thinking about

Privacy Policy

 

  1. 1. Privacy at a glance

General information

The following information provides a straightforward overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to identify you personally. Detailed information on data protection can be found in the privacy policy set out below.

Data collection on this website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. The operator's contact details can be found in the section entitled “Information on the controller” in this Privacy Policy.

How do we collect your data?

Some data is collected when you provide it to us. This may, for example, be data that you enter into a contact form. Other data is collected automatically, or after you have given your consent, by our IT systems when you visit the website. This primarily consists of technical data, such as your internet browser, operating system or the time at which the page was accessed. This data is collected automatically as soon as you enter this website.

What do we use your data for?

Some of the data is collected to ensure that the website can be provided without errors. Other data may be used to analyse your user behaviour. Where contracts can be concluded or initiated through the website, the data submitted may also be processed in connection with contractual offers, orders or other enquiries relating to commissions or services.

What rights do you have regarding your data?

You have the right at any time to obtain information, free of charge, about the origin, recipients and purpose of your stored personal data. You also have the right to request that this data be rectified or erased. If you have given consent to data processing, you may withdraw that consent at any time with effect for the future. You also have the right, in certain circumstances, to request restriction of the processing of your personal data.

You also have the right to lodge a complaint with the competent supervisory authority. You may contact us at any time if you have questions about data protection or wish to exercise any of these rights.

Analytics tools and third-party tools

When you visit this website, your browsing behaviour may be evaluated statistically. This is carried out mainly using analytics tools. Detailed information about these tools is provided in the Privacy Policy below.

  1. Hosting

We host the content of our website with the following provider:

IONOS

The provider is IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany (hereinafter “IONOS”). When you visit our website, IONOS records various log files, including IP addresses. For details, please refer to the IONOS privacy policy: https://www.ionos.de/terms-gtc/terms-privacy. IONOS is used on the basis of Article 6(1)(f) GDPR. We have a legitimate interest in ensuring that our website is displayed as reliably as possible. Where consent has been requested, processing is carried out exclusively on the basis of Article 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as that consent covers the storage of cookies or access to information on the user's device, for example through device fingerprinting, within the meaning of the TDDDG. Consent may be withdrawn at any time.

Data processing agreement

We have entered into a data processing agreement (DPA) for the use of the service referred to above. This is a contract required under data protection law which ensures that the provider processes the personal data of our website visitors only on our instructions and in compliance with the GDPR.

  1. General information and mandatory information

Privacy Policy

The operators of this website take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the applicable data protection legislation and this Privacy Policy. When you use this website, various items of personal data are collected. Personal data is data that can be used to identify you personally. This Privacy Policy explains what data we collect, what we use it for, and how and for what purpose it is processed. Please note that data transmission over the internet, for example when communicating by email, may be subject to security vulnerabilities. Complete protection of data against access by third parties is not possible.

Information on the controller

The controller responsible for data processing on this website is:

Dr. I. M. Lemm

Caspar-Olevian-Str. 87

D - 54295 Trier

Telephone: +49 (0) 15786883857

Email: hello@thinking-about.de

The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of processing personal data, such as names or email addresses.

Storage period

Unless a more specific storage period is stated in this Privacy Policy, your personal data will remain with us until the purpose for processing it no longer applies. If you submit a legitimate request for erasure or withdraw your consent to data processing, your data will be erased unless we have other legally permissible grounds for retaining it, for example retention periods under tax or commercial law. In the latter case, the data will be erased once those grounds no longer apply.

General information on the legal bases for data processing on this website

If you have consented to data processing, we process your personal data on the basis of Article 6(1)(a) GDPR or, where special categories of personal data within the meaning of Article 9(1) GDPR are processed, Article 9(2)(a) GDPR. Where you have expressly consented to the transfer of personal data to third countries, processing is also based on Article 49(1)(a) GDPR. If you have consented to the storage of cookies or to access to information on your device, for example through device fingerprinting, processing is additionally based on Section 25(1) TDDDG. Consent may be withdrawn at any time. Where your data is required for the performance of a contract or for pre-contractual measures, we process it on the basis of Article 6(1)(b) GDPR. We also process your data where this is necessary to comply with a legal obligation, on the basis of Article 6(1)(c) GDPR.

Data may also be processed on the basis of our legitimate interests under Article 6(1)(f) GDPR. The legal basis applicable in each individual case is set out in the relevant sections of this Privacy Policy.

