Privacy policy

Introduction

With the following data protection declaration we would like to inform you about the types of personal data (hereinafter also referred to as "data") 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 in the context of providing our services and, in particular, on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter also referred to collectively as "online offer").

    Status: September 15, 2019

    Table of contents

    Responsible

    Stephan Buchmann
    Erzgießereistr. 1
    80335 Munich

    E-mail address: info@citysim.de

    Phone: +49 (0) 160 95917290

    Legal notice: www.citysim.de

      Overview of the processing operations

      The following table summarises the types of data processed and the purposes of their processing, and refers to the data subjects.

      Types of data processed

      • inventory data (e.g. names, addresses).

      • Content data (e.g. text entries, photographs, videos).

      • Contact details (e.g. e-mail, telephone numbers).

      • Meta/communication data (e.g. device information, IP addresses).

      • Usage data (e.g. websites visited, interest in content, access times).

      • Location data (data indicating the location of an end user's terminal equipment).

      • Contract data (e.g. object of contract, duration, customer category).

      • Payment data (e.g. bank details, invoices, payment history).

      Categories of data subjects

      • Business and contractual partners.

      • Interested parties.

      • customers.

      • Users (e.g. website visitors, users of online services).

      Purpose of processing

      • Provision of our online offer and user-friendliness.

      • Visit action evaluation.

      • Office and organisational procedures.

      • Cross-device tracking (cross-device processing of user data for marketing purposes).

      • Feedback (e.g. collecting feedback via online form).

      • Interest based and behavioral marketing.

      • Contact requests and communication.

      • Conversion measurement (measuring the effectiveness of marketing measures).

      • Profiling (creation of user profiles).

      • Remarketing.

      • Range measurement (e.g. access statistics, recognition of returning visitors).

      • Security measures.

      • Tracking (e.g. interest/behavioural profiling, use of cookies).

      • Contractual benefits and service.

      • Management and response to requests.

      • Target group formation (determination of target groups relevant for marketing purposes or other output of content).

      Relevant legal bases

      In the following, we provide the legal basis of the basic data protection regulation (DSGVO), on the basis of which we process personal data. Please note that in addition to the regulations of the DSGVO, national data protection regulations may apply in your or our country of residence and domicile.

      • Consent (Art. 6 para. 1 sentence 1 letter a FADP) - The data subject has given his or her consent to the processing of personal data relating to him or her for one or more specific purposes.

      • Fulfilment of a contract and pre-contractual requests (Art. 6 para. 1 sentence 1 lit. b. FADP) - The processing is necessary for the performance of a contract to which the data subject is party or for carrying out pre-contractual measures taken at the request of the data subject.

      • Legal obligation (Art. 6 para. 1 sentence 1 lit. c. FADP) - The processing is necessary to fulfil a legal obligation to which the controller is subject.

      • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. FADP) - The processing is necessary to protect the legitimate interests of the controller or of a third party unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data outweigh the processing.

      National data protection regulations in Germany: In addition to the data protection regulations of the basic data protection regulation, national regulations on data protection apply in Germany. These include in particular the law on protection against misuse of personal data in data processing (Federal Data Protection Act - BDSG). In particular, the BDSG contains special regulations on the right to information, the right to deletion, the right of objection, the processing of special categories of personal data, processing for other purposes and transmission as well as automated decision making in individual cases including profiling. Furthermore, it regulates data processing for the purposes of the employment relationship (Section 26 BDSG), in particular with regard to the establishment, implementation or termination of employment relationships and the consent of employees. Furthermore, state data protection laws of the individual federal states may apply.

        Security measures

        We take appropriate technical and organizational measures in accordance with the legal requirements, 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 different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection commensurate with the risk.

        These measures shall include in particular the safeguarding of confidentiality, integrity and availability of data by controlling physical and electronic access to data as well as access, input, disclosure, safeguarding of availability and segregation of data relating thereto. Furthermore, we have established procedures to ensure that data subjects' rights are exercised, data is deleted, and responses are made 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 processes in accordance with the principle of data protection, by designing technology and by using data protection-friendly default settings.

        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 transferred to or disclosed to other bodies, companies, legally independent organisational units or persons. The 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 observe the legal requirements and in particular conclude appropriate contracts or agreements with the recipients of your data which serve to protect 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 if the processing takes place in the context of the use of services of third parties or the disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements.

        Subject to express consent or transfer required by contract or by law, we process or allow the data to be processed only in third countries with a recognised level of data protection, including the US processors certified under the Privacy Shield, or on the basis of special guarantees, such as contractual obligations under so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

        Use of cookies

        Cookies" are small files that are stored on the user's device. Cookies can be used to store different information. The information can include, for example, the language settings on a website, the login status, a shopping cart or the location where a video was watched.

        As a rule, cookies are also used when the interests of a user or his behaviour (e.g. viewing certain content, using functions etc.) on individual websites are stored in a user profile. Such profiles are used to show users e.g. content that corresponds to their potential interests. This procedure is also known as "tracking", i.e. following the potential interests of users. The term "cookies" also includes other technologies that perform the same functions as cookies (e.g., when user information is stored using pseudonymous online identifiers, also known as "user IDs").

