I. Principles
1. Joint controllers for the processing of personal data
The purposes and means of processing personal data when you visit our Facebook page (“Facebook page”) are carried out by Betterguards Technology GmbH, Eiswerderstr. 20A, 13585 Berlin, Germany (“Betterguards Technology GmbH”) and Meta Platforms Ireland Ltd. (“Facebook”) together within the meaning of Article 26 of the EU General Data Protection Regulation (GDPR). This results from the fact that Betterguards Technology GmbH, as the operator of the Facebook page, by setting up such a page gives Facebook the opportunity to place cookies on the computer or any other device of the person who visits the Facebook page (“visitor”) , regardless of whether the visitor has a Facebook account.
As part of the shared responsibility, Facebook assumes primary responsibility under the GDPR for the processing of Insights data and fulfills all obligations under the GDPR with regard to the processing of Insights data (including Articles 12 and 13 GDPR, Articles 15 to 22 GDPR and Articles 32 to 34 GDPR). In addition, Facebook makes the essence of this Page Insights supplement available to the data subjects (the corresponding “Page Insights Controller Addendum” can be found here:
https://www.facebook.com/legal/terms/page_controller_addendum ).
Below you will find a description of how Betterguards Technology GmbH and Facebook handle personal data when you visit the Facebook page. However, since Betterguards Technology GmbH generally or largely has no influence on the data collected by Facebook and its processing by Facebook, we cannot currently provide any conclusive information about the purpose and extent of the processing of your data by Facebook. However, we will monitor further developments in this regard and adapt this data protection declaration accordingly if necessary.
We would like to point out that you use this Facebook page and its functions at your own risk. This applies in particular to the use of the interactive functions (in particular commenting, sharing, rating).
2. Name and address of those jointly responsible
a) The person primarily responsible is:
Facebook
Meta Platforms Ireland Ltd.
4 Grand Canal Square
Grand Canal Harbor
Dublin 2 Ireland
b) Another person responsible is:
Betterguards Technology GmbH
Eiswerderstr. 20A
13585 Berlin
Germany
Tel: 030/4220669-0
Email: info@betterguards.de
Website: www.betterguards.de
3. Contact options for the data protection officer of the primarily responsible Facebook
You can contact the data protection officer of Facebook, the primary controller, using the following link:
https://www.facebook.com/help/contact/540977946302970
4. Name and address of the data protection officer of the additional controller
You can reach the data protection officer of the additional controller Betterguards Technology GmbH under 2.b) at:
DataCo GmbH
Nymphenburger Str. 86
80636 Munich
Germany
+49 89 7400 45840
www.dataguard.de
5. Legal basis for processing personal data
If consent is obtained from the data subject for processing personal data, Article 6 Paragraph 1 Sentence 1 Letter a (GDPR) serves as the legal basis for the processing of personal data.
When processing personal data that is necessary to fulfill a contract to which the data subject is a party, Art. 6 Paragraph 1 Sentence 1 Letter b GDPR serves as the legal basis. This also applies to processing operations that are necessary to carry out pre-contractual measures.
If the processing of personal data is necessary to fulfill a legal obligation to which Betterguards Technology GmbH or Facebook is subject, Article 6 Paragraph 1 Sentence 1 Letter c GDPR serves as the legal basis.
In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6 Paragraph 1 Sentence 1 Letter d GDPR serves as the legal basis.
If the processing is necessary to protect a legitimate interest of Betterguards Technology GmbH, Facebook or a third party and the interests, fundamental rights and freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 Paragraph 1 Sentence 1 Letter f of the GDPR serves as the legal basis for this the processing.
6. Possibility of objection and removal
The visitor has the option at any time to revoke his consent to the processing of personal data (see also rights of data subjects). If the visitor contacts us via email, they can object to the storage of their personal data at any time.
The collection of data to provide the Facebook page and the storage of the data in log files is absolutely necessary for the operation of the Facebook page. There is therefore no possibility for the visitor to object.
7. Rights of data subjects
If your personal data is processed, you are the data subject within the meaning of the GDPR and you have the following rights towards those responsible:
- Right to information about the data stored about you by Betterguards Technology GmbH or Facebook;
- Right to rectification, deletion or restriction of processing of your personal data;
- Right to object to processing that serves the legitimate interest of Betterguards Technology GmbH or Facebook, a public interest or profiling, unless Betterguards Technology GmbH or Facebook can demonstrate compelling legitimate reasons for the processing that exceed your interests, rights and Freedoms prevail, or the processing serves to assert, exercise or defend legal claims;
- right to data portability;
- Right to complain to a supervisory authority;
- Right to revoke your consent to the collection, processing and use of your personal data at any time with future effect.
