# Privacy policy | DL Packaging > Originele URL: https://www.dlpack.com/en/privacy-policy - Samenvatting: With the following privacy policy, we would like to inform you about what types of your personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent. Belangrijke onderwerpen: Privacy policy. --- # Privacy policy With the following privacy policy, we would like to inform you about what types of your personal data (hereinafter also referred to as "data") we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer"). The terms used are not gender-specific. Status: 22 November 2023 ## Table of contents * Preamble * Person responsible * Overview of processing * Relevant legal bases * Security measures * Transmission of personal data * International data transfers * Deletion of data * Rights of the data subjects * Use of cookies * Provision of the online offer and web hosting * Contact and enquiry management * Cloud services * Web analysis, monitoring and optimisation * Online marketing * Plugins and embedded functions and content * Amendment and updating of the privacy policy * Definitions of terms ## Person responsible DL Packaging BV  Distributieweg 20  4900 AD Oosterhout  Netherlands E-mail address: info@dlpack.com Telephone: +31 (0)162 484 910 ## Overview of processing The following overview summarises the types of data processed and the purposes of their processing and refers to the data subjects. Types of data processed * Inventory data. * Location data. * Contact details. * Content data. * Usage data. * Meta, communication and process data. * Image and/or video recordings. Categories of affected persons * Customers. * Employees. * Interested parties. * Communication partner. * Users. * Persons depicted. Purposes of the processing * Contact enquiries and communication. * Safety measures. * Reach measurement. * Tracking. * Office and organisational procedures. * Conversion measurement. * Target group formation. * Managing and responding to enquiries. * Feedback. * Marketing. * Profiles with user-related information. * Provision of our online services and user-friendliness. * Information technology infrastructure. ## Relevant legal bases **Relevant legal bases according to the GDPR:** Below you will find an overview of the legal bases of the GDPR on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Should more specific legal bases also apply in individual cases, we will inform you of these in the privacy policy. * **Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR)** - The data subject has given their consent to the processing of their personal data for one or more specific purposes. * **Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR)** - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract. * **Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR)** - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. **National data protection regulations in Germany:** In addition to the data protection regulations of the GDPR, national data protection regulations apply in Germany. These include, in particular, the Act on the 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 erasure, the right to object, 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. The data protection laws of the individual federal states may also apply. **National data protection regulations in the Netherlands:** In addition to the data protection regulations of the GDPR, national data protection regulations apply in the Netherlands. These include in particular the "Implementing Act to the General Data Protection Regulation" (Uitvoeringswet Algemene verordening gegevensbescherming - UAVG). ## Safety measures We take appropriate technical and organisational 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 appropriate to the risk. The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, safeguarding of availability and its separation. Furthermore, we have established procedures that ensure the exercise of data subject rights, the deletion of data and responses to data threats. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes in accordance with the principle of data protection, through technology design and data protection-friendly default settings. TLS/SSL encryption (https): To protect user data transmitted via our online services, we use TLS/SSL encryption. Secure Sockets Layer (SSL) is the standard technology for securing internet connections by encrypting the data transmitted between a website or app and a browser (or between two servers). Transport Layer Security (TLS) is an updated and more secure version of SSL. Hyper Text Transfer Protocol Secure (HTTPS) is displayed in the URL when a website is secured by an SSL/TLS certificate. ## Transmission of personal data As part of our processing of personal data, the data may be transferred to other bodies, companies, legally independent organisational units or persons or disclosed to them. The recipients of this data may include, for example, 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 corresponding contracts or agreements with the recipients of your data that serve to protect your data. Data transfer within the group of companies: We may transfer personal data to other companies within our group of companies or grant them access to this data. If this transfer takes place for administrative purposes, the transfer of the data is based on our legitimate business and commercial interests or takes place if it is necessary to fulfil our contractual obligations or if the consent of the data subjects or legal permission exists. ## International data transfers Data processing in third countries: If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements. If the level of data protection in the third country has been recognised by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data will only be transferred if the level of data protection is otherwise ensured, in particular through standard contractual clauses (Art. 46 para. 2 lit. c) GDPR), express consent or