        If we use cookies or "tracking" technologies, we will inform you separately in our privacy policy.

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

        Revocation and objection (Opt-Out): Regardless of whether processing is based on consent or legal permission, you have the opportunity at any time to revoke any consent 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 the settings of your browser, e.g. by deactivating the use of cookies (whereby the functionality of our online offer can also be limited by this).

        An objection to the use of cookies for online marketing purposes can be declared by means of a variety of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/ or generally on http://optout.aboutads.info.

        • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Persons concerned: Users (e.g. website visitors, users of online services).

        • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

        Commercial and business services

        We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as "contractual partners") within the scope of contractual and comparable legal relationships as well as associated measures and within the scope of communication with the contractual partners (or pre-contractual), e.g. to answer inquiries.

        We process these data in order to fulfil our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with these data and for the purposes of the business organisation. Within the framework of the applicable law, we only pass on the data of the contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or to fulfil legal obligations or with the consent of the contractual partners (e.g. to participating telecommunication, 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 other forms of processing, e.g. for marketing purposes, within the scope of this data protection declaration.

        We inform the contractual partners which data are required for the above-mentioned purposes before or within the scope of data collection, e.g. in online forms, by means of special marking (e.g. colours) or symbols (e.g. asterisks or similar), or personally.

        We delete the data after expiry of legal warranty and comparable obligations, i.e., in principle 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., for tax purposes usually 10 years). We will delete data that has been disclosed to us by the contractual partner within the scope of an order in accordance with the specifications of the order, generally after the end of the order.

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

        Economic analyses and market research: For economic reasons and in order to be able to identify market trends, wishes of contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., whereby contractual partners, interested parties, customers, visitors and users of our online offer may fall into the group of persons concerned.

        The analyses are carried out for the purpose of business evaluations, marketing and market research (e.g. to determine customer groups with different characteristics). If available, we can take into account the profiles of registered users and their details, e.g. the services they use. The analyses serve solely to serve us and are not disclosed externally, unless they are anonymous analyses with summarised, i.e. anonymised, values. Furthermore, we respect the privacy of the users and process the data for analysis purposes as pseudonymously as possible and, if feasible, anonymously (e.g. as summarized data).

        Shop and e-commerce: We process the data of our customers in order to enable them to select, purchase or order the selected products, goods and related services, as well as their payment and delivery or execution.

        The required information is marked as such within the scope of the ordering or comparable acquisition process and includes the information required for delivery, or provision and invoicing, as well as contact information in order to be able to make any necessary arrangements.

        • Processed data types: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Persons concerned: Interested parties, business and contractual partners, customers.

        • Purposes of the processing: contractual services and support, contact requests and communication, office and organisational procedures, management and response to requests, visit evaluation, interest based and behavioural marketing, profiling (creation of user profiles), security measures.

        • Legal bases: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), Legal obligation (Art. 6 para. 1 sentence 1 lit. c. DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO)

        Payment service provider

        Within the scope of contractual and other legal relationships, due to legal obligations or otherwise based on our legitimate interests, we offer the persons concerned efficient and secure payment options and use other payment service providers in addition to banks and credit institutions (collectively "payment service providers").

        The data processed by the payment service providers include inventory data, such as name and address, bank data, such as account or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient related information. These details are required to carry out the transactions. However, the data entered is only processed by the payment service providers and stored by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the payment service providers may transfer the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard we refer to the General Terms and Conditions and the data protection information of the payment service providers.

        Payment transactions are subject to the terms and conditions and the data protection information of the respective payment service providers, which are available within the respective websites or transaction applications. We also refer to these for further information and the assertion of rights of revocation, information and other affected parties.

        • Processed data types: inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of the contract, duration, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Persons concerned: Customers, interested parties.

        • Purposes of the processing: contractual and service.

        • Legal bases: Fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO)

        Used services and service providers:

        Provision of the online offer and web hosting

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

        The data processed within the framework of the provision of the hosting offer may include all data relating to the users of our online offer, which are generated within the framework 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 other information concerning 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 the purpose of SPAM detection. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted in transit, but (unless an 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 every access to the server (so-called server log files). Server log files may include the address and name of the web pages and files accessed, date and time of access, data volume 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 can be used for security purposes, e.g. to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the capacity utilisation of the servers and their stability.

        • Processed data types: Content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Persons concerned: Users (e.g. website visitors, users of online services).

        • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

        online marketing

        We process personal data for online marketing purposes, which includes in particular the presentation of advertising and other content (collectively referred to as "Content") based on the potential interests of users and the measurement of its effectiveness.

        For these purposes, so-called user profiles are created and stored in a file (a so-called "cookie") or similar procedures are used, by means of which the information about the user relevant for the presentation of the aforementioned contents is stored. This information may include, for example, the content viewed, web pages visited, online networks used, but also communication partners and technical details such as the browser used, the computer system used and information on usage times. If users have consented to the collection of their location data, this data may also be processed.

