Privacy policy

Introduction

With the following data protection declaration, we would like to inform you about the types of your personal data (hereinafter also referred to as "data" for short) that we process, for what purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both as part of the provision of our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "Online Offer").

Responsible

Europemobile GmbH

Sägewerkstr. 5

83416 Saaldorf-Surheim

Germany

Persons authorized to represent the company: Marco Matanza

E-mail address: info@europe-mobile.de

Telephone: +49 (0) 86 54 / 45 78 50

Imprint: www.europe-mobile.de

Contact data protection officer

By mail:

Data protection officer

Europemobile GmbH

Sawmill street 5

83416 Saaldorf-Surheim

By e-mail: datenschutz@europemobile.de

Overview of processing

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

  • Inventory and contact data (names, addresses, e-mail, telephone numbers, etc.).
  • Applicant data (personal details, postal and contact addresses and the documents belonging to the application and the information contained therein, such as cover letter, CV, certificates and other information provided with regard to a specific position or voluntarily by applicants regarding their person or qualifications).
  • Content data (text entries, photographs, videos)
  • Meta/communication data (device information, IP addresses).
  • Usage data (websites visited, interest in content, access times).
  • Contract data (subject matter of contract, term, customer category).
  • Payment data (bank details, invoices, payment history).

Categories of data subjects

  • Customers and interested parties
  • Business and contractual partners
  • Applicants
  • Communication partners
  • Users (website visitors, users of online services)

Purposes of processing

  • Registration procedure, e.g. for dealers
  • Provision of our online services and user friendliness
  • Visitor action evaluation
  • Application procedure (establishment and possible later implementation as well as possible later termination of the employment relationship.)
  • Office and organization procedures
  • Content Delivery Network (CDN)
  • Direct marketing (via e-mail or postal mail)
  • Feedback (collection of feedback, e.g. via form)
  • Interest-based and behavioral marketing
  • Contact requests and communication
  • Conversion measurement (measuring the effectiveness of marketing activities)
  • Profiling (creating profiles of users)
  • Remarketing
  • Reach measurement (access statistics, recognition of returning visitors)
  • Security measures
  • Tracking (interest/behavior-based profiling, cookies)
  • Contractual services and support
  • Administration and response to requests

Applicable legal bases


In the following, we share the legal basis of the General Data Protection Regulation (GDPR) on the basis of which we process personal data. Please note that in addition to the regulations of the DSGVO, the national data protection regulations in your or our country of residence and domicile may apply.

  • Consent (Art. 6 para. 1 p. 1 lit. a DSGVO)- The data subject has given his/her consent to the processing of personal data relating to him/her for one or more specific purposes.
  • Performance of a contract and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO)- Processing is necessary for the performance of a contract to which the data subject is a party or for the performance of pre-contractual measures carried out at the data subject's request.
  • Legal obligation (Art. 6 (1) p. 1 lit. c. DSGVO)- The processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 (1) p. 1 lit. f. DSGVO)- Processing is necessary for the purposes of the legitimate interests of the controller or a third party, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

Security measures


We take appropriate technical and organizational measures in accordance with the law, 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, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data, as well as access to, entry into, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, deletion of data, and response to data compromise. Furthermore, we already take into account the protection of personal data during the development, or selection of hardware, software as well as procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.

Shortening of the IP address
: If it is possible for us or the storage of the IP address is not necessary, we shorten or have your IP address shortened. When shortening the IP address, also known as "IP masking", the last octet, i.e. the last two numbers of an IP address are deleted (the IP address is in this context, an identifier individually assigned to an Internet connection by the online access provider). The shortening of the IP address is intended to prevent or make it significantly more difficult to identify a person on the basis of their IP address.

SSL encryption (https): To protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address line of your browser.

Transmission and disclosure of personal data


In the course of our processing of personal data, it may happen that the data is transmitted to or disclosed to other bodies, companies, legally independent organizational units or persons. Recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts, or agreements that serve to protect your data, with the recipients of your data.

Data processing in third countries


If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or disclosure, or transfer of data to other persons, bodies or companies, this is only done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we process or leave the data only in third countries with a recognized level of data protection or on the basis of special guarantees, such as contractual obligation by so-called standard contractual clauses (SCC) of the EU Commission, the existence of certifications or binding internal rules (Binding Corporate Rules).