in the case of contractual or legally required transfer (Art. 49 para. 1 GDPR). In addition, we will inform you of the basis for third country transfers with the individual providers from the third country, whereby the adequacy decisions take precedence. Information on third country transfers and existing adequacy decisions can be found in the information provided by the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection\_de. EU-US Trans-Atlantic Data Privacy Framework: As part of the so-called "Data Privacy Framework" (DPF), the EU Commission has also recognised the level of data protection for certain companies from the USA as secure as part of the adequacy decision of 10.07.2023. The list of certified companies and further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/. As part of the data protection information, we will inform you which service providers we use are certified under the Data Privacy Framework. ## Deletion of data The data processed by us will be deleted in accordance with the legal requirements as soon as the consent given for processing is revoked or other authorisations no longer apply (e.g. if the purpose for processing this data no longer applies or it is not required for the purpose). If the data is not deleted because it is required for other and legally permissible purposes, its processing is restricted 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 commercial or tax law reasons or whose storage is necessary for the assertion, exercise or defence of legal claims or to protect the rights of another natural or legal person. As part of our data protection information, we can provide users with further information on the erasure and retention of data that applies specifically to the respective processing operations. ## Rights of the data subjects Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR: * **Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) GDPR, including profiling based on those provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.** * **Right to withdraw consent:** You have the right to withdraw your consent at any time. * **Right of access:** You have the right to obtain confirmation as to whether or not personal data concerning you is being processed and to obtain information about this data and further information and a copy of the data in accordance with the legal requirements. * **Right to rectification**: In accordance with the statutory provisions, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you. * **Right to erasure and restriction of processing:**In accordance with the statutory provisions, you have the right to demand that data concerning you be erased immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions. * **Right to data portability:** You have the right to receive the data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format in accordance with the legal requirements or to request its transmission to another controller. * **Complaint to a supervisory authority:** In accordance with the statutory provisions and without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a data protection supervisory authority, in particular a supervisory authority in the Member State in which you are habitually resident, the supervisory authority of your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR. ## Use of cookies Cookies are small text files or other storage notes that store information on end devices and read information from the end devices. For example, to store the login status in a user account, the contents of a shopping basket in an e-shop, the content accessed or the functions of an online service used. Cookies can also be used for various purposes, e.g. to ensure the functionality, security and convenience of online services and to create analyses of visitor flows. **Notes on consent:** We use cookies in accordance with the statutory provisions. We therefore obtain prior consent from users, unless this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, is absolutely necessary in order to provide the user with a telemedia service expressly requested by them (i.e. our online offering). Strictly necessary cookies generally include cookies with functions that serve the display and operability of the online service, load balancing, security, storage of user preferences and selection options or similar purposes related to the provision of the main and secondary functions of the online service requested by the user. The revocable consent is clearly communicated to the users and contains the information on the respective use of cookies. **Information on legal bases under data protection law:** The legal basis under data protection law on which we process users' personal data with the help of cookies depends on whether we ask users for their consent. If users consent, the legal basis for processing their data is the consent they have given. Otherwise, the data processed using cookies is processed on the basis of our legitimate interests (e.g. in the commercial operation of our online offering and improving its usability) or, if this is done as part of the fulfilment of our contractual obligations, if the use of cookies is necessary to fulfil our contractual obligations. We explain the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing procedures. **Storage period:** With regard to the storage period, a distinction is made between the following types of cookies: * **Temporary cookies (also: session cookies):** Temporary cookies are deleted at the latest after a user has left an online service and closed their end device (e.g. browser or mobile application). * **Permanent cookies:** Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved or favourite content can be displayed directly when the user visits a website again. The user data collected with the help of cookies can also be used to measure reach. If we do not provide users with explicit information on the type and storage duration of cookies (e.g. when obtaining