We maintain social media pages on the networks of Facebook, Instagram, Twitter and Google+. As the operator of these sites, we, together with the operators of the respective social media networks, are the controller within the meaning of Art. 4 No. 7 of the General Data Protection Regulation (GDPR).
II. Use of analyses
In connection with the operation of our social media pages, we use the analysis functions provided to obtain anonymised statistical data about the visitors to our social media pages. When you visit these pages, cookies and similar technologies such as pixel tags, web beacons and local storage by the operators of the social media networks are used, and in each case a unique user code is generated. This user code can be linked to the data of those users who are registered with the social media networks.
Facebook, for example, provides information on the Insights and Facebook pages in its Data Policy.
III. Purpose of the processing
The processing of this information is, among other things, intended to allow the network operators to improve their systems of advertising, which they disseminate via their networks. It is also intended to allow us, as the operator of the social media pages, to obtain statistics which are generated based on the visits to our social media pages. The purpose of this is to manage the marketing of our activities. For example, this allows us to gain knowledge of the tendencies of the profiles of visitors who value our social media pages or use applications of the pages in order to provide them with more relevant content and to develop functions which might be of greater interest to them.
In order to better understand how we can further our business objectives with our social media pages, demographic and geographic analyses are also generated using the information collected and made available to us. We can use this information, for example, to display targeted advertisements based upon the visitor’s interests. We do not obtain any direct knowledge of the visitor’s identity, however. In the case of visitors who use social media networks on multiple devices, the data can be collected and analysed across these devices and, where necessary, across multiple services if the visitors are registered and are logged into their own profile.
The visitor statistics generated will only be made available to us in anonymised form and we have no access to the underlying data.
IV. Legal basis and legitimate interests
We operate our social media pages in order to present ourselves to and communicate with the users of these platforms and other interested persons who visit our social media pages. The personal data of users is processed on the basis of our legitimate interest of presenting the company and its products in an optimal manner (Art. 6   [f] GDPR).
V. Transmission of data to third countries
It is conceivable that some of the data collected will also be processed outside of the European Union by the network operators based in the USA. Facebook Inc. is certified under the EU/U.S. and the Swiss/U.S. “Privacy Shield” programmes and has therefore agreed to comply with the European data protection regulations. Google complies with the data protection regulations of the “EU/U.S. and Swiss/U.S. Privacy Shield” and is registered with the “U.S. Privacy Shield” programme. Twitter also meets the requirements of the “EU/U.S. Privacy Shield” programme.
We ourselves do not disclose any personal data.
VI. Joint responsibility / exercising of data subject rights
Under the agreement that we have with Facebook, Facebook acknowledges the joint responsibility under data protection law regarding so-called Insights Data and assumes significant obligations under data protection law concerning the information of data subjects, data security and the reporting of data privacy breaches. It is also stated in the agreement that Facebook is the primary contact partner when data subject rights (Art. 15–22 GDPR) are exercised. This is because as the provider of the social network, Facebook alone has direct access to the required information and can also directly take any necessary action and provide information. Should our assistance be required, however, you can contact us at any time.
Based, as well, on the agreements which we have with the other operators of social media networks, it makes more sense if these are contacted directly to request information and to exercise further rights of data subjects. This is because as the provider of the analysis functions in the social media networks and of the possibility of integrating company pages into these, it is first and foremost they who have direct access to the required information and who can also directly take any necessary action and provide information. Should our assistance be required, however, you can contact us at any time.
VII. Opportunities to object
Users of Facebook and Instagram can influence the extent to which their user behaviour may be recorded when they visit our Facebook page. Further opportunities to object are offered by the Facebook and Instagram settings and the form to report objections provided by Facebook.
Processing by Google can be objected to here.
You can manage your Twitter settings here. The processing of information by cookies can also be prevented by not allowing cookies from third-party providers in your own browser settings.
VIII. Further information Further information concerning our contact details, the rights that data subjects can exercise against us and how else personal data is processed by us can be accessed in the data privacy information on our website.