If the cookie has not expired, the conversion cookie is used to
    check whether certain sub-pages, e.g, the shopping cart from an online shop
    system, were called up on our website. Through the conversion cookie, both
    Google and the controller can understand whether a person who reached an
    AdWords ad on our website generated sales, that is, executed or canceled a
    sale of goods.

    The data and information collected through the use of the conversion cookie
    is used by Google to create visit statistics for our website. These visit
    statistics are used in order to determine the total number of users who have
    been served through AdWords ads to ascertain the success or failure of each
    AdWords ad and to optimize our AdWords ads in the future. Neither our
    company nor other Google AdWords advertisers receive information from Google
    that could identify the data subject.

    The conversion cookie stores personal information, e.g. the Internet pages
    visited by the data subject. Each time we visit our Internet pages, personal
    data, including the IP address of the Internet access used by the data
    subject, is transmitted to Google in the United States of America. These
    personal data are stored by Google in the United States of America. Google
    may pass these personal data collected through the technical procedure to
    third parties.

    The data subject may, at any time, prevent the setting of cookies by our
    website, as stated above, by means of a corresponding setting of the
    Internet browser used and thus permanently deny the setting of cookies. Such
    a setting of the Internet browser used would also prevent Google from
    placing a conversion cookie on the information technology system of the data
    subject. In addition, a cookie set by Google AdWords may be deleted at any
    time via the Internet browser or other software programs.

    The data subject has a possibility of objecting to the interest based
    advertisement of Google. Therefore, the data subject must access from each
    of the browsers in use the link www.google.de/settings/ads and set the
    desired settings.

    Further information and the applicable data protection provisions of Google
    may be retrieved under https://www.google.com/intl/en/policies/privacy/.
    15. Data protection provisions about the application and use of YouTube

    On this website, the controller has integrated components of YouTube.
    YouTube is an Internet video portal that enables video publishers to set
    video clips and other users free of charge, which also provides free
    viewing, review and commenting on them. YouTube allows you to publish all
    kinds of videos, so you can access both full movies and TV broadcasts, as
    well as music videos, trailers, and videos made by users via the Internet
    portal.

    The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San
    Bruno, CA 94066, UNITED STATES. The YouTube, LLC is a subsidiary of Google
    Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.

    With each call-up to one of the individual pages of this Internet site,
    which is operated by the controller and on which a YouTube component
    (YouTube video) was integrated, the Internet browser on the information
    technology system of the data subject is automatically prompted to download
    a display of the corresponding YouTube component. Further information about
    YouTube may be obtained under https://www.youtube.com/yt/about/en/. During
    the course of this technical procedure, YouTube and Google gain knowledge of
    what specific sub-page of our website was visited by the data subject.

    If the data subject is logged in on YouTube, YouTube recognizes with each
    call-up to a sub-page that contains a YouTube video, which specific sub-page
    of our Internet site was visited by the data subject. This information is
    collected by YouTube and Google and assigned to the respective YouTube
    account of the data subject.

    YouTube and Google will receive information through the YouTube component
    that the data subject has visited our website, if the data subject at the
    time of the call to our website is logged in on YouTube; this occurs
    regardless of whether the person clicks on a YouTube video or not. If such a
    transmission of this information to YouTube and Google is not desirable for
    the data subject, the delivery may be prevented if the data subject logs off
    from their own YouTube account before a call-up to our website is made.

    YouTube’s data protection provisions, available at
    https://www.google.com/intl/en/policies/privacy/, provide information about
    the collection, processing and use of personal data by YouTube and Google.
    16. Payment Method: Data protection provisions about the use of PayPal as a
    payment processor

    On this website, the controller has integrated components of PayPal. PayPal
    is an online payment service provider. Payments are processed via so-called
    PayPal accounts, which represent virtual private or business accounts.
    PayPal is also able to process virtual payments through credit cards when a
    user does not have a PayPal account. A PayPal account is managed via an
    e-mail address, which is why there are no classic account numbers. PayPal
    makes it possible to trigger online payments to third parties or to receive
    payments. PayPal also accepts trustee functions and offers buyer protection
    services.

    The European operating company of PayPal is PayPal (Europe) S.à.r.l. & Cie.
    S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg.

    If the data subject chooses “PayPal” as the payment option in the online
    shop during the ordering process, we automatically transmit the data of the
    data subject to PayPal. By selecting this payment option, the data subject
    agrees to the transfer of personal data required for payment processing.

    The personal data transmitted to PayPal is usually first name, last name,
    address, email address, IP address, telephone number, mobile phone number,
    or other data necessary for payment processing. The processing of the
    purchase contract also requires such personal data, which are in connection
    with the respective order.

    The transmission of the data is aimed at payment processing and fraud
    prevention. The controller will transfer personal data to PayPal, in
    particular, if a legitimate interest in the transmission is given. The
    personal data exchanged between PayPal and the controller for the processing
    of the data will be transmitted by PayPal to economic credit agencies. This
    transmission is intended for identity and creditworthiness checks.

    PayPal will, if necessary, pass on personal data to affiliates and service
    providers or subcontractors to the extent that this is necessary to fulfill
    contractual obligations or for data to be processed in the order.

    The data subject has the possibility to revoke consent for the handling of
    personal data at any time from PayPal. A revocation shall not have any
    effect on personal data which must be processed, used or transmitted in
    accordance with (contractual) payment processing.

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

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

    Where the processing of personal data is based on Article 6(1) lit. f GDPR
    our legitimate interest is to carry out our business in favor of the
    well-being of all our employees and the shareholders.
    19. Period for which the personal data will be stored

    The criteria used to determine the period of storage of personal data is the
    respective statutory retention period. After expiration of that period, the
    corresponding data is routinely deleted, as long as it is no longer
    necessary for the fulfillment of the contract or the initiation of a
    contract.
    20. Provision of personal data as statutory or contractual requirement;
    Requirement necessary to enter into a contract; Obligation of the data
    subject to provide the personal data; possible consequences of failure to
    provide such data

    We clarify that the provision of personal data is partly required by law
    (e.g. tax regulations) or can also result from contractual provisions (e.g.
    information on the contractual partner). Sometimes it may be necessary to
    conclude a contract that the data subject provides us with personal data,
    which must subsequently be processed by us. The data subject is, for
    example, obliged to provide us with personal data when our company signs a
    contract with him or her. The non-provision of the personal data would have
    the consequence that the contract with the data subject could not be
    concluded. Before personal data is provided by the data subject, the data
    subject must contact any employee. The employee clarifies to the data
    subject whether the provision of the personal data is required by law or
    contract or is necessary for the conclusion of the contract, whether there
    is an obligation to provide the personal data and the consequences of
    non-provision of the personal data.
    21. Existence of automated decision-making

    As a responsible company, we do not use automatic decision-making or
    profiling.

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