consent), users should assume that cookies are permanent and can be stored for up to two years. **General information on revocation and objection (so-called "opt-out"):** Users can revoke the consent they have given at any time and object to the processing in accordance with the legal requirements. Among other things, users can restrict the use of cookies in their browser settings (although this may also restrict the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. * **Processed data types:** Usage data (e.g. websites visited, interest in content, access times). * **Data subjects:** Users (e.g. website visitors, users of online services). * **Purposes of processing:** Provision of our online services and user-friendliness. * **Legal bases:** Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). **Further information on processing operations, procedures and services:** * **Processing of cookie data on the basis of consent:** We use a cookie consent management procedure in which the user's consent to the use of cookies or the processing and providers named in the cookie consent management procedure can be obtained, managed and revoked by the user. The declaration of consent is stored so that it does not have to be requested again and the consent can be proven in accordance with the legal obligation. The consent can be stored on the server and/or in a cookie (so-called opt-in cookie or with the help of comparable technologies) in order to be able to assign the consent to a user or their device. Subject to individual information on the providers of cookie management services, the following information applies: Consent may be stored for up to two years. A pseudonymous user identifier is created and stored with the time of consent, information on the scope of consent (e.g. which categories of cookies and/or service providers) as well as the browser, system and end device used; **legal basis:** consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). * **Cookiefirst:** Cookie consent management; **Service provider:** Digital Data Solutions B.V., Plantage Middenlaan 42a, 1018 DH Amsterdam, The Netherlands; **Website:** ; **Privacy Policy:** ; **Further information:** Stored data (on the server of the service provider): The user's IP number, date and time of consent, browser details, the URL from which the consent was sent, An anonymous, random and encrypted key value. the user's consent status. ## Consent to the use of cookies. For our website to function properly we use cookies. To obtain your valid consent for the use and storage of cookies in the browser you use to access our website and to properly document this we use a consent management platform: CookieFirst. This technology is provided by Digital Data Solutions BV, Plantage Middenlaan 42a, 1018 DH, Amsterdam, The Netherlands. Website: [[https://cookiefirst.com referred to as CookieFirst.](https://cookiefirst.com "Cookiefirst page") [When you access our website, a connection is established with CookieFirst’s server to give us the possibility to obtain valid consent from you to the use of certain cookies. CookieFirst then stores a cookie in your browser in order to be able to activate only those cookies to which you have consented and to properly document this. The data processed is stored until the predefined storage period expires or you request to delete the data. Certain mandatory legal storage periods may apply notwithstanding the aforementioned.](https://cookiefirst.com "Cookiefirst page") [CookieFirst is used to obtain the legally required consent for the use of cookies. The legal basis for this is article 6(1)(c) of the General Data Protection Regulation (GDPR).](https://cookiefirst.com "Cookiefirst page") ## [Data processing agreement](https://cookiefirst.com "Cookiefirst page") [We have concluded a data processing agreement with CookieFirst. This is a contract required by data protection law, which ensures that data of our website visitors is only processed in accordance with our instructions and in compliance with the GDPR.](https://cookiefirst.com "Cookiefirst page") ## [Server log files](https://cookiefirst.com "Cookiefirst page") [Our website and CookieFirst automatically collect and store information in so-called server log files, which your browser automatically transmits to us. The following data is collected:](https://cookiefirst.com "Cookiefirst page") * [Your consent status or the withdrawal of consent](https://cookiefirst.com "Cookiefirst page") * [Your anonymised IP address](https://cookiefirst.com "Cookiefirst page") * [Information about your Browser](https://cookiefirst.com "Cookiefirst page") * [Information about your Device](https://cookiefirst.com "Cookiefirst page") * [The date and time you have visited our website](https://cookiefirst.com "Cookiefirst page") * [The webpage url where you saved or updated your consent preferences](https://cookiefirst.com "Cookiefirst page") * [The approximate location of the user that saved their consent preference](https://cookiefirst.com "Cookiefirst page") * [A universally unique identifier (UUID) of the website visitor that clicked the cookie banner](https://cookiefirst.com "Cookiefirst page") ## [Provision of the online offer and web hosting](https://cookiefirst.com "Cookiefirst page") [We process users' data in order to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or end device.](https://cookiefirst.com "Cookiefirst page") * [**Processed data types:** Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).](https://cookiefirst.com "Cookiefirst page") * [**Data subjects:** Users (e.g. website visitors, users of online services).](https://cookiefirst.com "Cookiefirst page") * [**Purposes of processing:** Provision of our online offer and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)). Security measures.](https://cookiefirst.com "Cookiefirst page") * [**Legal basis:** Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).](https://cookiefirst.com "Cookiefirst page") [**Further information