Contents
Welcome to Aloma Online Marketing. This document informs about the publisher as well as the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offers and the associated websites, functions and content as well as external online presences, such as our social media profile on (hereinafter jointly referred to as “online offer”). 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).
Scope
The information on this page is valid and applicable to all online offers operated by Aloma Online Marketing on its own responsibility. This includes all websites, web applications, social media presences, blogs and other digital platforms that are marked by appropriate provider notices and refer to this document.
Imprint
Responsibility
Aloma Online Marketing
Inh. Dipl.-Ing. (FH) Tobias Sasse
Reeshoop 5
22926 Ahrensburg (Germany)
E-mail: info@aloma.de
Company type: sole proprietorship
VAT ID: DE262813014
Information about a professional liability insurance acc. § 2 para. 1 No. 11 DL-InfoV:
Hiscox SA Insurance
Arnulfstrasse 31
80636 Munich
There is worldwide insurance coverage. Insofar as it is not possible for the insurer for legal reasons to provide contractually owed services abroad (in particular in the case of so-called non-admitted countries), these benefits must be provided to the policyholder at the policyholder’s registered office. In this case, only the policyholder himself is entitled to the provision of benefits.
Online Dispute Resolution
The EU Commission provides a platform for out-of-court dispute resolution. This gives consumers the opportunity to initially settle disputes in connection with their online order out of court.
The dispute resolution platform can be found here: https://ec.europa.eu/consumers/odr/
We are not obliged to participate in a dispute settlement procedure before a consumer arbitration board and are generally not willing to do so.
Privacy Policy
Types of data processed:
– Inventory data (e.g., names, addresses)
– Contact details (e.g., email, phone numbers)
– Content data (e.g., text input, photographs, videos)
– Usage data (e.g., web pages visited, interest in content, access times).
– Meta/communication data (e.g., device information, IP addresses)
Categories of persons impacted
Visitors and users of the online offer (hereinafter we also refer to the data subjects collectively as “users” or “visitors”).
Processing purpose
– Provision of the online offer, its functions and contents
– Responding to contact requests and communicating with users
– Establishing the contact of the users with our clients
– Security measures
– Reach measurement/marketing
Terminology used
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) 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 upon Personal Data, whether or not by automatic means. The term is broad and encompasses virtually any handling of data.
“Pseudonymization” means the processing of personal data in such a way 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 organizational measures which ensure that the personal data are not attributed to an identified or identifiable natural person;
“Profiling” means any automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location;
The term “controller” refers to 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.
“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 inform you about the legal basis of 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 for the fulfilment of our services and implementation of contractual measures as well as answering inquiries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing to fulfil our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing to safeguard 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 make it necessary to process personal data, Art. 6 (1) lit. d GDPR serves as the legal basis.
Security measures
We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk in accordance with Article 32 of the GDPR, taking into account the state of the art, the costs of implementation 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, entry into, disclosure of, assurance of availability of and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, deletion of data, and response to data compromise. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings ( Art. 25 GDPR).
Cooperation with processors and third parties
If, in the course of our processing, we disclose data to other persons and companies (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 to payment service providers, is required for the performance of the contract pursuant to Art. 6 (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 with the processing of 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 is done in the context of using third-party services or disclosing or transferring data to third parties, this will only be done if it is done to fulfill our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or allow the processing of data in a third country only if the special requirements of Art. 44 et seq. GDPR are met. This means, for example, that processing takes place on the basis of special guarantees, such as the officially recognized determination of a level of data protection that corresponds to that of the EU (e.g., for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).
Rights of the data subjects
You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with Art. 15 GDPR.
In accordance with Art. 16 GDPR, you have the right to request the completion of data impacting you or the correction of incorrect data impacting you.
In accordance with Article 17 of the GDPR, you have the right to demand that the data in question be deleted without delay, or alternatively, in accordance with Article 18 of the GDPR, to demand restriction of the processing of the data.
You have the right to request to receive the data impacting you that you have provided to us in accordance with Article 20 of the GDPR and to request its transfer to other data controllers.
You also have the right to lodge a complaint with the competent supervisory authority pursuant to Art. 77 GDPR.
Right of withdrawal
You have the right to revoke given consents according to Art. 7 para. 3 GDPR with effect for the future
Right of objection
You may object to the future processing of data relating to you in accordance with Art. 21 GDPR at any time. The objection can be made in particular against the processing for purposes of direct advertising.
You may object to the processing of your personal data for advertising and data analysis purposes. You can inform us about your objection to advertising using the contact details given in the imprint.
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 site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/ . Furthermore, the storage of cookies can be achieved by means of their deactivation in the browser settings. Please note that not all functions of our online offers may then be used.
Cookie objection
Detailed information about the use of cookies on this website can be found in the cookie notice. Detailed information about the use of cookies on our other online offers can be found on the respective website. You can view and manage your consent in the cookie notices of the respective online offer.
Deletion of data
The data we process will be deleted or its processing restricted in accordance with Articles 17 and 18 of the GDPR. Unless expressly stated in this privacy policy, 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 data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.
