This Privacy Policy informs you about the type, scope, and purpose of processing personal data (hereinafter referred to as “data”) within our online offer and the websites, functions, and content associated with it, as well as external online presences, such as our social media profiles (collectively referred to as “online offer”). Regarding the terminology used, such as “processing” or “controller”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
(Note: The following English texts are automated translations of the original German texts.)
Frontend GmbH, Zionskirchstraße 66, 10119 Berlin, Germany
Visitors and users of the online offer (Hereinafter, we also refer to the affected persons as “users”).
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “affected person”); 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” refers to any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and includes virtually any handling of data.
“Pseudonymization” 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 organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
“Profiling” 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 analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
The “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.
In accordance with Art. 13 GDPR, we inform you about the legal bases of our data processing. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consents is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing for the performance 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 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 affected person or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.
We take appropriate technical and organizational measures in accordance with Art. 32 GDPR, considering the state of the art, the implementation costs, and the nature, scope, context, and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons, to ensure a level of security appropriate to the risk.
These measures include ensuring the confidentiality, integrity, and availability of data by controlling physical access to the data, as well as related access, input, disclosure, availability, and separation. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, deletion of data, and response to data endangerment. Additionally, we consider the protection of personal data already in the development, or selection of hardware, software, and procedures, in accordance with the principle of data protection through technology design and data protection-friendly default settings (Art. 25 GDPR).
If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transmit them to them or otherwise grant them access to the data, this is done only on the basis of a legal permission (e.g., if a transmission of the data to third parties, such as to payment service providers, pursuant to Art. 6 para. 1 lit. b GDPR is required to fulfill the contract), 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 “contract processing agreement”, this is done on the basis of Art. 28 GDPR.
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 in the context of the use of third-party services or disclosure or transmission of data to third parties, this is done only if it is 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 have the data processed in a third country only in the presence of the special requirements of Art. 44 et seq. GDPR. This means, the processing is carried out e.g., on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to the EU (e.g., for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contract clauses”).
You have the right to withdraw consents granted in accordance with Art. 7 para. 3 GDPR with effect for the future.
You can object to the future processing of the data concerning you in accordance with Art. 21 GDPR at any time. The objection can be made in particular against processing for direct marketing purposes.
“Cookies” are small files that are stored on users’ computers. Different data can be stored within the cookies. A cookie primarily serves to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offer. As temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes their browser. In such a cookie, e.g., the content of a shopping cart in an online store or a login status can be stored. “Permanent” or “persistent” cookies remain stored even after closing the browser. For example, the login status can be saved if users visit it after several days. Likewise, such a cookie can store the interests of users used for range measurement or marketing purposes. “Third-Party-Cookie” are cookies that are offered by providers other than the person responsible for operating the online offer (otherwise, if they are only its cookies, they are called “First-Party Cookies”).
We can use temporary and permanent cookies and clarify this in our privacy policy.
If users do not want cookies stored on their computer, they are asked to disable the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
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 switching them off in the settings of the browser. Please note that not all functions of this online offer can be used.
The data processed by us are deleted or limited in their processing in accordance with Articles 17 and 18 GDPR. Unless expressly stated in this privacy policy, the data stored by us are deleted as soon as they are no longer required for their purpose and the deletion does not conflict with any statutory storage obligations. If the data are not deleted because they are necessary for other and legally permissible purposes, their processing is restricted. That is, the data is blocked and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax reasons.
According to legal requirements in Germany, storage is carried out in particular for 10 years according to §§ 147 para. 1 AO, 257 para. 1 nos. 1 and 4, para. 4 HGB (books, records, management reports, accounting documents, trading books, documents relevant for taxation, etc.) and 6 years according to § 257 para. 1 nos. 2 and 3, para. 4 HGB (commercial letters).
According to legal requirements in Austria, storage is carried out in particular for 7 years according to § 132 para. 1 BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, statement of income and expenses, etc.), for 22 years in connection with real estate and for 10 years for documents related to electronically supplied services, telecommunications, radio and television services offered to non-entrepreneurs in EU Member States and for which the Mini-One-Stop-Shop (MOSS) is used.
Additionally, we process
We process our clients’ data in the context of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consultation or care, implementation of campaigns and processes/handling, server administration, data analysis/consulting services, and training services.
