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 websites, functions and contents connected to it, as well as external online presences, such as our social media profile (hereinafter collectively referred to as “online offer”). With regard to the terms used, such as “processing” or “responsible person”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Nils Christensen, IBC – Internet Business Christensen
Email: info (at) washingtonnewsday.com
Link to the imprint: https://washingtonnewsday.com/about-us/
Types of data processed:
– Inventory data (e.g., names, addresses).
– Contact details (e.g., email, telephone numbers).
– Content data (e.g., text input, photographs, videos).
– Usage data (e.g., websites visited, 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 refer to the data subjects collectively as “users”).
Purpose of processing
– Providing the online offer, its functions and content.
– Answering contact requests and communicating with users.
– Safety measures.
– Range measurement / marketing
“Personal data” is all information that relates to an identified or identifiable natural person (hereinafter “data subject”); A natural person is considered to be identifiable if he or she can be identified directly or indirectly, in particular by assigning an identifier such as a name, an identification number, location data, an online identifier (eg cookie) or one or more special features, expressing the physical, physiological, genetic, psychological, economic, cultural or social identity of this natural person.
“Processing” is any process or series of processes carried out with or without the help of automated processes in connection with personal data. The term goes far and covers practically every handling of data.
“Pseudonymization” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without the use of additional information, provided that this additional information is kept separately and is subject to technical and organizational measures that ensure that the personal data are not assigned to an identified or identifiable natural person;
“Profiling” means any type of automated processing of personal data, which consists in the fact that this personal data is used to evaluate certain personal aspects relating to a natural person, in particular aspects relating to work performance, economic situation, health, personal Analyze or predict the preferences, interests, reliability, behavior, location or change of location of this natural person;
The “person responsible” is the natural or legal person, public authority, agency or other body that alone or together with others decides on the purposes and means of processing personal data.
“Processor” means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller;
Relevant legal bases
In accordance with Art. 13 GDPR, we will inform you of the legal basis for our data processing. Unless the legal basis is mentioned in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 Para. 1 lit. a and Art. 7 GDPR, the legal basis for processing for the 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 case, Art. 6 Para. 1 lit. serves to ensure that the vital interests of the data subject or another natural person require the processing of personal data. d GDPR serves as the legal basis.
In accordance with Art. 32 GDPR, we take appropriate technical considerations, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing as well as the different probability and severity of the risk to the rights and freedoms of natural persons and organizational measures to ensure a level of protection appropriate to the risk.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling the physical access to the data, as well as the access, input, transfer, securing of availability and their separation. Furthermore, we have set up procedures that guarantee the exercise of data subject rights, deletion of data and reaction to data threats. We also take the protection of personal data into account when developing or selecting hardware, software and processes, in accordance with the principle of data protection through technology design and data protection-friendly default settings (Art. 25 GDPR).
Cooperation with processors and third parties
If we disclose data to other people and companies (processors or third parties) as part of our processing, transmit them to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g. if the data is transmitted to third parties, as required by payment service providers, in accordance with Art. 6 Para. 1 lit.
If we commission third parties to process data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 GDPR.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done as part of the use of third-party services or disclosure or transmission of data to third parties, this will only take place if it happens to fulfill our (pre) contractual obligations, based on your consent, on the basis of 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 if the special requirements of Art. 44 ff. GDPR are met. Ie the processingis carried out, for example, 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 contractual clauses”).
Rights of the data subjects
You have the right to request confirmation as to whether the data in question are being processed and for information about this data and for further information and a copy of the data in accordance with Art. 15 GDPR.
You have accordingly. Art. 16 DSGVO the right to request the completion of the data concerning you or the correction of the incorrect data concerning you.
In accordance with Art. 17 GDPR, you have the right to request that the data in question be deleted immediately, or alternatively, in accordance with Art. 18 GDPR, to request that the processing of the data be restricted.
You have the right to request that the data concerning you, which you have provided to us, be received in accordance with Art. 20 GDPR and to request their transmission to other responsible persons.
You have also gem. Art. 77 GDPR the right to file a complaint with the responsible supervisory authority.
Right of withdrawal
You have the right to give consent in accordance with Revoke Art. 7 Para. 3 GDPR with effect for the future
Right to object
You can object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection can in particular be made against processing for direct marketing purposes.
Cookies and right to object to direct mail
“Cookies” are small files that are stored on users’ computers. 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 their visit within an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. Such a cookie can be used, for example, to store the contents of a shopping cart in an online shop or a login status. Cookies are referred to as “permanent” or “persistent” and remain saved even after the browser is closed. For example, the login status can be saved, if users visit them after several days. Such a cookie can also be used to store the interests of users who are used for range measurement or marketing purposes. A “third party cookie” refers to cookies that are offered by providers other than the person responsible for operating the online offer (otherwise, if they are only their cookies, we speak of “first party cookies”).