According to legal requirements in Germany, the storage takes place in particular for 10 years in accordance with §§ 147 Abs. 1 AO, 257 Abs. 1 No. 1 and 4, Abs. 4 HGB (books, records, management reports, accounting vouchers, commercial books, for taxation relevant documents, etc.) and 6 years in accordance with § 257 Abs. 1 No. 2 and 3, Abs. 4 HGB (commercial letters).
According to legal requirements in Austria, storage is carried out in particular for 7 years in accordance with Section 132 (1) BAO (accounting records, vouchers/invoices, accounts, receipts, business papers, statement of income and expenses, etc.), for 22 years in connection with real property and for 10 years for records in connection with electronically provided services, telecommunications, radio and television services provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.
Hosting
The hosting services used by us serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services, which we use for the purpose of operating our online offers.
In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to our online offers on the basis of our legitimate interests in an efficient and secure provision of our online offers acc. Kind. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of order processing contract).
Collection of access data and log files
We and our hosting provider collect data on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR data about every access to the server on which our services are located (so-called server log files). This data is used for technical monitoring of the server and defense against harmful actions (e.g. DDOS, hacking, spamming). 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.
Anonymized log file information is stored for a maximum of 30 days and then automatically deleted. They are used for manual investigation of harmful actions and technical malfunctions.
Detailed log data, the storage of which is required for direct danger prevention, is stored for a period of 7 days and then automatically deleted. They are used for the automatic detection and defense against harmful actions to ensure the smooth and failure-free operation of the website.
Administration, financial accounting, office organization, contact management
We process data within the framework of administrative tasks as well as organization of our operations, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are impacted by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The cancellation of the data with regard to contractual services and contractual communication corresponds to the data mentioned in these processing activities.
We disclose or transfer data to the tax authorities, consultants, such as tax advisors or auditors, as well as other fee offices and payment service providers.
Furthermore, we store information on suppliers, event organizers and other business partners on the basis of our business interests, e.g. for the purpose of contacting them at a later date. We store this data, which is mostly company-related, permanently.
Registration function
Users can create a user account. As part of the registration process, the required mandatory information is provided to users and processed on the basis of Art. 6 (1) lit. b GDPR for the purpose of providing the user account. The processed data includes in particular the login information (name, password as well as an e-mail address). The data entered during registration will be used for the purposes of using the user account and its purpose.
Users may be notified of information relevant to their user account, such as technical changes, by email. If users have terminated their user account, their data relating to the user account will be deleted, except in the case of a legal obligation to retain data. It is the responsibility of the users to back up their data before the end of the contract if the contract has been terminated. We are entitled to irretrievably delete all of the user’s data stored during the term of the contract.
In the course of using our registration and login functions as well as the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as those of users in protection against misuse and other unauthorized use. In principle, this data will not be passed on to third parties, unless it is necessary for the pursuit of our claims or there is a legal obligation to do so pursuant to Art. 6 para. 1 lit. c. GDPR. The IP addresses are anonymized or deleted after 7 days at the latest.
Contact forms on behalf
In some cases, users are offered contact forms to third parties. Such contact forms are operated by us on behalf of advertisers. The client and recipient are clearly identified in the form. He will receive the message immediately by e-mail to an address provided by him for this purpose. All data entered into such forms will be stored by us for a maximum of 7 days to protect against loss or misuse.
Matomo
For statistical evaluation and dynamic delivery of advertising, we use a local Matomo installation on our websites. That’s an open source tool for web analytics. Matomo does not transmit data to servers that are outside of our control. Matomo is disabled when you visit our website. Only if you actively consent, your usage behavior will be recorded anonymously.
Matomo uses so-called cookies. These are text files that are stored on your computer and make it possible by means of Matomo to analyze the use of its website.uses so-called cookies. For this purpose, the information about usage obtained by the cookie is transmitted to Matomo and stored so that usage behavior can be evaluated. Your IP address is anonymized immediately; thus you remain anonymous as a user. The information generated by the cookie about your use of our websites will not be passed on to third parties.
Sharing features
Our websites occasionally use privacy-secure sharing buttons. These do not transmit data to third parties.
Zoho
We use various services provided by Zoho Corporation (Zoho), a provider of cloud software solutions, to administer and optimize our website and the services offered on it. Zoho Corporation is headquartered in the United States and has offices in the European Union and other countries. For more information about Zoho, see https://www.zoho.com. Zoho is certified under the EU-US Privacy Shield Framework, which means that Zoho takes appropriate data protection measures in accordance with EU regulations. We use the EU services of the German Zoho Corporation GmbH.
Zoho’s privacy policy can be found at https://www.zoho.com/privacy.html.
Zoho products used and their purposes
The Zoho products we use include, but are not limited to, Zoho CRM, Zoho Forms, Zoho Marketing Automation and Zoho SalesIQ. These products allow us to manage customer data and interactions, embed online forms and content on our website, improve our customer service, run marketing campaigns and analyze and develop the user experience on our website.
Storage and transmission of data
Zoho stores your personal information in secure data centers within the European Union and the United States. The transfer of data between the EU and the USA takes place in compliance with the EU-US Privacy Shield Framework, which ensures adequate data protection.