Use of cookies


''Cookies" are small files that are stored on users' devices. Various details can be stored within the cookies. The information may include, for example, language settings on a website, login status, a shopping cart, or where a video was watched.

Cookies are also generally used when a user's interests or behavior (e.g. viewing certain content, using functions, etc.) are stored in a user profile via individual websites. These profiles are used, for example, to display ads to users that match their potential interests. This process is also referred to as "tracking", i.e. tracking the potential interests of users. We further include in the term cookies other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also referred to as "user IDs").

Insofar as we use cookies or "tracking" technologies, we will inform you about this in our data protection declaration.

Notes on legal bases
: the legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g., in a business operation of our online offer and its improvement) or if the use of cookies is necessary to fulfill our contractual obligations.

Revocation and objection (opt-out)
: Regardless of whether processing is based on consent or legal permission, you have the option at any time to revoke any consent you have given or to object to the processing of your data by cookie technologies (collectively referred to as "opt-out").

You can initially declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (whereby this may also restrict the functionality of our online offer).

An objection to the use of cookies 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/oder the EU site http://www.youronlinechoices.com/ or generally on http://optout.aboutads.info.

You will also find further information on the possibility to object in the context of the information on the respective processing in this data protection declaration.

Processing of cookie data on the basis of consent
: Before we process or have processed data in the context of the use of cookies, we ask users for consent that can be revoked at any time. Before the consent has not been expressed, cookies are used at most, which are necessary for the operation of our online offer. Their use is based on our interest and the interest of users in the expected functionality of our online offer.

  • Types of data processed: Usage data (web pages visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Data subjects: Users (website visitors, users of online services).
  • Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Commercial and business services


We process data of our contractual and business partners, e.g. customers and of interested parties (collectively referred to as "contractual partners") in the context of contractual and comparable legal relationships as well as related measures and communication with contractual partners (or pre-contractual), e.g. to answer inquiries.

We process this data to fulfill our contractual obligations, secure our rights and for the purposes of the administrative tasks associated with this information as well as the corporate organization. In this context, we only disclose the data of the contractual partners to third parties within the scope of applicable law to the extent that this is necessary for the aforementioned purposes or for the fulfillment of legal obligations or with the consent of the contractual partners (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about further processing, e.g. for marketing purposes, within the scope of this data protection declaration.

We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms by means of special marking (e.g. colors), or symbols (e.g. asterisks or similar) or in person.

We delete the data after expiry of legal warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account e.g. as long as it must be kept for legal archiving reasons (e.g. generally 10 years for tax purposes). In the case of data disclosed to us by the contractual partner as part of an order, we delete the data in accordance with the specifications of the order, generally after the end of the order.

Insofar as we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.

Third-party provider


We work with various third-party providers on whose sites we place ads for our vehicles. If you have a user relationship with such a third party provider and are logged in while contacting us, the third party provider will provide us with your phone number, email and name so that we can contact you. Third-party providers are:

Mobile.de: https://www.mobile.de/service/privacyPolicy?lang=de

Autoscout24.de: http://about.autoscout24.com/de-de/au-company/au-company-privacy.aspx?genlnk=foot&genlnkorigin=de-all-all-home

EU-car.de: https://eu-car.de/de/Datenschutz/

Cargurus.de: https://www.cargurus.de/Cars/privacyPolicy.html

Gebrauchtwagen.de: https://www.gebrauchtwagen.de/services/datenschutz

Meinauto.de: https://www.meinauto.de/datenschutz/

Autrado.de: https://www.autrado.de/datenschutz.php

Mitarbeitervorteile.de: https://www.mitarbeitervorteile.de/datenschutz

DPolG-Service.de: https://www.dpolg-service.de/datenschutzerklaerung

Customer account: Contractual partners can create an account within our online offer (e.g., customer or user account, "customer account" for short). If registration of a customer account is required, contractual partners will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. Within the scope of registration and subsequent logins and use of the customer account, we store the IP addresses of the customers along with the access times in order to be able to prove the registration and prevent any misuse of the customer account.

If customers have terminated their customer account, their data with regard to the customer account will be deleted, unless their retention is required for legal reasons. It is the responsibility of customers to back up their data when their customer account is terminated.

Payment service provider


In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use other payment service providers (collectively "payment service providers") in addition to banks and credit institutions for this purpose.