We process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., email, phone numbers), content data (e.g., text inputs, photographs, videos), contract data (e.g., subject matter of the contract, term), payment data (e.g., bank details, payment history), usage and metadata (e.g., in the context of evaluation and performance measurement of marketing measures). Special categories of personal data are generally not processed, unless they are components of a commissioned processing. The affected persons include our customers, prospects, and their customers, users, website visitors, employees, and third parties. The purpose of processing is to provide contract services, billing, and our customer service. The legal basis of the processing results from Art. 6 para. 1 lit. b GDPR (contractual services), Art. 6 para. 1 lit. f GDPR (analysis, statistics, optimization, security measures). We process data necessary to justify and fulfill the contractual services and point out the necessity of their disclosure. Disclosure to external parties only takes place if it is required within the framework of a contract. When processing data provided to us within the scope of an order, we act according to the instructions of the clients as well as the legal requirements of a contract processing according to Art. 28 GDPR and do not process the data for any other purposes than the ones agreed upon.
We delete the data after expiration of legal warranty and comparable obligations. The necessity of keeping the data is reviewed every three years; in the case of legal archiving obligations, deletion takes place after their expiration (6 years, according to § 257 para. 1 HGB, 10 years, according to § 147 para. 1 AO). In the case of data disclosed to us by the client within the framework of an order, we delete the data according to the specifications of the order, generally after the end of the order.
We process applicant data only for the purpose and within the scope of the application process in accordance with the legal requirements. The processing of the applicant data is carried out to fulfill our (pre)contractual obligations within the framework of the application process within the meaning of Art. 6 para. 1 lit. b. GDPR, Art. 6 para. 1 lit. f. GDPR if data processing becomes necessary for us, e.g., within the framework of legal procedures (in Germany additionally § 26 BDSG applies).
The application process requires applicants to provide us with applicant data. The necessary applicant data is indicated if we offer an online form, otherwise it arises from the job descriptions and generally includes personal information, postal and contact addresses, and the documents belonging to the application, such as cover letter, curriculum vitae, and certificates. In addition, applicants can voluntarily provide us with additional information.
By submitting an application to us, applicants agree to the processing of their data for the purposes of the application process according to the nature and scope set out in this privacy policy.
Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are voluntarily communicated within the framework of the application process, their processing is additionally carried out in accordance with Art. 9 para. 2 lit. b GDPR (e.g., health data, such as severely disabled status or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 para. 1 GDPR are requested from applicants during the application process, their processing is additionally carried out in accordance with Art. 9 para. 2 lit. a GDPR (e.g., health data, if this is necessary for the exercise of the profession).
If provided, applicants can submit their applications via an online form on our website. The data is encrypted and transmitted to us in accordance with the state of the art.
Furthermore, applicants can send us their applications via email. Please note, however, that emails are generally not sent in an encrypted form and the applicants themselves must ensure encryption. Therefore, we cannot take responsibility for the transmission path of the application between the sender and the reception on our server and recommend using an online form or postal dispatch. Instead of applying via the online form and email, applicants still have the option to send us the application by post.
The data provided by applicants may be further processed by us in the event of a successful application for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. The applicants’ data will also be deleted if an application is withdrawn, which the applicants are entitled to do at any time.
The deletion is carried out, subject to a justified revocation by the applicants, after the expiry of a period of six months so that we can answer any follow-up questions to the application and meet our proof obligations under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with the tax regulations.
Furthermore, applicants can send us their applications via email. Please note, however, that emails are generally not sent in an encrypted form and the applicants themselves must ensure encryption. Therefore, we cannot take responsibility for the transmission path of the application between the sender and the reception on our server and recommend using an online form or postal dispatch. Instead of applying via the online form and email, applicants still have the option to send us the application by post.
The data provided by applicants may be further processed by us in the event of a successful application for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. The applicants’ data will also be deleted if an application is withdrawn, which the applicants are entitled to do at any time.
The deletion is carried out, subject to a justified revocation by the applicants, after the expiry of a period of six months so that we can answer any follow-up questions to the application and meet our proof obligations under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with the tax regulations.
We use the service Gravatar from Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA, within our online offer and especially in our blog.
Gravatar is a service where users can register and store profile pictures and their email addresses. When users leave posts or comments on other online presences (especially in blogs) with the respective email address, their profile pictures can be displayed next to the posts or comments. For this purpose, the email address provided by the users is transmitted to Gravatar in encrypted form for the purpose of checking whether a profile has been stored. This is the sole purpose of transmitting the email address and it is not used for other purposes, but rather deleted thereafter.