        The IP addresses of users are also stored. However, we use IP masking procedures (i.e., pseudonymization by shortening the IP address) to protect the users. In general, the online marketing procedure does not store any clear user data (such as e-mail addresses or names), but pseudonyms. This means that we as well as the providers of the online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.

        The information in the profiles is usually stored in the cookies or by similar methods. These cookies can later generally also be read out on other websites that use the same online marketing procedure, analysed for the purpose of presenting content and supplemented with additional data and stored on the server of the online marketing procedure provider.

        As an exception, clear data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing methods we use and the network links the profiles of the users in the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.

        As a matter of principle, we only have access to summarized information about the success of our advertisements. However, in the context of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e., for example, to the conclusion of a contract with us. The conversion measurement is used solely to analyse the success of our marketing measures.

        Notes on legal bases: If we ask users for their consent to use the third party providers, the legal basis for processing data is consent. Otherwise, the users' data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

        Facebook pixel: With the help of the Facebook pixel, Facebook is on the one hand able to determine the visitors of our online offer as a target group for the presentation of ads (so-called "Facebook ads"). Accordingly, we use the Facebook pixel in order to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our online offering or who exhibit certain characteristics (e.g. interest in certain topics or products that can be seen from the websites visited) that we transmit to Facebook (so-called "custom audiences"). With the help of the Facebook pixel, we also want to ensure that our Facebook Ads correspond to the potential interest of the users and do not appear annoying. The Facebook Pixel also enables us to track the effectiveness of Facebook ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook ad (so-called "conversion measurement").

        • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), location data (data indicating the location of an end user's terminal equipment).

        • Persons concerned: Users (e.g. website visitors, users of online services), interested parties.

        • Purposes of processing: Tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, visitor action evaluation, interest-based and behaviour-based marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), reach measurement (e.g. access statistics, recognition of returning visitors), target group formation (determination of target groups relevant for marketing purposes or other output of content), cross-device tracking (cross-device processing of user data for marketing purposes).

        • Security measures: IP masking (pseudonymization of the IP address).

        • Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

        • Possibility of objection (Opt-Out): We refer to the data protection information of the respective providers and the possibilities of objection stated for the providers (so-called \"Opt-Out\"). If no explicit opt-out possibility has been indicated, there is, on the one hand, the possibility that you can switch off cookies in the settings of your browser. However, this can restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary form for the respective areas: a) Europe: https://www.youronlinechoices.eu. (b) Canada: https://www.youradchoices.ca/choices. (c) USA: https://www.aboutads.info/choices. d) Cross-territory: http://optout.aboutads.info.

        Used services and service providers:

        Presence in social networks

        We maintain online presences within social networks in order to communicate with the users active there or to offer information about us there.

        We point out that user data may be processed outside the European Union. This may result in risks for the users, because the enforcement of the users' rights could be made more difficult. With regard to US providers that are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we would like to point out that they thereby undertake to comply with the data protection standards of the EU.

        Furthermore, user data within social networks is usually processed for market research and advertising purposes. Thus, for example, user profiles can be created based on the user behaviour and the resulting interests of the users. The user profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behaviour and interests of the users are stored. Furthermore, data may also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).

        For a detailed presentation of the respective forms of processing and the possibilities of objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.

        Also in the case of requests for information and the assertion of data subject rights, we would like to point out that these can most effectively be asserted with the providers. Only the providers have access to the data of the users and can take appropriate measures and provide information directly. Should you nevertheless require assistance, you can contact us.

        • Processed data types: inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

        • Persons concerned: Users (e.g. website visitors, users of online services).

        • Purposes of processing: contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).

        • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

        Used services and service providers:

        Plugins and embedded functions and content

        We include in our online offer functional and content elements 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 and contributions (hereinafter referred to uniformly as "content").

        The integration always requires that the third party providers of this content process the IP address of the users, as without the IP address they would not be able to send the content to their browsers. The IP address is therefore required to display these contents or functions. We make every effort to use only such content whose respective providers use the IP address only to deliver 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 technical information about the browser and operating system, the websites to be linked, the time of visit and other details about the use of our online offer, as well as being linked to such information from other sources.

        Notes on legal bases: If we ask users for their consent to use the third party providers, the legal basis for processing data is consent. Otherwise, the users' data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this privacy policy.

        • Processed data types: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos), inventory data (e.g. names, addresses).

        • Persons concerned: Users (e.g. website visitors, users of online services).

        • Purposes of processing: Provision of our online offer and user-friendliness, contractual benefits and service, tracking (e.g. interest/behaviour-related profiling, use of cookies), feedback (e.g. collection of feedback via online form), security measures, administration and answering of enquiries.

        • Legal bases: Leg itimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO), consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), performance of the contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO).

        Used services and service providers:

        deletion of data

        The data processed by us will be deleted in accordance with the legal requirements as soon as their consent permitted for processing is revoked or other permissions cease to apply (e.g. if the purpose for which the data were processed ceases to apply or if they are not necessary for the purpose).

        Unless the data are deleted because they are required for other and legally permissible purposes, their processing is limited to these purposes. This means that 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 that must be stored for the purpose of asserting, exercising or defending legal claims or protecting 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 notes of this privacy policy.

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