on processing operations, procedures and services:**](https://cookiefirst.com "Cookiefirst page") * [**Provision of online offer on rented storage space:** For the provision of our online offer, we use storage space, computing capacity and software that we rent or otherwise obtain from a corresponding server provider (also called "web host"); **Legal basis:** Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).](https://cookiefirst.com "Cookiefirst page") * [**Collection of access data and log files:**Access to our online offering is logged in the form of so-called "server log files". The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider. The server log files may be used for security purposes, e.g. to avoid overloading the servers (especially in the event of abusive attacks, so-called DDoS attacks) and to ensure the utilisation of the servers and their stability; **legal basis**: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). **Deletion of data:** Log file information is stored for a maximum of 30 days and then deleted or anonymised. Data whose further storage is required for evidentiary purposes is excluded from erasure until the respective incident has been finally clarified.](https://cookiefirst.com "Cookiefirst page") * [**LeaseWeb Netherlands B.V.**: services in the field of the provision of information technology infrastructure and related services (e.g. storage space and/or computing capacity;**service provider:** Leaseweb Netherlands B.V. Hessenbergweg 95  1101 CX Amsterdam; **Website**: https://www.leaseweb.com/nl. **Privacy Policy:** https://www.leaseweb.com/de/gesetze-zum-schutz-personenbezogener-daten.](https://cookiefirst.com "Cookiefirst page") ## [Contact and enquiry management](https://cookiefirst.com "Cookiefirst page") [When contacting us (e.g. by post, contact form, email, telephone or via social media) and in the context of existing user and business relationships, the data of the enquiring persons are processed insofar as this is necessary to answer the contact enquiries and any requested measures.](https://cookiefirst.com "Cookiefirst page") * [**Processed data types:**Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status).](https://cookiefirst.com "Cookiefirst page") * [**Affected persons:** Communication partner.](https://cookiefirst.com "Cookiefirst page") * [**Purposes of processing:** Contact enquiries and communication; managing and responding to enquiries; feedback (e.g. collecting feedback via online form). Provision of our online services and user-friendliness.](https://cookiefirst.com "Cookiefirst page") * [**Legal bases:** Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Contract fulfilment and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR).](https://cookiefirst.com "Cookiefirst page") [**Further information on processing operations, procedures and services:**](https://cookiefirst.com "Cookiefirst page") * [**Contact form:** If users contact us via our contact form, e-mail or other communication channels, we process the data provided to us in this context to process the communicated request; legal basis: fulfilment of contract and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b) GDPR), legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).](https://cookiefirst.com "Cookiefirst page") ## [Cloud services](https://cookiefirst.com "Cookiefirst page") [We use software services accessible via the internet and running on the servers of their providers (so-called "cloud services", also referred to as "software as a service") for the storage and management of content (e.g. document storage and management, exchange of documents, content and information with specific recipients or publication of content and information).](https://cookiefirst.com "Cookiefirst page") [In this context, personal data may be processed and stored on the provider's servers if they are part of communication processes with us or are otherwise processed by us as set out in this privacy policy. This data may include, in particular, master data and contact data of users, data on transactions, contracts, other processes and their content. The cloud service providers also process usage data and metadata that they use for security purposes and to optimise their services.](https://cookiefirst.com "Cookiefirst page") [If we use cloud services to provide other users or publicly accessible websites with forms or other documents and content, the providers may store cookies on users' devices for the purposes of web analysis or to remember user settings (e.g. in the case of media control).](https://cookiefirst.com "Cookiefirst page") * [**Processed data types:** Inventory data (e.g. names, addresses); Contact data (e.g. e-mail, telephone numbers); Content data (e.g. entries in online forms); Usage data (e.g. websites visited, interest in content, access times); Meta, communication and process data (e.g. IP addresses, time data, identification numbers, consent status); Image and/or video recordings (e.g. photographs or video recordings of a person).](https://cookiefirst.com "Cookiefirst page") * [**Affected persons:**Customers; employees (e.g. employees, applicants, former employees); interested parties; communication partners. Persons depicted.](https://cookiefirst.com "Cookiefirst page") * [**Purposes of processing:**Office and organisational procedures. Information technology infrastructure (operation and provision of information systems and technical equipment (computers, servers, etc.)).](https://cookiefirst.com "Cookiefirst page") * [**Legal basis:** Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).](https://cookiefirst.com "Cookiefirst page") [**Further information on processing operations, procedures and services:**](https://cookiefirst.com "Cookiefirst page") * [**Google Photos:** Online service for storing images and videos; **Service provider:** Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; **Legal basis:** Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); **Website**: https://www.google.com/photos/about/. **Privacy Policy:**https://policies.google.com/privacy.](https://cookiefirst.com "Cookiefirst page") ## [Web analysis, monitoring and optimisation](https://cookiefirst.com "Cookiefirst page") [Web analysis (also referred to as "reach measurement") is used to evaluate the flow of visitors to our online offering and may include behaviour, interests or demographic information about visitors, such as age or gender, as pseudonymous values. With the help of reach analysis, we can, for example, recognise at what time our online offering or its functions or content are most frequently used or invite visitors to reuse them. We can also understand which areas require optimisation.](https://cookiefirst.com "Cookiefirst page") [In addition to web analysis, we may also use test procedures, e.g. to test and optimise different versions of our online offering or its components.](https://cookiefirst.com "Cookiefirst page") [Unless otherwise stated below, profiles, i.e. data summarised for a usage process, can be created for these purposes and information can be stored in a browser or in an end device and read out from it. The information collected includes, in particular, websites visited and the elements used there as well as technical information 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 from us or from the providers of the services we use, location data may also be processed.](https://cookiefirst.com "Cookiefirst page") [The IP addresses of users are also stored. However, we use an IP masking procedure (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as email addresses or names) is stored in the context of web analysis, A/B testing and optimisation, but pseudonyms. This means that we and the providers of the software used do not know the actual identity of the users, but only the information stored in their profiles for the purposes of the respective processes.](https://cookiefirst.com "Cookiefirst page") * [**Processed data types:**Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).](https://cookiefirst.com "Cookiefirst page") * [**Data subjects:** Users (e.g. website visitors, users of online services).](https://cookiefirst.com "Cookiefirst page") * [**Purposes of processing:**Reach measurement (e.g. access statistics, recognition of returning visitors). Profiles with user-related information (creation of user profiles).](https://cookiefirst.com "Cookiefirst page") * [**Security measures:** IP masking (pseudonymisation of the IP address).](https://cookiefirst.com "Cookiefirst page") * [**Legal basis:**Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).](https://cookiefirst.com "Cookiefirst page") [**Further information on processing operations, procedures and services:**](https://cookiefirst.com "Cookiefirst page") * [**Google Analytics in consent mode**: In consent mode, personal user data is processed by Google for measurement and advertising purposes, depending on the user's consent. Consent is obtained from users as part of our online services. If users do not give their consent at all, the data will only be processed at an aggregated level (i.e. not assigned to individual users and summarised). If the consent only includes statistical measurement, no personal data of the users will be processed for the placement of adverts or the measurement of advertising success (so-called "conversion"); **legal basis:** Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR). **Website**: https://support.google.com/analytics/answer/9976101?hl=de.](https://cookiefirst.com "Cookiefirst page") * [**Google Tag Manager:** Google Tag Manager is a solution with which we can manage so-called website tags via an interface and thus integrate other services into our online offering (please refer to further information in this privacy policy). The Tag Manager itself (which implements the tags) therefore does not create user profiles or store cookies, for example. Google only learns the IP address of the user, which is necessary to run the Google Tag Manager; **service provider:**Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; **Legal basis:** Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR); **Website**: https://marketingplatform.google.com; **Privacy Policy:** https://policies.google.com/privacy; **Data processing agreement:**https://business.safety.google/adsprocessorterms. **Basis for third country transfers:** EU-US Data Privacy Framework (DPF), Standard Contractual Clauses (https://business.safety.google/adsprocessorterms).](https://cookiefirst.com "Cookiefirst page") * [**LinkedIn Ads (Analytics):** Web analysis, reach measurement and analysis of user behaviour in terms of usage and interests regarding functions and content as well as their duration of use on the basis of a pseudonymous user identification number and profile creation; **service provider**: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; **Website**: https://de.linkedin.com/company/webalyse-marketing-&-consulting-gmbh. **Privacy Policy:** https://de.linkedin.com/legal/privacy-policy .](https://cookiefirst.com "Cookiefirst page") ## [Online marketing](https://cookiefirst.com "Cookiefirst page") [We process personal data for online marketing purposes, which may include in particular the marketing of advertising space or 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.](https://cookiefirst.com "Cookiefirst page") [For these purposes, so-called user profiles are created and stored in a file (so-called "cookie") or similar procedures are used, by means of which the user information relevant for the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on usage times and functions used. If users have consented to the collection of their location data, this can also be processed.](https://cookiefirst.com "Cookiefirst page") [The IP addresses of users are also stored. However, we use available IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that neither we nor the providers of the online marketing