We can use temporary and permanent cookies and clarify this in the context of our data protection declaration.
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 restrictions of this online offer.
Deletion of data
The data processed by us is deleted in accordance with Art. 17 and 18 GDPR or its processing is restricted. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and there are no statutory retention requirements to prevent deletion. If the data is not deleted because it is required for other and legally permissible purposes, its 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 kept for commercial or tax law reasons.
According to legal requirements in Germany, storage is carried out in particular for 10 years in accordance with §§ 147 Paragraph 1 AO, 257 Paragraph 1 No. 1 and 4, Paragraph 4 HGB (books, records, management reports, booking vouchers, trading books, more relevant for taxation Documents, etc.) and 6 years according to § 257 Paragraph 1 No. 2 and 3, Paragraph 4 HGB (commercial letters).
According to legal requirements in Austria, storage is carried out especially for 7 years in accordance with Section 132 (1) BAO (accounting documents, receipts / invoices, accounts, receipts, business papers, statement of income and expenses, etc.) for 22 years in connection with land and for 10 years for documents in connection with electronically provided services, telecommunication, radio and television services, which are provided to non-entrepreneurs in EU member states and for which the mini-one-stop shop (MOSS) is used.
Business related processing
In addition, we process
– contract data (e.g., subject of contract, term, customer category).
– Payment data (e.g., bank details, payment history)
from our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
The hosting services used by us serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services that we use for the purpose of operating this online offer.
Here, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer based on our legitimate interests in the efficient and secure provision of this online offer in accordance with. Art. 6 para. 1 lit. f GDPR in conjunction with Art. 28 GDPR (conclusion of an order processing contract).
Collection of access data and log files
We, or our hosting provider, based on our legitimate interests within the meaning of Art. 6 Para. 1 lit. f. GDPR 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 website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider .
For security reasons (e.g. to investigate misuse or fraud), log file information is stored for a maximum of 7 days and then deleted. Data whose further storage is necessary for evidence purposes are excluded from deletion until the respective incident has been finally clarified.
Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as the organization of our company, financial accounting and compliance with legal obligations, such as archiving. We process the same data that we process as part of the provision of our contractual services. The processing bases are Art. 6 Para. 1 lit. c. GDPR, Art. 6 Para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose 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.
We disclose or transmit data to the financial administration, consultants such as tax advisors or auditors, as well as other fee agencies and payment service providers.
Furthermore, based on our business interests, we store information about suppliers, organizers and other business partners, e.g. for the purpose of contacting you later. We generally store this mostly company-related data permanently.
Data protection information in the application process
We process the applicant data only for the purpose and as part of the application process in accordance with the legal requirements. The processing of the applicant data takes place to fulfill our (pre) contractual obligations in the context 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, for example, as part of legal procedures (in Germany, § 26 BDSG also applies).
The application process requires applicants to provide us with the applicant data. If we offer an online form, the necessary applicant data is marked, otherwise results from the job descriptions and basically includes information about the person, postal and contact addresses and the documents associated with the application, such as cover letter, curriculum vitae and certificates. In addition, applicants can voluntarily provide us with additional information.
By submitting the application to us, the applicants consent to the processing of their data for the purposes of the application process in accordance with the type and scope set out in this data protection declaration.
Insofar as special categories of personal data within the meaning of Art. 9 Para. 1 GDPR are voluntarily communicated within the scope of the application process, their processing is also 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, their processing is also carried out in accordance with Art. 9 Para. 2 lit. a GDPR (e.g. health data if this is necessary for the exercise of a profession).
If provided, applicants can send us their applications using an online form on our website. The data is encrypted and transmitted to us in accordance with the state of the art.
Applicants can also send us their applications via email. However, please note that emails are generally not sent in encrypted form and applicants must ensure that they are encrypted themselves. We can therefore not assume any responsibility for the transmission path of the application between the sender and receipt on our server and therefore recommend using an online form or sending by post. Because instead of applying via the online form and e-mail, applicants still have the option to send us the application by post.
The data provided by the applicants can be 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 unsuccessful, the applicant’s data will be deleted. Applicant data will also be deleted if an application is withdrawn, which applicants are entitled to do at any time.
The deletion takes place, subject to a justified revocation of the applicants, after a period of six months, so that we can answer any follow-up questions to the application and meet our obligations to provide evidence from the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with tax regulations.
Amazon affiliate program
Users can create a user account. As part of the registration, the required mandatory information is communicated to the users and based on Art. 6 Para. 1 lit. b GDPR processed for the purpose of providing the user account. The processed data include in particular the login information (name, password and an email address). The data entered during registration are used for the purposes of using the user account and its purpose.