If you would like to exercise your rights, you can address your request to both Betterguards Technology GmbH and Facebook. To do this, you can, for example, use the contact options listed above. If you contact us, we will forward your request to Facebook if it concerns questions regarding the processing of Insights data. Facebook will respond to requests consistent with our obligations under the Page Insights Supplement.
II. Processing of personal data by Betterguards Technology GmbH
1. Purpose of data processing
Betterguards Technology GmbH maintains online presences within social networks in order to communicate with interested parties and users active there and to inform them about our products, events and news.
When you access our Facebook page (regardless of whether you are logged into your Facebook account or not), your browser transmits certain data to the web server responsible for Facebook for technical reasons. Facebook also uses so-called “cookies”. Cookies are small text files that are stored in the memory of your device via your browser. Cookies set by Facebook are intended, among other things, to enable Betterguards Technology GmbH, as the operator of the Facebook page, to receive statistics that Facebook creates based on visits to this page for the purpose of controlling the marketing of our activities.
2. Description and scope of data processing
As the operator of the Facebook page, Betterguards Technology GmbH can receive anonymized statistical data regarding visitors to our Facebook page using the Facebook Page Insights function, which Facebook provides to us free of charge as an indispensable part of the user relationship. This data is collected using cookies set by Facebook, each of which contains a unique user code that Facebook stores on the visitor’s device. The user code, which can be linked to the registration data of users who are registered with Facebook, is collected and processed when the Facebook page is accessed.
In particular, the fan page operator may receive demographic data provided by Facebook about its target group – and thus the processing of this data – such as, among other things, trends in the areas of age, gender, relationship status and professional situation, information about the lifestyle and interests of its target group and information about the purchases and online purchasing behavior of visitors to its site, the categories of goods or services that most interest them, as well as geographical data that informs it where to carry out specific promotions or organize events and, more generally, allows it to do so to make its information offering as targeted as possible.
Although the visitor statistics created by Facebook are only transmitted in anonymized form to Betterguards Technology GmbH as the operator of the Facebook page, the creation of these statistics is based on the previous collection – through the cookies set by Facebook on the visitor’s device – and the processing of the personal data of these visitors for these statistical purposes. For more information about Facebook Page Insights, see:
https://de-de.facebook.com/legal/terms/information_about_page_insights_data
https://de-de.facebook.com/help/pages/insights
Data on the Facebook groups linked to our Facebook page are also provided in this way. Due to the constant development of Facebook, the availability and processing of data is changing, so for further details we refer to the Facebook data protection information mentioned in the previous paragraph and below under “PROCESSING OF PERSONAL DATA BY FACEBOOK”.
We use this data, available in aggregate form, to make our posts and activities on our Facebook page more attractive to users. For example, we use the distributions according to age and gender for an adapted approach and the users’ preferred visiting times for a time-optimized planning of our contributions. Information about the type of devices visitors use helps us to adapt the posts visually and creatively. In accordance with the Facebook Terms of Use, to which each user has agreed when creating a Facebook profile, we can identify the page’s subscribers and fans and view their profiles and other information shared by them.
In addition to this automatically collected anonymized data, we also process the data that you voluntarily provide to us within the framework of e.g. B. have provided comments on posts or contacts.
If you click on the link https://betterguards.de/pages/datenschutzerklarung (this is the page you are currently on) that is posted on the Betterguards Technology GmbH Facebook fan page, you will be taken to a subpage of the Betterguards Technology GmbH website. Personal data is also processed on this site. The relevant data protection declaration for these pages can be found here: tbd
3. Data deletion and storage period
Personal data will be deleted or blocked as soon as the purpose of storage no longer applies. Storage may also be necessary if this has been provided for by European or national legislators in EU regulations, laws or other regulations to which Betterguards Technology GmbH is subject. The data will also be blocked or deleted if a storage period prescribed by the standards mentioned expires, unless there is a need for further storage of the data to conclude or fulfill a contract.
III. Processing of personal data by Facebook
How Facebook uses the data from visits to Facebook pages for its own purposes, to what extent activities on the Facebook page are assigned to individual users, how long Facebook stores this data and whether data from a visit to the Facebook page is passed on to third parties are passed on is not conclusively and clearly stated by Facebook and is not fully known to us. However, we will monitor further developments in this regard and adapt this data protection declaration accordingly if necessary. The following information is based on information publicly provided by Facebook regarding the processing of personal data when using Facebook products.
1. Purpose of data processing
According to Facebook, it processes visitors’ personal data for the following purposes:
- Providing, personalizing and improving Facebook Products;
- Providing measurements, analytics and other Facebook services;
- promoting protection, integrity and security;
- Communication with Facebook users;
- Research and innovation for social purposes.