processes know the actual identity of the users, but only the information stored in their profiles.](https://cookiefirst.com "Cookiefirst page") [The information in the profiles is generally stored in cookies or by means of similar procedures. These cookies can generally also be read later on other websites that use the same online marketing process, analysed for the purpose of displaying content and supplemented with further data and stored on the server of the online marketing process provider.](https://cookiefirst.com "Cookiefirst page") [In exceptional cases, 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 processes we use and the network links the user profiles with the aforementioned data. Please note that users can make additional agreements with the providers, e.g. by giving their consent during registration.](https://cookiefirst.com "Cookiefirst page") [In principle, we only receive access to summarised information about the success of our advertisements. However, as part 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.](https://cookiefirst.com "Cookiefirst page") [Unless otherwise stated, we ask you to assume that cookies used are stored for a period of two years.](https://cookiefirst.com "Cookiefirst page") * [**Processed data types:** Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status).](https://cookiefirst.com "Cookiefirst page") * [**Data subjects:** Users (e.g. website visitors, users of online services).](https://cookiefirst.com "Cookiefirst page") * [**Purposes of Processing:** Web Analytics (e.g. access statistics, recognition of returning visitors); Targeting (e.g. profiling based on interests and behaviour, use of cookies); Marketing; Profiles with user-related information (Creating user profiles); Provision of our online services and usability; Conversion tracking (Measurement of the effectiveness of marketing activities). Target group formation.](https://cookiefirst.com "Cookiefirst page") * [**Security measures:** IP masking (pseudonymisation of the IP address).](https://cookiefirst.com "Cookiefirst page") * [**Legal bases:** Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).](https://cookiefirst.com "Cookiefirst page") * [**Possibility of objection (opt-out):** We refer you to the data protection notices of the respective providers and the opt-out options specified for the providers (so-called "opt-out"). If no explicit opt-out option has been specified, you have the option of switching off cookies in your browser settings. However, this may restrict the functions of our online offering. We therefore recommend the following additional opt-out options, which are summarised for the respective regions:  a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices.       c) USA: https: //www.aboutads.info/choices. d) Cross-territory: https://optout.aboutads.info.](https://cookiefirst.com "Cookiefirst page") [**Further information on processing operations, procedures and services:**](https://cookiefirst.com "Cookiefirst page") * **Google Ad Manager (formerly Doubleclick)**: We use the "Google Ad Manager (formerly Doubleclick)" service to place adverts in the Google advertising network (e.g. in search results, in videos, on websites, etc.). Google Ad Manager (formerly Doubleclick) is characterised by the fact that ads are displayed in real time based on the presumed interests of users. This allows us to display adverts for our online offering to users who may have a potential interest in our offering or have previously shown an interest in it, and to measure the success of the adverts; **service provider:** Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; **Legal basis:** Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); **Website:** ; **Privacy Policy:** ; **Basis for transfer to third countries:** EU-US Data Privacy Framework (DPF); **Further information:** Types of processing and data processed: ; Data processing conditions for Google advertising products: Information on the services Data processing terms between controllers and standard contractual clauses for third country transfers of data: . If Google acts as a processor, data processing terms for Google advertising products and standard contractual clauses for third country transfers of data: . * [**LinkedIn adverts:** Placement of adverts within the LinkedIn platform and analysis of the ad results; **Service provider:** LinkedIn Ireland Unlimited Company, Wilton Plaza Wilton Place, Dublin 2, Ireland; **Legal basis:** Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR), **Legitimate interests** (Art. 6 para. 1 sentence 1 lit. f) GDPR); **Website**: https://business.linkedin.com/de-de/marketing-solutions/ads; **Privacy Policy:** https://www.linkedin.com/legal/privacy-policy; **Basis for third country transfer:** Standard Contractual Clauses (https://de.linkedin.com/legal/l/dpa); **Opt-Out:**https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. **Further information:**https://legal.linkedin.com/dpa.](https://cookiefirst.com "Cookiefirst page") ## E-mailmarketing For sending our newsletters and email marketing, we use the Mailchimp platform, a service of Intuit Inc., 2700 Coast Avenue, Mountain View, CA 94043, United States. When you subscribe to our newsletter, we process the following information: * Email address * Name (if provided) * Any additional information you voluntarily provide * Technical data such as IP address and subscription timestamp (for proof of consent) **Purpose of Processing** We process this data exclusively for: * Sending newsletters * Marketing and promotional communications * Analysis of open and click behavior to optimize our communications **Legal Basis** Processing takes place on the basis of: * Your consent (Art. 6(1)(a) GDPR) You can withdraw your consent at any time via the unsubscribe link at the bottom of each newsletter or by contacting us at info@dlpack.com. **Processor and Data Transfer** Mailchimp acts as a processor under the GDPR and processes personal data exclusively on