Users can be informed by email about information relevant to their user account, such as technical changes. If users have terminated their user account, their data with regard to the user account will be deleted, subject to a legal retention requirement. It is the responsibility of the users to back up their data before termination of the contract if the contract is terminated. We are entitled to irretrievably delete all user data stored during the contract period.
As part of the use of our registration and registration functions and the use of the user account, we will save the IP address and the time of the respective user action. The storage takes place on the basis of our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. This data is not passed on to third parties, unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with. Art. 6 para. 1 lit. c GDPR. The IP addresses are anonymized or deleted after 7 days at the latest.
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the information provided by the user for processing the contact request and processing it in accordance with Art. 6 para. 1 lit. b) GDPR processed. The information provided by users can be stored in a customer relationship management system (“CRM system”) or a comparable request organization.
We delete the requests if they are no longer necessary. We check the necessity every two years; The statutory archiving obligations also apply.
Comments and posts
If users leave comments or other contributions, their IP addresses can be based on our legitimate interests within the meaning of Art. 6 Para. 1 lit. f. GDPR can be stored for 7 days. This is done for our security, if someone leaves illegal content in comments and contributions (insults, forbidden political propaganda, etc.). In this case we can be prosecuted for the comment or contribution and are therefore interested in the identity of the author.
Furthermore, we reserve the right, based on our legitimate interests. Art. 6 para. 1 lit. f. GDPR to process user information for spam detection.
The data provided in the context of the comments and contributions will be permanently saved by us until the user objects.
The follow-up comments can be made by users with their consent in accordance with Art. 6 para. 1 lit. a GDPR. The users will receive a confirmation email to check whether they are the owner of the email address entered. Users can unsubscribe from ongoing comment subscriptions at any time. The confirmation email will contain information about the cancellation options. For the purpose of proving the consent of the users, we save the registration point along with the IP address of the users and delete this information when users unsubscribe from the subscription.
You can cancel the receipt of our subscription menu at any time, ie revoke your consent. Based on our legitimate interests, we can save the e-mail addresses that have been removed for up to three years before we delete them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the previous consent is confirmed.
Akismet anti-spam check
Our online offering uses the “Akismet” service, which is offered by Automattic Inc., 60 29th Street # 343, San Francisco, CA 94110, USA. Use is based on our legitimate interests within the meaning of Art. 6 Para. 1 lit. f) GDPR. With the help of this service, comments from real people are distinguished from spam comments. All comments are sent to a server in the USA, where they are analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data will be saved beyond this time. This information includes the name you entered, the email address, the IP address, the comment content, the referrer, information about the browser used and the computer system and the time of the entry.
Further information on the collection and use of data by Akismet can be found in Automattic’s data protection information: https://automattic.com/privacy/ .
Users are welcome to use pseudonyms, or to refrain from entering their names or email addresses. You can completely prevent the transfer of data by not using our comment system. That would be a shame, but unfortunately we don’t see any other alternatives that work just as effectively.
Retrieval of profile pictures from Gravatar
We use the Gravatar service of Automattic Inc., 60 29th Street # 343, San Francisco, CA 94110, USA, within our online offer and in particular in our blog.
Gravatar is a service where users can log in and store profile pictures and their email addresses. If users leave posts or comments with the respective email address on other online presences (especially in blogs), their profile pictures can be displayed next to the posts or comments. For this purpose, the email address provided by the users is sent to Gravatar in encrypted form in order to check whether a profile is saved for it. This is the only purpose of the transmission of the email address and it will not be used for other purposes, but will be deleted afterwards.
Gravatar is used on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f) GDPR, since with the help of Gravatar we offer the authors of posts and comments the opportunity to personalize their posts with a profile picture.
By displaying the images, Gravatar finds out the user’s IP address, as this is necessary for communication between a browser and an online service. Further information on the collection and use of data by Gravatar can be found in Automattic’s data protection information: https://automattic.com/privacy/.
If users do not want a user image linked to their Gravatar email address to appear in the comments, you should use an email address that is not stored by Gravatar to comment. We would also like to point out that it is also possible to use an anonymous or no e-mail address if the users do not want their own e-mail address to be sent to Gravatar. Users can completely prevent the transfer of data by not using our comment system.
Google is certified under the Privacy Shield Agreement and thereby 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 online offer by the user, to compile reports on the activities within this online offer and to provide us with other services related to the use of this online offer and the internet. Pseudonymous user profiles can be created from the processed data.
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. The full IP address will only be transmitted to a Google server in the USA and abbreviated there in exceptional cases.