Further information on the purposes of data processing by Facebook can be found in the Facebook data policy:
https://de-de.facebook.com/policy.php
Further information on Facebook’s legitimate interests in the processing of personal data can be found here:
https://de-de.facebook.com/about/privacy/legal_bases
When you access our Facebook page (regardless of whether you are logged into your Facebook account or not), your browser transmits certain data to the web server responsible for Facebook for technical reasons. Facebook also uses “cookies”. Facebook uses cookies, among other things, to provide Betterguards Technology GmbH, as the operator of the Facebook page, with statistics for the purpose of controlling the marketing of our activities. Further information on Facebook’s use of cookies can be found in the Facebook Cookie Policy:
https://de-de.facebook.com/policies/cookies
2. Description and scope of data processing
a) What types of information does Facebook process?
In order to provide Facebook products, it is necessary for Facebook to process information about visitors. The types of information Facebook collects depend on how the visitor uses Facebook Products. The following information can be processed by Facebook:
Things made and provided by visitors and others, such as information about how the visitor uses the Facebook Products, information about transactions conducted on Facebook Products, or information about the people, pages, accounts, hashtags and groups with which the visitor is connected .
Device information such as device attributes, identifiers, network and connections, and cookie data.
Information from partners that allows advertisers, app developers and publishers to send information to Facebook via the Facebook business tools they use, including the social plugins (such as the “Like” button), Facebook login or the Facebook pixel. These partners provide Facebook with information about the visitor’s activities outside of Facebook.
In addition, Facebook uses cookies that are set on the visitor’s device when the Facebook page is accessed, regardless of whether the visitor is logged into their Facebook account or not. In addition, Facebook also processes the information stored in the cookies when a person visits the Facebook services, services provided by other members of the Facebook group of companies, and services provided by other companies that use the Facebook services . In addition, other entities such as Facebook partners and other third parties on the Facebook services may use cookies to provide services to Facebook or the companies that advertise on Facebook. Further information on Facebook’s use of cookies can be found in the Facebook Cookie Policy:
https://de-de.facebook.com/policies/cookies
When you access a Facebook page, the IP address assigned to your device is transmitted to Facebook. According to information from Facebook, this IP address is anonymized (for “German” IP addresses) and deleted after 90 days. Facebook also stores information about its users’ devices (particularly as part of the “login notification” function); If necessary, Facebook may be able to assign IP addresses to individual users.
If you want to avoid this, you should log out of Facebook or deactivate the “stay logged in” function, delete the cookies on your device and close and restart your browser. In this way, Facebook information that can be used to directly identify you will be deleted. This allows you to use our Facebook page without your Facebook ID being revealed. When you access interactive functions of the site (like, comment, share, news, etc.), a Facebook login screen appears. After you have logged in, you will again be recognized by Facebook as a specific user.
For information about how to manage or delete information about you, please visit the following Facebook support pages:
https://de-de.facebook.com/about/privacy.
For more information about the types of information Facebook processes, see the Facebook data policy:
https://de-de.facebook.com/policy.php
b) How is the information processed by Facebook shared with others?
Facebook works with third-party partners who help Facebook provide and improve its products or who use Facebook Business tools to grow business. Facebook may share information with the following third-party partners:
- Partners who use Facebook analytics services;
- advertisers;
- measurement partner;
- Partners who offer goods and services in Facebook Products;
- providers and service providers;
- researchers and scientists;
- Law enforcement or Law enforcement agencies or legal requests.
For more information about the data that Facebook may share with third-party partners, please see the Facebook Data Policy:
https://de-de.facebook.com/policy.php
c) How does Facebook process and transfer data as part of its global services?
Facebook shares information globally, both internally between Facebook companies and externally with its partners and with those people or organizations with whom the visitor connects and shares around the world. Data can also be transferred to the USA or other third countries that do not have an adequate level of data protection and processed there. In this regard, Facebook uses standard data protection clauses approved by the European Commission or relies on the adequacy decisions issued by the European Commission with regard to certain countries.
Further information on data transfers by Facebook can be found in the Facebook data policy:
https://de-de.facebook.com/policy.php
3. Data deletion and storage period
Facebook stores data until it is no longer needed to provide its services and Facebook products or until the user’s Facebook account is deleted, whichever occurs first. This is a case-by-case determination and depends on things such as the type of data, why it is being collected and processed, and the relevant legal or operational storage needs.
Further information on data deletion and storage period can be found in the Facebook data policy:
https://de-de.facebook.com/policy.php
Regarding the storage period of cookies set by Facebook, you can find further information in the Facebook Cookie Policy:
https://de-de.facebook.com/policies/cookies
This data protection declaration was created with the support of DataGuard.