our behalf, in accordance with the Data Processing Agreement (DPA) included in Mailchimp’s Terms of Use. The full Mailchimp Data Processing Agreement can be viewed here: Mailchimp is based in the United States. This means personal data may be transferred to and processed in a country outside the European Economic Area (EEA). Transfers take place on the basis of: * The EU-U.S. Data Privacy Framework (if applicable), and/or * Standard Contractual Clauses approved by the European Commission (Art. 46 GDPR) These provide appropriate safeguards for the protection of your personal data. **Retention Period** Your data is retained as long as you are subscribed to our newsletter. After unsubscribing, your data will be removed from the active mailing list. We may retain your email address in a suppression list to prevent accidental re-subscription. **Your Rights** You have the right to: * Access your personal data * Request correction or deletion * Request restriction of processing * Object to processing * Withdraw your consent Requests can be directed to info@dlpack.com.  ## [Plugins and embedded functions and content](https://cookiefirst.com "Cookiefirst page") [We incorporate functional and content elements into our online offering that are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These may be, for example, graphics, videos or city maps (hereinafter uniformly referred to as "content").](https://cookiefirst.com "Cookiefirst page") [The integration always requires that the third-party providers of this content process the IP address of the user, as they would not be able to send the content to their browser without the IP address. The IP address is therefore required to display this content or function. We endeavour to only use content whose respective providers only use the IP address 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. Pixel tags can be used to analyse information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring websites, time of visit and other information about the use of our online offer, as well as being linked to such information from other sources.](https://cookiefirst.com "Cookiefirst page") * [**Processed data types:** Usage data (e.g. websites visited, interest in content, access times); meta, communication and procedural data (e.g. IP addresses, time data, identification numbers, consent status). Location data (information on the geographical position of a device or person).](https://cookiefirst.com "Cookiefirst page") * [**Data subjects:** Users (e.g. website visitors, users of online services).](https://cookiefirst.com "Cookiefirst page") * [**Purposes of processing:**Provision of our online services and user-friendliness.](https://cookiefirst.com "Cookiefirst page") * [**Legal basis:**Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).](https://cookiefirst.com "Cookiefirst page") [**Further information on processing operations, procedures and services:**](https://cookiefirst.com "Cookiefirst page") * [**Google Fonts (obtained from the Google server):** Obtaining fonts (and symbols) for the purpose of a technically secure, maintenance-free and efficient use of fonts and symbols with regard to up-to-dateness and loading times, their uniform presentation and consideration of possible licence restrictions. The provider of the fonts is informed of the user's IP address so that the fonts can be made available in the user's browser. In addition, technical data (language settings, screen resolution, operating system, hardware used) are transmitted that are necessary for the provision of the fonts depending on the devices used and the technical environment. This data may be processed on a server of the font provider in the USA - When visiting our online offering, users' browsers send their browser HTTP requests to the Google Fonts Web API (i.e. a software interface for retrieving fonts). The Google Fonts Web API provides users with the Google Fonts Cascading Style Sheets (CSS) and then the fonts specified in the CCS. These HTTP requests include (1) the IP address used by the respective user to access the Internet, (2) the requested URL on the Google server and (3) the HTTP headers, including the user agent, which describes the browser and operating system versions of the website visitors, as well as the referral URL (i.e. the web page on which the Google font is to be displayed). IP addresses are neither logged nor stored on Google servers and are not analysed. The Google Fonts Web API logs details of HTTP requests (requested URL, user agent and referrer URL). Access to this data is restricted and strictly controlled. The requested URL identifies the font families for which the user wishes to load fonts. This data is logged so that Google can determine how often a particular font family is requested. With the Google Fonts Web API, the user agent must adapt the font that is generated for the respective browser type. The user agent is primarily logged for debugging and used to generate aggregated usage statistics to measure the popularity of font families. These summarised usage statistics are published on the "Analyses" page of Google Fonts. Finally, the referral URL is logged so that the data can be used for production maintenance and to generate an aggregated report on the top integrations based on the number of font requests. According to its own information, Google does not use any of the information collected by Google Fonts to create profiles of end users or to place targeted adverts; **service provider:** Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland; **Legal basis:** Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); **Website**:  https://fonts.google.com/; Privacy Policy: https://policies.google.com/privacy; **Basis for transfer to third countries:** EU-US Data Privacy Framework (DPF). **Further information:**  https://developers.google.com/fonts/faq/privacy?hl=de.](https://cookiefirst.com "Cookiefirst page") * [**Google Maps:** We integrate the maps of the "Google Maps" service provided by Google. The processed data may include, in particular, IP addresses and user location data; **Service provider:** Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland; **Legal basis:** Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); **Website**: https://mapsplatform.google.com/; **Privacy Policy:** https://policies.google.com/privacy. **Basis for transfer to third countries:** EU-US Data Privacy Framework (DPF).](https://cookiefirst.com "Cookiefirst page") ## [Amendment and updating of the privacy policy](https://cookiefirst.com "Cookiefirst page") [We ask you to inform yourself regularly about the content of our privacy policy. We will amend the privacy policy as soon as changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.](https://cookiefirst.com "Cookiefirst page") [If we provide addresses and contact information of companies and organisations in this privacy policy, please note that the addresses may change over time and please check the information before contacting us.](https://cookiefirst.com "Cookiefirst page") [Supervisory authority responsible for us:](https://cookiefirst.com "Cookiefirst page") [AUTORITEIT PERSOONSGEGEVENS  Hoghe Nieuwstraat 8  2514 EL Den Haag Postal address  P.O. Box 93374  2509 AJ Den Haag  +34 (0) 88 18005 250 https://autoriteitpersoonsgegevens.nl/en/contact](https://cookiefirst.com "Cookiefirst page") ## [Definitions of terms](https://cookiefirst.com "Cookiefirst page") [This section provides you with an overview of the terms used in this privacy policy. Insofar as the terms are defined by law, their legal definitions apply. The following explanations, on the other hand, are primarily intended to aid understanding.](https://cookiefirst.com "Cookiefirst page") * [**Conversion measurement:**Conversion measurement (also referred to as "visit action evaluation") is a process that can be used to determine the effectiveness of marketing measures. For this purpose, a cookie is usually stored on the user's device within the websites on which the marketing measures take place and then retrieved again on the target website. For example, this allows us to track whether the adverts we have placed on other websites have been successful.](https://cookiefirst.com "Cookiefirst page") * [**Personal data:** "Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.](https://cookiefirst.com "Cookiefirst page") * [**Profiles with user-related information:** The processing of "profiles with user-related information", or "profiles" for short, includes any type of automated processing of personal data that consists of using this personal data to analyse, evaluate or predict certain personal aspects relating to a natural person (depending on the type of profiling, this may include various information relating to demographics, behaviour and interests, such as interaction with websites and their content, etc.) (e.g. interests in certain content or products, click behaviour on a website or location). Cookies and web beacons are often used for profiling purposes.](https://cookiefirst.com "Cookiefirst page") * [**Reach measurement:** Reach measurement (also known as web analytics) is used to evaluate the flow of visitors to an online offering and can include the behaviour or interests of visitors in certain information, such as website content. With the help of reach analysis, operators of online services can, for example, recognise at what time users visit their websites and what content they are interested in. This enables them, for example, to better customise the content of their websites to the needs of their visitors. Pseudonymous cookies and web beacons are often used for reach analysis purposes in order to recognise returning visitors and thus obtain more precise analyses of the use of an online offering.](https://cookiefirst.com "Cookiefirst page") * [**Location data:** Location data is generated when a mobile device (or another device with the technical requirements for location determination) connects to a radio cell, a WLAN or similar technical means and functions of location determination. Location data is used to indicate the geographically determinable position on earth at which the respective device is located. Location data can be used, for example, to display map functions or other location-dependent information.](https://cookiefirst.com "Cookiefirst page") * [**Tracking**: The term "tracking" is used when the behaviour of users can be traced across several online offers. As a rule, behaviour and interest information is stored in cookies or on the servers of the providers of the tracking technologies with regard to the online offers used (so-called profiling). This information can then be used, for example, to display adverts to users that are likely to match their interests.](https://cookiefirst.com "Cookiefirst page") * [**Controller**: The "controller" is 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.](https://cookiefirst.com "Cookiefirst page") * [**Processing**: "Processing" means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and encompasses practically every handling of data, whether it is collecting, analysing, storing, transmitting or deleting.](https://cookiefirst.com "Cookiefirst page") * [**Target group formation:** Target group formation (custom audiences) is when target groups are determined for advertising purposes, e.g. the display of adverts. For example, based on a user's interest in certain products or topics on the internet, it can be concluded that this user is interested in adverts for similar products or the online shop in which they viewed the products. In turn, "lookalike audiences" (or similar target groups) are when the content deemed suitable is displayed to users whose profiles or interests presumably correspond to the users for whom the profiles were created. Cookies and web beacons are generally used for the purpose of creating custom audiences and lookalike audiences.](https://cookiefirst.com "Cookiefirst page")