The use of Gravatar is based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f) GDPR, as we offer post and comment authors the opportunity to personalize their posts with a profile picture.
By displaying the images, Gravatar learns the IP addresses of the users, as this is necessary for a communication between a browser and an online service. Further information about the collection and use of data by Gravatar can be found in Automattic’s privacy policy: https://automattic.com/privacy/.
If users do not want a user image linked to their email address at Gravatar to appear in the comments, they should use an email address that is not registered with Gravatar for commenting. We also point out that it is also possible to use an anonymous or no email address if users do not wish their own email address to be sent to Gravatar. Users can prevent the transmission of data completely by not using our comment system.
When contacting us (e.g., via contact form, email, phone, or social media), the user’s information is processed for the purpose of handling the contact request and its processing in accordance with Art. 6 para. 1 lit. b) GDPR. The user’s information may be stored in a Customer Relationship Management System (“CRM System”) or a comparable request organization.
We delete inquiries if they are no longer necessary. We review the necessity every two years; furthermore, the statutory archiving obligations apply.
The hosting services we use are for the purpose of providing the following services: infrastructure and platform services, computing capacity, storage space and database services, email delivery, security services, and technical maintenance services that we use for the operation of this online offering.
In this context, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, prospects, and visitors to this online offering on the basis of our legitimate interests in an efficient and secure provision of this online offering in accordance with Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of a data processing agreement).
We, or our hosting provider, collect data on every access to the server on which this service is located, based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR (so-called server log files). Access data includes the name of the website accessed, file, date and time of access, amount of data transferred, message about successful retrieval, type of browser and version, user’s operating system, referrer URL (previously visited page), IP address, and requesting provider.
Log file information is stored for security reasons (e.g., for investigating misuse or fraud) for a maximum of 7 days and then deleted. Data whose further retention is required for evidentiary purposes is exempt from deletion until final clarification of the respective incident.
Google Tag Manager is a solution that allows us to manage website tags, such as Google Analytics and other Google marketing services, through an interface. The Tag Manager itself (which implements the tags) does not process personal data of users. Regarding the processing of users’ personal data, please refer to the following information on Google services. Usage policy: https://www.google.com/intl/de/tagmanager/use-policy.html.
We use Google Analytics, a web analytics service provided by Google LLC (“Google”), 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). Google uses cookies. The information generated by the cookie about the use of the online offering by users is generally transmitted to a Google server in the USA and stored there.
Google is certified under the Privacy Shield Agreement and thus provides a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offering by users, to compile reports on the activities within this online offering, and to provide us with further services related to the use of this online offering and internet usage. Pseudonymous user profiles can be created from the processed data.
We use Google Analytics with IP anonymization enabled. This means that the IP address of users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user’s browser is not merged with other Google data. Users can prevent the storage of cookies by adjusting their browser software settings accordingly; users can also prevent the collection of data generated by the cookie related to their use of the online offering to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
For more information about Google’s data usage, settings, and opt-out options, please refer to Google’s Privacy Policy (https://policies.google.com/technologies/ads) and the settings for displaying ads by Google (https://adssettings.google.com/authenticated).
User data is deleted or anonymized after 14 months.
We use Google Analytics in the form of “Universal Analytics.” “Universal Analytics” refers to a method of Google Analytics in which user analysis is based on a pseudonymous user ID, creating a pseudonymous user profile with information from the use of various devices (so-called “cross-device tracking”).
We offer a live chat on our site. The provider of the live chat software is Tawk.to. Tawk.to also uses “cookies” that are stored on your computer. By using the chat, you consent to the storage and use of the data. You can find more information from Tawk.to here: Tawk.to Privacy Policy.
We maintain online presences within social networks and platforms to communicate with active customers, prospects, and users and to inform them about our services. When accessing 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 user data if they communicate with us within social networks and platforms, e.g., by posting on our online presences or sending us messages.
Within our online offering, we use content or service offerings from third-party providers 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) to incorporate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).
This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore necessary for the presentation of this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. With the help of “pixel tags,” information such as visitor traffic on the pages of this website can be evaluated. The pseudonymous information may also be stored in cookies on the user’s device and may include technical information about the browser and operating system, referring web pages, visit time, and other information about the use of our online offering, as well as be linked to such information from other sources.
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.
We embed maps from the “Google Maps” service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The processed data may include IP addresses and location data of users, which, however, are not collected without their consent (usually as part of the settings of their mobile devices). The data may be processed in the USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.