Legal information

Privacy policy

This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the associated websites, functions and contents as well as external online presences, such as our Social Media Profile (hereinafter referred to collectively as “online offer”). With regard to the terms used, e.g. “processing” or “responsible person”, we refer to the definitions in Art. 4 of the Basic Data Protection Regulation (DSGVO).

Responsible person

IT Service Robert Frunzke
Rahnsdorfer Strasse 81
15566 Schöneiche near Berlin
E-mail: post@manjadigital.de
Owner: Robert Frunzke
Link to the imprint: https://manjadigital.de/en/imprint/

Types of data processed:

inventory data (e.g., names, addresses).
Contact data (e.g., e-mail, telephone numbers).
Content data (e.g., text input, photographs, videos).
Usage data (e.g., visited websites, interest in content, access times).
Meta/communication data (e.g., device information, IP addresses).

Categories of data subjects

Visitors and users of the online offer (in the following we will refer to the persons concerned collectively as “users”).

Purpose of processing

Provision of the online offer, its functions and contents.
Answering of contact requests and communication with users.
Security measures.
Reach Measurement/Marketing

Used terms

“Personal data” shall mean any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, a location data, an online identifier (e.g. a cookie) or 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 covers virtually all data handling.

“pseudonymization” shall mean the processing of personal data in such a way that the personal data cannot be related to a specific data subject without the inclusion of additional information, provided that this additional information is kept separately and is subject to technical and organizational measures ensuring that the personal data is not attributed to an identified or identifiable natural person

“profiling” shall mean any automated processing of personal data consisting in using such personal data to evaluate certain personal aspects relating to a natural person, in particular with a view to analysing or predicting aspects relating to the performance of work, economic situation, health, personal preferences, interests, reliability, conduct, whereabouts or movements of that natural person

The term “controller” shall mean 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 any natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller

Applicable legal basis

In accordance with Art. 13 DSGVO we inform you about the legal basis of our data processing. If the legal basis is not stated in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 Para. 1 lit. a and Art. 7 DSGVO, the legal basis for processing for the purpose of fulfilling our services and implementing contractual measures and answering inquiries is Art. 6 Para. 1 lit. b DSGVO, the legal basis for processing for the purpose of fulfilling our legal obligations is Art. 6 Para. 1 lit. c DSGVO, and the legal basis for processing for the purpose of safeguarding our legitimate interests is Art. 6 Para. 1 lit. f DSGVO. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO serves as the legal basis.

Security measures

In accordance with Art. 32 DSGVO and taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the varying probability of occurrence and severity of the risk to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk.

These measures shall include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling the physical access to the data, as well as the access, input, disclosure, security of availability and separation of the data relating to them. Furthermore, we have established procedures to ensure that the rights of data subjects are exercised, data is deleted, and we respond to any threats to the data. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly presettings (Art. 25 DSGVO).

Cooperation with contract processors and third parties

If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transfer it to them or otherwise grant them access to the data, this is only done on the basis of a legal authorization (e.g. if a transfer of the data to third parties, such as payment service providers, is necessary for the performance of the contract in accordance with Art. 6 para. 1 lit. b DSGVO), if you have consented, if 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 DSGVO.

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 the services of third parties or disclosure or transfer of data to third parties, this will only take place if it is done to fulfil our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we will only process or transfer the data in a third country if the special requirements of Art. 44 ff. DSGVO. This means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding 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 or not data in question is being processed and to receive information about this data and to receive further information and a copy of the data in accordance with Art. 15 of the Data Protection Act.

You have accordingly. Art. 16 DSGVO the right to request the completion of data concerning you or the correction of incorrect data concerning you.

In accordance with Art. 17 DSGVO, you have the right to demand that data concerning you be deleted immediately, or alternatively, in accordance with Art. 18 DSGVO, to demand that the processing of the data be restricted.

You have the right to demand that the data concerning you, which you have made available to us, be received in accordance with Art. 20 DSGVO and to demand its transfer to other responsible parties.

You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 DSGVO.

Right of withdrawal

You have the right to revoke consents granted in accordance with Art. 7 para. 3 DSGVO with effect for the future

Right of objection

You can object to the future processing of data concerning you at any time in accordance with Art. 21 DSGVO. The objection may in particular be made against processing for the purposes of direct advertising.

Cookies and right of objection for direct advertising

Cookies” are small files that are stored on the user’s computer. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his visit to an online service. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the contents of a shopping cart in an online store or a login status can be stored. Cookies are described as “permanent” or “persistent” if they remain stored even after the browser is closed. For example, the login status can be saved if the user visits it after several days. Likewise, the interests of the users can be stored in such a cookie, which is used for range measurement or marketing purposes. Third-party cookies are cookies that are offered by providers other than the person responsible for operating the online service (otherwise, if it is only their cookies, it is called “first-party cookies”).

We may use temporary and permanent cookies and provide information on this in our privacy policy.

If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional limitations of this online offer.

A general objection to the use of cookies used for online marketing purposes can be declared for many of the services, especially in the case of tracking, via the US site https://optout.aboutads.info/?c=2&lang=EN or the EU site https://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that in this case not all functions of this online offer can be used.