Sub-processors
Zoho uses sub-processors to perform certain tasks related to the processing of personal data. For a list of sub-processors used by Zoho, see https://www.zoho.com/privacy/sub-processors.html.
Google Services
With your permission, our websites integrate services from Google to improve website functionality, reach more people or generate revenue. These are services of Google LLC., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
Google’s Privacy Policy: https://www.google.com/policies/privacy/
Deactivate Google’s data collection (opt-out): https://adssettings.google.com/authenticated
Google Advertising Services
Our websites use Google services (Ads, Adsense, Tag Manager) temporarily and only with consent to display and integrate advertisements. Google’s advertising services use cookies. These are files whose storage in your web browser allows Google to analyze the data of your use of our website. In addition, Google’s advertising services also use web beacons, invisible graphics that allow Google to analyze clicks on our websites, traffic on them and similar information.
The information obtained via cookies and web beacons, your IP address and the delivery of advertising formats are transmitted to a Google server located in the USA and stored there. Google may transfer this collected information to third parties if this is required by law or if Google commissions third parties to process the data. However, Google will merge your IP address together with the other stored data.
By making the appropriate settings on your Internet browser, you can prevent the aforementioned cookies from being stored by you. As a result, however, there is the possibility that the contents of our websites can no longer be used to the same extent. When using our websites, you can consent to the processing of data about you by Google in the manner and for the purposes set out above by consenting to marketing purposes.
Google’s Privacy Policy: https://www.google.com/policies/privacy/
Deactivate Google’s data collection (opt-out): https://adssettings.google.com/authenticated
Our website uses advertising services from Facebook from time to time and only with your consent. (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland)
To measure success, we use the Facebook pixel – JavaScript code that loads a collection of functions that allow Facebook to track your user actions, especially if you came to our website via Facebook advertising. For example, if you purchase something on our website or achieve another advertising objective, the Facebook pixel will run. This happens selectively, not with every page view. Facebook stores your action on our website in one or more cookies. These cookies enable Facebook to compare your user data (customer data such as IP address, user ID) with the data of your Facebook account. Then Facebook deletes this data again.
The data collected is not visible to us and can only be used in the context of advertising. If you use Facebook yourself and are logged in there, Facebook will merge this data.
With the help of Facebook pixels, our advertising measures can be better tailored to your wishes and interests. In this way, Facebook users (if they have allowed personalized advertising) get to see suitable advertising. This makes it easier for us to attract new visitors and advertise more cost-effectively. Facebook also uses the data for its own purposes.
Facebook Privacy Policy: https://www.facebook.com/policy.php
Awin
Our websites occasionally and exclusively with the consent of the users use the advertising network of Awin (www.awin.com) to display and integrate advertisements. Awin uses techniques such as cookies, JavaScript tags and fingerprinting. The information obtained in this way, your IP address and the delivery of advertising formats are transmitted to an Awin server and stored there. Awin may share this collected information with third parties if required to do so by law or if Awin engages third parties to process the data.
By making the appropriate settings on your Internet browser, you can prevent the aforementioned cookies from being stored by you. As a result, however, there is the possibility that the contents of our websites can no longer be used to the same extent. By using our websites, you consent to the processing of data about you by Awin in the manner and for the purposes set out above.
Awin Privacy Policy: https://www.awin.com/de/datenschutzerklarung
Security and Antispam
On our websites we use either the plugin WordFence or WP Cerber Security to ensure a high level of security against viruses, hackers and spammers. Both plugins help us protect our website from harmful attacks, malware, unauthorized access and spam by collecting, analyzing and comparing information about access to the websites with the provider’s databases. Auxiliary cookies are also created in the web browser to improve the detection of malicious access.
Since the processing of the data is essential for the security of our websites and users, the data processing is based on the legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR. Due to this legitimate interest, there is no possibility to object to the processing of your data by the aforementioned security and anti-spam providers. If you have any concerns about this, we recommend that you stop using our websites.
WordFence
WordFence is provided by Defiant Inc., 800 5th Ave., Suite 4100, Seattle, WA 98104, USA. The data collected by WordFence includes IP address, browser type and version, operating system, date and time of access, and URL of the page accessed. The data will be used exclusively for the purpose of security analysis and optimization and will not be used for other purposes or passed on to third parties. The storage period of the collected data is 30 days, unless further security incidents are detected.
For more information about WordFence’s privacy, please visit https://www.wordfence.com/help/general-data-protection-regulation/ and Defiant Inc.’s Privacy Policy: https://www.wordfence.com/privacy-policy/
WP Cerber Security
WP Cerber Security is a plugin from Cerber Tech Inc., New York, NY, 1732 1st Ave, 10128, USA. It protects the WordPress installation against intruders and spam by creating an IP blacklist and an IP whitelist, allowing control over logins of specific IP addresses. Cerber Tech Inc. only processes the IP address to provide the service.
Further information on the collection and use of data by WP Cerber Security & Antispam can be found at: https://wpcerber.com/privacy-policy/
This privacy policy has been widely adapted by the site operator. The original version was created with Datenschutz-Generator.de by RA Dr. Thomas Schwenke