The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored with them. I.e. we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment. Under certain circumstances, the payment service providers transmit the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the terms and conditions and data protection information of the payment service providers.

For the payment transactions, the terms and conditions and data protection information of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of revocation, information and other data subject rights.

Types of data processed
: inventory data (names, addresses, etc.), payment data (bank details, invoices, payment history), contract data (subject matter of contract, term, customer category), usage data (websites visited, interest in content, access times), meta/communication data (device information, IP addresses).

Data subjects
: Customers, interested parties.

Contacting
When contacting us (e.g. by e-mail, telephone or via social media), the information of the inquiring persons is processed to the extent necessary to respond to the contact requests and any requested measures.

The response to the contact requests in the context of contractual or pre-contractual relationships is carried out in order to fulfill our contractual obligations or respond to (pre)contractual requests and otherwise on the basis of the legitimate interests in responding to the requests.

Chat function (via HubSpot)
: For purposes of communication and answering inquiries, we offer a chat function within our online offer. Users' entries within the chat are processed for the purpose of responding to their inquiries.

  • Types of data processed: inventory data (names, addresses, etc.), contact data (e-mail, telephone numbers), content data (text entries, photographs, videos), usage data (web pages visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Data subjects: Communication partners, interested parties.
  • Purposes of processing:Contact requests and communication, managing and responding to requests.
  • Legal basis:Contract performance and pre-contractual inquiries (Art. 6 para. 1 p. 1 lit. b. DSGVO), Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Provision of the online offer and web hosting


In order to provide our online offer securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.

The data processed as part of the provision of the hosting service may include all information relating to the users of our online service, which is generated in the course of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

E-mail dispatch and hosting
: The web hosting services we use also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders, as well as further information regarding the e-mail dispatch (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted during transport. As a rule, e-mails are encrypted in transit, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on each access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, the date and time of access, the volume of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files may be used on the one hand for security purposes, e.g. to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the utilization of the servers and optimization of their stability.

Content Delivery Network: We use a "content delivery network" (CDN). A CDN is a service with the help of which content of an online offer, in particular large media files, such as graphics or program scripts can be delivered faster and more securely with the help of regionally distributed servers connected via the Internet.

  • Types of data processed: Content data (text input, photographs, videos), usage data (web pages visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Data subjects: Users (website visitors, users of online services).
  • Purposes of processing: Content Delivery Network (CDN).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Application procedure


The application procedure requires applicants to provide us with the data necessary for their assessment and selection. The information required is determined by the job offer.

In principle, the required information includes personal information such as the name, address, a means of contact and proof of the qualifications required for a position. Upon request, we will be happy to provide additional information about which details are required.

Duration of retention of applicant data:

If your application is successful, we will continue to process your data for the purposes of your employment. If your application is not successful, your data will be deleted no later than six months after the end of the application process.

  • Types of data processed: applicant data (personal details, postal and contact addresses and the documents belonging to the application and the information contained therein, such as cover letter, CV, certificates and other information provided with regard to a specific position or voluntarily by applicants regarding their person or qualifications).
  • Data subjects:
  • Purposes of the processing: application procedure (establishment and possible later implementation as well as later possible termination of the employment relationship.).
  • Legal basis: 9 para. 1 p. 1 lit. b DSGVO (application procedure as a pre-contractual or contractual relationship). Insofar as special categories of personal data within the meaning of Art. 9 (1) DSGVO (e.g. health data, such as severely disabled status or ethnic origin) are requested from applicants as part of the application procedure in order for the controller or the data subject to exercise the rights accruing to him or her under employment law and social security and social protection law and to comply with his or her obligations in this regard, their processing is carried out in accordance with Art. 9 (2) lit. b. DSGVO, in case of protection of vital interests of the applicants or other persons according to Art. 9 para. 2 lit. c. DSGVO or for the purposes of preventive health care or occupational medicine, for the assessment of the employee's ability to work, for medical diagnostics, care or treatment in the health or social sector or for the management of systems and services in the health or social sector pursuant to Art. 9 para. 2 lit. h. DSGVO. In the case of a communication of special categories of data based on voluntary consent, their processing is based on Art. 9 para. 2 lit. a. DSGVO. In the case of processing of applicant data in Germany, Sections 22, 26 BDSG shall additionally apply specifically.