Deletion of data

The data processed by us will be deleted or limited in their processing in accordance with articles 17 and 18 DSGVO. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory storage obligations. If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

According to legal requirements in Germany, the storage is in particular for 10 years according to §§ 147 para. 1 AO, 257 para. 1 No. 1 and 4, para. 4 HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.) and 6 years according to § 257 para. 1 No. 2 and 3, para. 4 HGB (commercial letters).

According to legal requirements in Austria, the storage is in particular for 7 J according to § 132 para. 1 BAO (accounting documents, vouchers / invoices, accounts, receipts, business documents, statement of income and expenditure, etc.), for 22 years in connection with real estate and for 10 years for documents in connection with electronically provided services, telecommunications, radio and television services provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.

Business-related processing

Additionally we process

Contract data (e.g., object of contract, duration, customer category).
Payment data (e.g., bank details, payment history)

by our customers, interested parties and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

Agency services

We process the data of our customers within the scope of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, 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., e-mail, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of the contract, duration), payment data (e.g., bank details, payment history), usage and meta data (e.g., in the context of evaluation and performance measurement of marketing measures). As a matter of principle, we do not process special categories of personal data, unless they are part of a commissioned processing. Those affected include our customers, interested parties and their customers, users, website visitors or employees as well as third parties. The purpose of processing is to provide contractual services, billing and our customer service. The legal basis of the processing is derived from Art. 6 para. 1 letter b DSGVO (contractual services), Art. 6 para. 1 letter f DSGVO (analysis, statistics, optimization, security measures). We process data which are necessary for the justification and fulfilment of the contractual services and point out the necessity of their disclosure. Disclosure to external parties will only be made if it is necessary within the scope of an order. When processing the data provided to us within the scope of an order, we act in accordance with the instructions of the client and the legal requirements of an order processing in accordance with Art. 28 DSGVO and do not process the data for any other purposes than those specified in the order.

We delete the data after the expiry of statutory warranty and comparable obligations. The necessity of storing the data is reviewed every three years; in the case of statutory archiving obligations, deletion takes place after the expiry of these obligations (6 years in accordance with § 257 para. 1 HGB, 10 years in accordance with § 147 para. 1 AO). In the case of data that has been disclosed to us by the client within the scope of an order, we delete the data in accordance with the specifications of the order, in principle after the end of the order.

Contractual services

We process the data of our contractual partners and interested parties as well as other principals, customers, clients, clients or contractual partners (uniformly referred to as “contractual partners”) in accordance with Art. 6 para. 1 lit. b. DSGVO in order to provide them with our contractual or pre-contractual services. The data processed in this context, the nature, scope and purpose and the necessity of their processing, are determined by the underlying contractual relationship.

The processed data includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g., e-mail addresses and telephone numbers) as well as contract data (e.g., services used, contract contents, contractual communication, names of contact persons) and payment data (e.g., bank details, payment history).

As a matter of principle, we do not process special categories of personal data, unless these are part of a commissioned or contractual processing.

We process data which are necessary for the justification and fulfilment of the contractual services and point out the necessity of their disclosure, if this is not evident to the contractual partners. Disclosure to external persons or companies will only be made if it is necessary within the scope of a contract. When processing the data provided to us within the framework of an order, we act in accordance with the instructions of the client and the legal requirements.

When using our online services, we may store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the interests of the users in protection against misuse and other unauthorized use. This data will not be passed on to third parties, unless it is necessary to pursue our claims in accordance with Art. 6 Par. 1 lit. f. DSGVO or if there is a legal obligation to do so in accordance with Art. 6 para. 1 lit. c. DSGVO.

The data will be deleted when the data is no longer necessary for the fulfilment of contractual or statutory duties of care and for dealing with any warranty or comparable duties, whereby the necessity of keeping the data will be reviewed every three years; otherwise the statutory duties of safekeeping apply.

Administration, financial accounting, office organization, contact management

We process data within the framework of administrative tasks as well as the 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 within the scope of providing our contractual services. The basis for processing is art. 6 par. 1 lit. c. DSGVO, Art. 6 para. 1 lit. f. DSGVO. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose of and our interest in processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion 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 consultants or auditors, as well as other fee agencies 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 these mostly company-related data permanently.

Economic analyses and market research

In order to run our business economically, to identify market trends, wishes of contract partners and users, we analyze the data available to us on business transactions, contracts, inquiries, etc. In doing so, we process inventory data, communication data, contract data, payment data, usage data, meta data on the basis of Art. 6 para. 1 lit. f. DSGVO, whereby the persons concerned include contractual partners, interested parties, customers, visitors and users of our online offer.

The analyses are carried out for the purpose of business management evaluations, marketing and market research. In doing so, we can take into account the profiles of the registered users with information, e.g. on the services they have used. The analyses serve us to increase user-friendliness, to optimize our offer and business efficiency. The analyses serve only us and are not disclosed externally, unless they are anonymous analyses with summarized values.