Information on transfers to third countries without an adequate level of data protection and to US companies not certified under the DPF

Among other things, we use tools provided by companies established in third countries that are not regarded as providing an adequate level of data protection, as well as US tools whose providers are not certified under the EU-US Data Privacy Framework (DPF). When these tools are active, your personal data may be transferred to and processed in such countries. We point out that a level of data protection comparable to that in the EU cannot be guaranteed in countries that are not regarded as providing an adequate level of data protection.

We also point out that the USA is, in principle, regarded as providing a level of data protection comparable to that of the EU where the recipient is certified under the EU-US Data Privacy Framework (DPF) or has appropriate additional safeguards in place. Information on transfers to third countries, including the recipients of the data, can be found in this Privacy Policy.

Recipients of personal data

In the course of our activities, we work with various external parties. In some cases, this also requires the transfer of personal data to those external parties.

We disclose personal data to external parties only where this is necessary for the performance of a contract, where we are legally obliged to do so, for example by disclosing data to tax authorities, where we have a legitimate interest in the disclosure under Article 6(1)(f) GDPR, or where another legal basis permits the disclosure. When we use processors, we disclose our customers' personal data only on the basis of a valid data processing agreement. Where processing is carried out jointly, an agreement on joint controllership is concluded.

Withdrawal of your consent to data processing

Many data-processing operations are possible only with your express consent. You may withdraw consent that you have already given at any time. The lawfulness of processing carried out before the withdrawal remains unaffected.

Right to object to data collection in specific cases and to direct marketing (Article 21 GDPR)

Direktwerbung (Art. 21 DSGVO)

IF DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ARTICLE 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT AT ANY TIME, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA. THIS ALSO APPLIES TO PROFILING BASED ON THOSE PROVISIONS. THE RELEVANT LEGAL BASIS FOR PROCESSING CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS THE PERSONAL DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING IS NECESSARY FOR THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS (OBJECTION UNDER ARTICLE 21(1) GDPR).

WHERE YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR SUCH MARKETING. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL NO LONGER BE USED FOR DIRECT MARKETING PURPOSES (OBJECTION UNDER ARTICLE 21(2) GDPR).

Right to lodge a complaint with the competent supervisory authority

In the event of a breach of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or the place of the alleged infringement. This right is without prejudice to any other administrative or judicial remedy.

Right to data portability

You have the right to receive data that we process automatically on the basis of your consent or in performance of a contract, in a commonly used, machine-readable format, either for yourself or for a third party. If you ask for the data to be transferred directly to another controller, this will be done only where technically feasible.

Access, rectification and erasure

Within the framework of the applicable legal provisions, you have the right at any time to obtain information, free of charge, about your stored personal data, its origin and recipients and the purpose of the processing, and where applicable, the right to have that data rectified or erased. You may contact us at any time with questions about personal data or to exercise these rights.

Right to restriction of processing

You have the right to request restriction of the processing of your personal data. You may contact us at any time to exercise this right. The right to restriction of processing applies in the following cases:

• If you contest the accuracy of personal data stored by us, we will generally need time to verify it. For the duration of that verification, you have the right to request restriction of the processing of your personal data. • If the processing of your personal data is or was unlawful, you may request restriction of processing instead of erasure. • If we no longer need your personal data but you require it for the establishment, exercise or defence of legal claims, you have the right to request restriction of processing instead of erasure. • If you have objected under Article 21(1) GDPR, your interests and ours must be weighed against one another. Until it has been determined whose interests prevail, you have the right to request restriction of the processing of your personal data.

If you have restricted the processing of your personal data, that data may, apart from being stored, be processed only with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or a Member State.

SSL/TLS encryption

For security reasons and to protect the transmission of confidential content, such as enquiries that you send to us as the website operator, this website uses SSL/TLS encryption. You can recognise an encrypted connection by the change in your browser's address bar from “http://” to “https://” and by the padlock symbol in the browser. When SSL/TLS encryption is enabled, the data you transmit to us cannot be read by third parties.

Objection to promotional emails

We hereby object to the use of contact details published in connection with our legal notice obligations for the purpose of sending unsolicited advertising or information material. The website operators expressly reserve the right to take legal action in the event of unsolicited promotional information being sent, for example in the form of spam emails.