Promotional communication via mail, fax or telephone


We process personal data for the purpose of promotional communication, which may take place via various channels, such as e-mail, telephone, mail or fax. In doing so, we comply with legal requirements and obtain the necessary consents, unless the communication is permitted by law.

Recipients have the right to revoke consent given at any time or to object to promotional communication at any time.

After revocation or objection, we may store the data required to prove consent for up to three years based on our legitimate interests before deleting it. The processing of this data will be limited to the purpose of a possible defense against claims. An individual deletion request is possible at any time, provided that the former existence of consent is confirmed at the same time.

  • Types of data processed: inventory data (names, addresses, etc.), contact data (e-mail, telephone numbers).
  • Data subjects: Communication partner
  • Purposes of processing: Direct marketing (by e-mail or post).
  • Legal basis: consent (Art. 6 para. 1 p. 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Web analysis and optimization


Web analysis (also referred to as "reach measurement"), is used to evaluate the flow of visitors to our online offering and may include their behavior, interests or demographic information, such as age or gender as pseudonymous values. With the help of reach analysis, we can see, for example, at what time our online offer or its functions or content are most frequently used or invite re-use, as well as which areas require optimization.

In addition to web analytics, we may also use testing procedures, for example, to test and optimize different versions of our online offering or its components.

For these purposes, so-called profiles of the users may be created and stored in a file (so-called "cookie") or similar procedures, in which the, for the aforementioned analyses relevant information about the user. This information may include, for example, content viewed, websites visited and elements used there and technical information such as the browser used, computer system used and information on usage times. If users have consented to the collection of their location data, this may also be processed, depending on the provider.

The IP addresses of the users are also stored. However, we use an existing IP masking procedure (i.e., pseudonymization by shortening the IP address) to protect users. Generally, in the context of web analysis, A/B testing and optimization, no clear data of the users (such as e-mail addresses or names) are stored, but pseudonyms. This means that we, as well as the providers of the software used, do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective procedures.

Notes on legal bases: If we ask users for their consent (e.g., in the context of a so-called "cookie banner consent"), the legal basis for processing data for online marketing purposes is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer. In this regard, we refer to the note on the use of cookies in this privacy policy.

  • Data subjects: Users (website visitors)
  • Purposes of processing: range measurement (access statistics, recognition of returning visitors).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal grounds: consent (Art. 6 para. 1 p. 1 lit. a DSGVO), legitimate interest (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Website analysis
Services used and service providers:

  • Google Analytics: Google Analytics; Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA;

Website: https://marketingplatform.google.com/intl/de/about/analytics/;
Privacy Policy: https://policies.google.com/privacy;
Opt-out: Opt-Out Plugin: http://tools.google.com/dlpage/gaoptout?hl=de,
Settings for the display of advertisements: https://adssettings.google.com/authenticated.

Online appointment with Calendly


You have the possibility to make an appointment on our website. We use the tool calendly to make appointments easily, quickly and without complications. "Calendly" is an offer of Calendly, LLC, 3423 Piedmont Road NE, Atlanta, GA 30305-1754, United States.

Calendly is used to improve and simplify our sales advice as well as to arrange appointments for a vehicle handover for interested parties and customers. This constitutes a legitimate interest within the meaning of Art. 6 (1) lit. f DSGVO.

When using the tool, you will be asked for personal data such as first and last name, e-mail address and mobile phone number. You also have the opportunity to present your request and provide us with further information. If you use the tool, your data from the inquiry form, including the information you provide there, will be stored and, of course, transmitted on the Internet.

The appointment booking will be confirmed to you by e-mail or as a text message. Furthermore, you will receive an Outlook appointment invitation and, if you book an appointment for a live video car presentation, the login data for the virtual presentation via Microsoft Teams will be sent to you by e-mail.

The information you provide in the Calendly form, including the data you enter there, will be stored by us and Calendly for the purpose of processing the appointment booking, inquiry and in case of follow-up questions. This data remains with us and Calendly until you request us to delete it, revoke your consent to store it or the purpose for storing the data no longer applies. Mandatory legal provisions, e.g. retention periods, remain unaffected.

The processing of the entered data is based exclusively on your consent (Art. 6 para. 1 lit. a DSGVO).