If these analyses or profiles are personal, they will be deleted or made anonymous upon termination by the user, otherwise after two years from the conclusion of the contract. In all other respects, the macroeconomic analyses and general trend determinations are prepared anonymously wherever possible.

Hosting and e-mail dispatch

The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services as well as technical maintenance services that we use for the purpose of operating this online offer.

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 of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer in accordance with Art. 6 para. 1 lit. f DSGVO in conjunction with Art. 28 DSGVO (conclusion of contract processing agreement).

Collection of access data and log files

We, or our hosting provider, on the basis of our legitimate interests as defined in Art. 6 para. 1 lit. f. DSGVO data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the accessed website, file, date and time of access, transferred data volume, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited site), IP address and the requesting provider.

For security reasons (e.g. to clarify misuse or fraud), log file information is stored for a maximum of 7 days and then deleted. Data whose further storage is required for evidence purposes is excluded from deletion until the respective incident has been finally clarified.

Google Tag Manager

Google Tag Manager is a solution that allows us to manage so-called website tags via an interface (and thus integrate e.g. Google Analytics and other Google marketing services into our online offering). The Tag Manager itself (which implements the tags) does not process any personal user data. With regard to the processing of users’ personal data, we refer to the following information on Google services. Usage guidelines: https://marketingplatform.google.com/intl/de/about/analytics/tag-manager/use-policy/.

Google Analytics

On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) we use Google Analytics, a web analysis service of Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the website by the user is usually transferred to a Google server in the USA and stored there.

Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google will use this information on our behalf to evaluate the use of our website by the users, to compile reports on the activities within this website and to provide us with further services related to the use of this website and the internet. The processed data can be used to create pseudonymous user profiles of the users.

We only use Google Analytics with activated IP anonymization. This means that the IP address of the user 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 is the full IP address transferred 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 accordingly; users can also prevent the collection of data generated by the cookie and related to their use of the online offer to Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

Further information on the use of data by Google, setting and objection options, can be found in the Google privacy policy (https://policies.google.com/technologies/ads) and in the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).

The users’ personal data will be deleted or anonymized after 14 months.

Google AdWords and conversion measurement

Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

We use the Google “AdWords” online marketing process to place ads on Google’s advertising network (e.g., in search results, in videos, on web pages, etc.) to be displayed to users who have a presumed interest in the ads. This allows us to better target ads for and within our online services so that we only show users ads that potentially match their interests. For example, if a user is shown ads for products that he or she has been interested in on other websites, this is called “remarketing”. For these purposes, when you visit our website and other websites on which the Google advertising network is active, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) are incorporated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (instead of cookies, comparable technologies can also be used). This file records which websites the user has visited, what content he is interested in and which offers the user has clicked on, as well as technical information on the browser and operating system, referring websites, visiting time and other information on the use of the online offer.

We also receive an individual “conversion cookie”. The information obtained with the help of the cookie is used by Google to compile conversion statistics for us. However, we only learn the anonymous total number of users who clicked on our ad and were redirected to a page with a conversion tracking tag. We do not receive any information that personally identifies users.

User data is processed pseudonymously within the Google advertising network. This means that Google does not store and process the name or e-mail address of the user, for example, but processes the relevant data cookie-related within pseudonymous user profiles. I.e. from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who that cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymization. The information collected about users is transmitted to Google and stored on Google’s servers in the USA.

Google Doubleclick

We use the Google “Doubleclick” online marketing process to place ads on the Google advertising network (e.g., in search results, in videos, on web pages, etc.). Double Click is characterized by the fact that ads are displayed in real time based on presumed interests of the users. This allows us to display ads for and within our online offering in a more targeted manner, so that we can show users only ads that potentially match their interests. For example, if a user is shown ads for products that he or she has been interested in on other websites, this is called “remarketing”. For these purposes, when you visit our website and other websites on which the Google advertising network is active, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) are incorporated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (instead of cookies, comparable technologies can also be used). This file records which websites the user has visited, what content he is interested in and which offers the user has clicked on, as well as technical information on the browser and operating system, referring websites, visiting time and other information on the use of the online offer.

The IP address of the user is also recorded, whereby this is shortened within member states of the European Union or in other states that are party to the Agreement on the European Economic Area and only in exceptional cases is it transferred in full to a Google server in the USA and shortened there. Google may also combine the above-mentioned information with information from other sources. If the user subsequently visits other websites, advertisements tailored to his or her presumed interests can be displayed on the basis of his or her user profile.

User data is processed pseudonymously within the Google advertising network. This means that Google does not store and process e.g. the name or e-mail address of the user, but processes the relevant data cookie-related within pseudonymous user profiles. I.e. from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who that cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymization. The information collected by Google marketing services about users is transmitted to Google and stored on Google’s servers in the USA.

Integration of third party services and content

We set within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO), we use content or service offers from third parties in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).

Google ReCaptcha

We integrate the function for detecting bots, e.g. when entering data into online forms (“ReCaptcha”) of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://policies.google.com/privacy/privacy/, Opt-Out: https://adssettings.google.com/authenticated.