  1. Data collection on this website

Cookies

Our website uses cookies. Cookies are small data packets and do not cause any damage to your device. They are stored on your device either temporarily for the duration of a session (session cookies) or for a longer period (persistent cookies). Session cookies are automatically deleted when you leave the website. Persistent cookies remain stored on your device until you delete them yourself or they are deleted automatically by your web browser.

Cookies may be set by us (first-party cookies) or by third-party companies (third-party cookies). Third-party cookies allow certain services provided by third parties to be integrated into websites, for example cookies used to process payment services. Cookies perform a variety of functions. Many cookies are technically necessary because certain website functions would not work without them, for example a shopping basket or the display of videos. Other cookies may be used to analyse user behaviour or for advertising purposes.

Cookies that are required to carry out electronic communications, to provide certain functions you have requested, for example a shopping basket, or to optimise the website, for example cookies used for audience measurement, are stored on the basis of Article 6(1)(f) GDPR unless another legal basis is specified.

The website operator has a legitimate interest in storing necessary cookies in order to provide its services without technical errors and in an optimised manner. Where consent has been requested for the storage of cookies or comparable recognition technologies, processing is carried out exclusively on the basis of that consent (Article 6(1)(a) GDPR and Section 25(1) TDDDG). Consent may be withdrawn at any time.

You can configure your browser to notify you when cookies are set and to allow cookies only on a case-by-case basis, to reject cookies in certain cases or generally, and to delete cookies automatically when the browser is closed. Disabling cookies may restrict the functionality of this website. Where additional cookies and services are used on this website, details can be found in this Privacy Policy.

Real Cookie Banner

We use the WordPress plugin Real Cookie Banner on our website to obtain, manage and document the consents required for the use of cookies and comparable technologies. The choices you make are stored on our own web server or in the database of our WordPress installation. Real Cookie Banner uses technically necessary cookies and local-storage entries for this purpose. Technical information is also stored in order to document consent and provide evidence of whether consent was given or refused.

Real Cookie Banner runs entirely on our own web space. According to the provider, neither the settings nor the documented consents are transmitted to the provider's servers during normal operation. Processing is carried out in order to comply with our legal obligations under Article 6(1)(c) GDPR. It serves to manage and document the data-protection choices you have made.

Server log files

The website provider automatically collects and stores information in server log files which your browser automatically transmits to us. This information includes:

• browser type and browser version

• operating system used

• referrer URL

• host name of the accessing computer

• time of the server request

• IP address in anonymised form According to IONOS, visitor data is stored for eight weeks. This data is not combined with data from other sources. It is collected on the basis of Article 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of the website, for which server log files are required.

Contact form

If you send us an enquiry via the contact form, the information you enter in the form, including the contact details you provide there, will be stored by us for the purpose of dealing with your enquiry and any follow-up questions. We will not pass this data on without your consent. This data is processed on the basis of Article 6(1)(b) GDPR where your enquiry is related to the performance of a contract or is necessary in order to take steps prior to entering into a contract. In all other cases, processing is based on our legitimate interest in dealing effectively with enquiries addressed to us (Article 6(1)(f) GDPR), or on your consent (Article 6(1)(a) GDPR) where this has been requested. Consent may be withdrawn at any time.

The data you enter in the contact form will remain with us until you ask us to erase it, withdraw your consent to its storage, or the purpose for storing the data no longer applies, for example once your enquiry has been fully dealt with. Mandatory statutory provisions, in particular retention periods, remain unaffected.

Enquiries by email or telephone

If you contact us by email or telephone, your enquiry, including all personal data arising from it, such as your name and the content of your enquiry, will be stored and processed by us for the purpose of dealing with your request. We will not pass this data on without your consent.

This data is processed on the basis of Article 6(1)(b) GDPR where your enquiry is related to the performance of a contract or is necessary in order to take steps prior to entering into a contract. In all other cases, processing is based on our legitimate interest in dealing effectively with enquiries addressed to us (Article 6(1)(f) GDPR), or on your consent (Article 6(1)(a) GDPR) where this has been requested. Consent may be withdrawn at any time. The data you send us in connection with an enquiry will remain with us until you ask us to erase it, withdraw your consent to its storage, or the purpose for storing the data no longer applies, for example once your enquiry has been fully dealt with. Mandatory statutory provisions, in particular statutory retention periods, remain unaffected.