This privacy policy and the provider's privacy policy apply to the handling of data collected through the use of calendly. You can find the privacy policy of calendly at: https://calendly.com/pages/privacy

HubSpot
On this website, we use the service HubSpot for various purposes. HubSpot is a software company from the USA with a branch office in Ireland (HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland).
Website: https://www.hubspot.com/careers/dublin-ireland
Privacy policy: https://legal.hubspot.com/privacy-policy

Hubspot is an integrated software solution that we use to cover various aspects of our online marketing. These include: Email Marketing, Social Media Publishing & Reporting, Reporting, Contact Management (e.g. user segmentation & CRM), Landing Pages and Contact Forms.
This information, as well as the content of our website, is stored on servers of our software partner HubSpot. It can be used by us to contact visitors to our website and to determine which of our company's services are of interest to them. We use all collected information exclusively to optimize our marketing measures.

As part of the optimization of our marketing measures, the following data may be collected and processed via Hubspot:
- Geographical position
- Browser type
- Navigation information
- Referral URL
- Performance data
- Mobile apps data
- Files displayed on site
- Domain names
- Pages viewed
- Aggregated usage
- Operating system version
- Internet service provider
- IP address
- Device identifier
- Duration of visit
- Operating system
- Events that occur within the application
- Access times
- Clickstream data
- Device model and version

Legal basis: consent (Art. 6 para. 1 lit. a DSGVO).
If you do not want Hubspot to collect and process the aforementioned data, you can refuse your consent or revoke it at any time with effect for the future.
Storage period: personal data will be kept for as long as it is necessary to fulfill the purpose of processing. The data will be deleted as soon as they are no longer required to achieve the purpose.

In the context of processing via HubSpot, data may be transferred to the USA. The security of the transfer is secured via so-called standard contractual clauses, which ensure that the processing of personal data is subject to a level of security that corresponds to that of the GDPR.

HubSpot (CRM)
We use HubSpot for our online marketing activities. This is an integrated software solution that we use to cover various aspects of our online marketing. These include:
- Content Management (website and blog)
- Email marketing (newsletter as well as automated mailings, e.g. to provide downloads)
- Social media publishing and reporting
- Reporting (e.g. traffic sources, hits)
- Contact management (e.g. user segmentation and CRM)
- Landing pages and contact forms

Our service allows users to learn more about our company, download content, and provide their contact information and other demographic information. This information, as well as our website content, is stored on servers operated by our software partner HubSpot. It may be used by us to contact visitors to our website and to determine which of our company's services are of interest to them. We use all collected information exclusively to optimize our marketing.
Service provider HubSpot, Inc, 25 First St., 2nd floor, Cambridge, Massachusetts 02141, USA; website: https://www.hubspot.de;
Privacy policy: https://legal.hubspot.com/de/privacy-policy

Evaluation platforms
We participate in evaluation procedures in order to evaluate, optimize and advertise our services. If users rate us via the participating rating platforms or procedures (e.g., mobile.de, autoscout.de) or otherwise provide feedback (Google), the general terms and conditions of business or use and the data protection information of the providers also apply. As a rule, the rating also requires registration with the respective providers.

In order to ensure that the evaluating persons have actually used our services, we transmit, with the consent of the customer, the data required for this with regard to the customer and the service used to the respective evaluation platform (this includes the name, the e-mail address, and the order number or item number). This data is used solely to verify the authenticity of the user.

Types of data processed: contract data (subject matter of the contract, term, customer category), usage data (websites visited, interest in content, access times), meta/communication data (device information, IP addresses).
Data subjects: Customers, users (website visitors, users of online services).
Purposes of processing: feedback (collecting feedback, e.g. via form).
Legal basis: Consent (Art. 6 para. 1 p. 1 lit. a DSGVO), Legitimate Interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Plugins and embedded functions and content


We include functional and content elements within our online offer that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These can be, for example, graphics, videos or social media buttons as well as posts (hereinafter uniformly referred to as "content").

The integration always requires that the third-party providers of this content process the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is thus required for the presentation of these contents or functions. We endeavor to use only such content whose respective providers use the IP address only 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. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as be linked to such information from other sources.

Notes on legal bases
: If we ask users for their consent (e.g. in the context of a so-called "cookie banner consent"), the legal basis for processing data for online marketing purposes is consent. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer. In this regard, we refer to the information on the use of cookies in this privacy policy.