The IP address transmitted by the user’s browser is not merged with other Google data. Users can prevent cookies from being saved by making the appropriate settings in their browser software; Users can also prevent Google from collecting the data generated by the cookie and related to their use of the online offer and from processing this data by Google by downloading and installing the browser plug-in available under the following link: http: // tools .google.com / dlpage / gaoptout? hl = de .
Further information on the use of data by Google, setting and objection options can be found in Google’s data protection declaration ( https://policies.google.com/technologies/ads ) and in the settings for the display of advertisements by Google (https: // adssettings.google.com/authenticated ).
The personal data of the users will be deleted or anonymized after 14 months.
Online presence in social media
We maintain online presences within social networks and platforms in order to communicate with the customers, interested parties and users active there and to be able to inform them about our services. When calling up the respective networks and platforms, the terms and conditions and the data processing guidelines of their respective operators apply.
Unless otherwise stated in our data protection declaration, we process the data of users provided that they communicate with us within social networks and platforms, e.g. write posts on our online presence or send us messages.
Integration of services and content from third parties
We use content or service offers from third-party providers within our online offer based on our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. Integrate services such as videos or fonts (hereinafter referred to as “content”).
This always presupposes that the third-party providers of this content perceive the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is therefore required to display this content. We strive to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can 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 can also be stored in cookies on the user’s device and, among other things, technical information about the browser and operating system,
We integrate the videos from the “YouTube” platform from Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Data protection declaration: https://www.google.com/policies/privacy/ , opt-out: https://adssettings.google.com/authenticated .
We integrate the function for detecting bots, e.g. when entering online forms (“ReCaptcha”) from the provider Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Data protection declaration: https://www.google.com/policies/privacy/ , opt-out: https://adssettings.google.com/authenticated .
We integrate the maps of the service “Google Maps” from Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. The processed data can include, in particular, IP addresses and location data of the users, which, however, are not collected without their consent (usually carried out as part of the settings of their mobile devices). The data can be processed in the USA. Data protection declaration: https://www.google.com/policies/privacy/ , opt-out: https://adssettings.google.com/authenticated .
Use of Facebook social plugins
On the basis of our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Article 6 (1) (f) GDPR), we use social plugins (“plugins”) from the social network facebook.com, which operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland (“Facebook”). The plugins can represent interaction elements or content (e.g. videos, graphics or text contributions) and can be recognized by one of the Facebook logos (white “f” on a blue tile, the terms “Like”, “Like” or a “thumbs up” sign ) or are marked with the addition “Facebook Social Plugin”. The list and appearance of the Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/ .
Facebook 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=a2zt0000000GnywAAC&status=Active ).
When a user calls up a function of this online offer that contains such a plugin, his device establishes a direct connection to the Facebook servers. The content of the plug-in is transmitted from Facebook directly to the user’s device, which integrates it into the online offer. User profiles of the users can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore informs the users according to our level of knowledge.
By integrating the plugins, Facebook receives the information that a user has called up the corresponding page of the online offer. If the user is logged into Facebook, Facebook can assign the visit to their Facebook account. If users interact with the plugins, for example by pressing the Like button or leaving a comment, the corresponding information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will find out and save his IP address. According to Facebook, only an anonymized IP address is saved in Germany.
The purpose and scope of the data collection and the further processing and use of the data by Facebook as well as the related rights and setting options for protecting the privacy of users can be found in Facebook’s data protection information: https://www.facebook.com/about/privacy/ .
If a user is a Facebook member and does not want Facebook to collect data about him via this online offer and link it to his member data stored on Facebook, he must log out of Facebook before using our online offer and delete his cookies. Further settings and contradictions regarding the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US website http://www.aboutads.info / choices / or the EU site http://www.youronlinechoices.com/ . The settings are platform-independent, ie they are applied to all devices, such as desktop computers or mobile devices.
Functions and content of the Twitter service offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA can be integrated into our online offer. This may include, for example, content such as images, videos or texts and buttons with which users can express their liking for the content, subscribe to the authors of the content or subscribe to our contributions. If the users are members of the Twitter platform, Twitter can assign the access to the above-mentioned content and functions to the user profiles there. Twitter 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=a2zt0000000TORzAAO&status=Active ). Data protection: https://twitter.com/de/privacy , opt-out: https://twitter.com/personalization .
Google service reCaptcha
We use the Google reCaptcha service to determine whether a person or a computer makes a particular entry in our contact or newsletter form. Google uses the following data to check whether you are a human or a computer: IP address of the device used, the website that you visit with us and on which the captcha is integrated, the date and duration of the visit, the identification data of the device used Browser and operating system type, Google account if you are logged in to Google, mouse movements on the reCaptcha areas and tasks for which you have to identify images. The legal basis for the data processing described is Art. 6 Para. 1 lit. f General data protection regulation. There is a legitimate interest on our part in this data processing,