  1. Analytics tools and advertising

IONOS WebAnalytics

This website uses the analytics services of IONOS WebAnalytics (hereinafter “IONOS”). The provider is 1&1 IONOS SE, Elgendorfer Straße 57, D-56410 Montabaur, Germany. IONOS analytics may be used to analyse, among other things, visitor numbers and behaviour, such as the number of page views, length of visits and bounce rates, sources of visitors, in other words the website from which a visitor arrived, visitor locations, and technical data such as browser and operating-system versions. For this purpose, IONOS stores in particular the following data:

• referrer (previously visited website)

• requested website or file

• browser type and browser version

• operating system used

• device type used

• time of access

• IP address in anonymised form (used only to determine the location of access)

According to IONOS, the data is collected in fully anonymised form and cannot therefore be traced back to individual persons. IONOS WebAnalytics does not store cookies. The storage and analysis of the data is based on Article 6(1)(f) GDPR. The website operator has a legitimate interest in the statistical analysis of user behaviour in order to optimise the website technically. Where corresponding consent has been requested, processing is carried out exclusively on the basis of Article 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as that consent covers the storage of cookies or access to information on the user's device, for example through device fingerprinting, within the meaning of the TDDDG. Consent may be withdrawn at any time. Further information on data collection and processing by IONOS WebAnalytics can be found in the IONOS privacy policy at: https://www.ionos.de/terms-gtc/datenschutzerklaerung/

Data processing agreement

We have entered into a data processing agreement (DPA) for the use of the service referred to above. This is a contract required under data protection law which ensures that the provider processes the personal data of our website visitors only on our instructions and in compliance with the GDPR.

VG WORT / METIS access measurement

For selected texts, we use the METIS access-measurement system operated by Verwertungsgesellschaft WORT (VG WORT), Untere Weidenstraße 5, 81543 Munich, Germany. It is used to determine how often texts published by us are accessed and, on that basis, whether the requirements for a possible payment of copyright remuneration are met. For this purpose, an individual counting tag is assigned to the relevant texts. When a tagged text is accessed, the system can count how often it has been viewed. To avoid multiple counts within a single browser session, a client ID and a METIS session cookie are used. According to VG WORT, no personal data is processed as part of this access measurement. The technical operation of METIS access measurement is carried out on behalf of VG WORT by Kantar GmbH, Landsberger Straße 284, 80687 Munich, Germany. VG WORT currently takes the view that no consent is required for METIS access measurement because no personal data is processed and because of the way the session cookie is designed.

  1. Newsletter

Newsletter data

If you wish to receive the newsletter offered on this website, we require an email address from you, together with information that enables us to verify that you are the owner of the email address provided and that you agree to receive the newsletter. We use this data to send you the information requested. For the purpose of distributing the newsletter, we transmit the necessary data to the newsletter service provider named below, which processes it on our behalf. In connection with newsletter campaigns, we may analyse various data, such as the time an email was opened, IP address, device information, links clicked and, where applicable, subsequent actions. The data entered in the newsletter subscription form is processed exclusively on the basis of your consent (Article 6(1)(a) GDPR). You may withdraw your consent to the storage of the data and email address and to their use for sending the newsletter at any time, for example by using the unsubscribe link in the newsletter. The lawfulness of processing carried out before withdrawal is unaffected.

The data you provide for the purpose of receiving the newsletter will be stored by us or by the newsletter service provider until you unsubscribe, and will then be deleted from the newsletter distribution list after you unsubscribe or once the purpose for which it was collected no longer applies. We reserve the right to delete or block email addresses from our newsletter distribution list at our discretion on the basis of our legitimate interest under Article 6(1)(f) GDPR. Data stored by us for other purposes remains unaffected.

After you unsubscribe from the newsletter distribution list, your email address may be stored by us or by the newsletter service provider on a blacklist where this is necessary to prevent future mailings. Data on the blacklist is used solely for this purpose and is not combined with other data. This serves both your interests and ours in complying with the legal requirements governing newsletter distribution, and is based on our legitimate interest within the meaning of Article 6(1)(f) GDPR. Storage on the blacklist is not subject to a fixed time limit. You may object to this storage if your interests outweigh our legitimate interest.