  • Types of data processed: Usage data (websites visited, interest in content, access times), meta/communication data (device information, IP addresses), contact data (e-mail, telephone numbers), content data (text input, photographs, videos).
  • Data subjects: Users (website visitors, users of online services), communication partners.
  • Purposes of processing: provision of our online offer and user experience, contractual performance and service, contact requests and communication, direct marketing (by e-mail or postal mail), tracking (interest/behavioral profiling, cookies), interest-based and behavioral marketing, profiling (profiling of users).
  • Legal basis: Legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO), consent (Art. 6 para. 1 p. 1 lit. a DSGVO).

Services used and service providers:

  • Facebook Social Plugins: Facebook Social Plugins - This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Facebook. The list and appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/;
    Service Provider: https://www.facebook.com, Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, Parent Company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA;

website: https://www.facebook.com;
Privacy policy: https://www.facebook.com/about/privacy;
Opt-out: Ads settings: https://www.facebook.com/settings?tab=ads.

  • Google Fonts: We integrate the fonts ("Google Fonts") of the provider Google, whereby the user's data is used solely for the purpose of displaying the fonts in the user's browser. The integration is based on our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform display and consideration of possible licensing restrictions for their integration. Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, Parent Company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://fonts.google.com/;
    Privacy Policy: https://policies.google.com/privacy;

  • Google Maps: We integrate the maps of the service "Google Maps" of the provider Google. Processed data may include, in particular, IP addresses and location data of users, which, however, are not collected without their consent (usually executed within the settings of their mobile devices). Service provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, parent company: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; website: https://maps.google.de;
    Privacy policy: https://policies.google.com/privacy;

    Opt-out: Opt-Out Plugin: http://tools.google.com/dlpage/gaoptout?hl=de,

    Ad display settings: https://adssettings.google.com/authenticated.

  • Instagram plugins and buttons:Instagram plugins and buttons - This may include, for example, content such as images, videos or texts and buttons with which users can share content of this online offer within Instagram. Service provider: https://www.instagram.com, Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA;
    Website: https://www.instagram.com;
    Privacy policy: http://instagram.com/about/legal/privacy.

Planning, organization and auxiliary tools


We use services, platforms and software of other providers (hereinafter referred to as "Third-Party Providers") for the purposes of organization, administration, planning as well as provision of our services. When selecting third-party providers and their services, we observe the legal requirements.

In this context, personal data may be processed and stored on the servers of the third-party providers. This may include various data that we process in accordance with this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their contents.

If users are referred to the third-party providers, or their software or platforms, in the course of communication, business or other relationships with us, the third-party providers may process usage data and metadata processed by them for security, service optimization or marketing purposes. We therefore ask you to observe the data protection notices of the respective third-party providers.

Notes on legal basis
: If we ask users for their consent to use the third-party providers, the legal basis for processing data for online marketing purposes is consent. Furthermore, their use may be a component of our (pre)contractual services, provided that the use of the third-party providers has been agreed within this framework. Otherwise, user data is processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services.).

  • Types of data processed: inventory data (names, addresses, etc.), contact data (e-mail, telephone numbers), content data (text input, photographs, videos), usage data (web pages visited, interest in content, access times), meta/communication data (device information, IP addresses).
  • Data subjects: Communication partners, users (website visitors, users of online services).
  • Legal grounds: consent (Art. 6 para. 1 p. 1 lit. a DSGVO), contract performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 p. 1 lit. f. DSGVO).

Deletion of data
The data processed by us will be deleted in accordance with the legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (e.g. if the purpose of processing this data has ceased to apply or it is not required for the purpose).

If the data is not deleted because it is required for other and legally permissible purposes, its processing is limited to these purposes. That is, 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 or whose storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.

Further information on the deletion of personal data can also be found in the individual data protection notices of this privacy policy.

Changes and updates to the privacy policy


We ask you to regularly check the content of our privacy policy. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

Rights of the data subjects

  • Right of objection: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to withdraw consent: You have the right to revoke any consent given at any time.
  • Right to information: 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 the legal requirements.
  • Right to rectification: you have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be rectified.
  • Right to erasure and restriction of processing: You have the right, in accordance with the law, to request that data concerning you be erased without delay, or alternatively, in accordance with the law, to request restriction of the processing of the data.
  • Right to data portability: You have the right to receive data concerning you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to demand its transfer to another responsible party.
  • Complaint to the supervisory authority: You also have the right to file a complaint with the competent supervisory authority in accordance with the legal requirements.