Newsletter distribution with Brevo

We use Brevo to distribute our newsletter. The provider is Brevo GmbH, Köpenicker Straße 126, 10179 Berlin, Germany. When you subscribe to our newsletter, the data you provide when registering, in particular your email address and, where applicable, your name, is transmitted to Brevo and processed there for the purpose of distributing the newsletter. Email opens and clicks are evaluated on an individual, identifiable basis only where separate consent has been given for this purpose. Without such consent, no individualised tracking of email opens and clicks takes place.

Registration uses a double opt-in procedure. After signing up, you will receive an email asking you to confirm your subscription. You will be added to the newsletter distribution list only after you have provided this confirmation. Brevo records the individual steps in the double opt-in procedure so that the consent given can be demonstrated.

The legal basis for sending the newsletter is your consent under Article 6(1)(a) GDPR. You may withdraw this consent at any time with effect for the future, in particular by using the unsubscribe link in each newsletter email. We have a data processing agreement (DPA) with Brevo. The DPA forms part of Brevo's Terms of Use.

Notification when the book becomes available for pre-order

On our website, you can register your interest in being notified as soon as an announced book becomes available for pre-order. We also use Brevo for this purpose. If you register your interest, we process your email address and the information required to document your consent. This registration also uses a double opt-in procedure. You will first receive a confirmation email and will be added to the relevant notification list only after clicking the link contained in that email.

Processing is based on your consent under Article 6(1)(a) GDPR. You may withdraw your consent at any time with effect for the future. The data will be stored until you withdraw your consent or until the purpose of the notification no longer applies, unless statutory retention obligations require otherwise. Data relating to the book notification is processed in a separate list. Registering your interest in the book does not automatically subscribe you to the general newsletter.

  1. Plugins and tools

Cloudflare Turnstile

We use Cloudflare Turnstile (hereinafter “Turnstile”) on this website. The provider is Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA (hereinafter “Cloudflare”). Turnstile is used to determine whether data entered on this website, for example in the newsletter and register-your-interest forms embedded on the site, is being submitted by a human being or by an automated program. To do this, Turnstile analyses the behaviour of website visitors on the basis of various characteristics.

This analysis starts automatically as soon as a website visitor enters a page on which Turnstile is enabled. Turnstile evaluates various information for the purpose of the analysis, for example IP address, the length of time the visitor spends on the website, or mouse movements made by the user. The data collected during the analysis is transmitted to Cloudflare.

The storage and analysis of data is based on Article 6(1)(f) GDPR. The website operator has a legitimate interest in protecting its online services against abusive automated activity and spam. Where corresponding consent has been requested, processing is carried out exclusively on the basis of Article 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as that consent covers the storage of cookies or access to information on the user's device, for example through device fingerprinting, within the meaning of the TDDDG. Consent may be withdrawn at any time.

The data processing is based on Standard Contractual Clauses, which can be found here: https://www.cloudflare.com/cloudflare-customer-scc/.

Further information about Cloudflare Turnstile can be found in the data protection provisions at: https://www.cloudflare.com/cloudflare-customer-dpa/.

The company is certified under the EU-US Data Privacy Framework (DPF). The DPF is an agreement between the European Union and the United States intended to ensure compliance with European data protection standards when data is processed in the United States. Every company certified under the DPF undertakes to comply with those standards. Further information is available from the provider at: https://www.dataprivacyframework.gov/participant/5666.

Wordfence

We have integrated Wordfence into this website. The provider is Defiant Inc., 1700 Westlake Ave N, Ste 200, Seattle, WA 98109, USA (hereinafter “Wordfence”). Wordfence is used to protect our website against unwanted access and malicious cyberattacks. For this purpose, our website maintains a continuous connection to Wordfence's servers so that Wordfence can compare access to our website with its databases and block access where appropriate.

Wordfence is used on the basis of Article 6(1)(f) GDPR. The website operator has a legitimate interest in protecting the website as effectively as possible against cyberattacks. Where corresponding consent has been requested, processing is carried out exclusively on the basis of Article 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as that consent covers the storage of cookies or access to information on the user's device, for example through device fingerprinting, within the meaning of the TDDDG. Consent may be withdrawn at any time. Transfers of data to the United States are based on the European Commission's Standard Contractual Clauses. Details can be found here: https://www.wordfence.com/help/general-data-protection-regulation/.

Data processing agreement

We have entered into a data processing agreement (DPA) for the use of the service referred to above. This is a contract required under data protection law which ensures that the provider processes the personal data of our website visitors only on our instructions and in compliance with the GDPR.

Source: https://www.e-recht24.de