1. Data protection at a glance

General information

The following information provides a simple overview of what happens to your personal data when you visit our website. Personal data is any data that can be used to identify you personally. For detailed information on the subject of data protection, please refer to our data protection declaration listed below this text.

Data collection on our website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find the operator’s contact details in the legal notice of this website.

How do we collect your data?

On the one hand, your data is collected when you provide it to us. This may, for example, be data that you enter in a contact form.

Other data is collected automatically by our IT systems when you visit the website. This is primarily technical data (e.g. internet browser, operating system or time of page view). This data is collected automatically as soon as you enter our website.

What do we use your data for?

Some of the data is collected to ensure that the website is provided without errors. Other data may be used to analyse your user behaviour.

What rights do you have regarding your data?

You have the right to receive information about the origin, recipient and purpose of your stored personal data free of charge at any time. You also have the right to request the correction, blocking or deletion of this data. You can contact us at any time at the address given in the legal notice if you have any further questions on the subject of data protection. You also have the right to lodge a complaint with the competent supervisory authority.

You also have the right to request the restriction of the processing of your personal data under certain circumstances. For details, please refer to the privacy policy under ‘Right to restriction of processing’.

Analysis tools and tools from third-party providers

When you visit our website, your surfing behaviour may be statistically analysed. This is primarily done using cookies and so-called analysis programmes. The analysis of your surfing behaviour is usually anonymous; the surfing behaviour cannot be traced back to you. You can object to this analysis or prevent it by not using certain tools. Detailed information on this can be found in the following privacy policy.

You can object to this analysis. We will inform you about the objection options in this privacy policy.

2. General notes and mandatory information

Data protection

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 statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected. Personal data is data that can be used to identify you personally. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We would like to point out that data transmission over the Internet (e.g. when communicating by email) may be subject to security vulnerabilities. Complete protection of data against access by third parties is not possible.

Note on the responsible body

The party responsible for data processing on this website is

Michael Rübenach
Hanedoorn 9
6226TB Maastricht
Nederland

Phone DE: +49 (0) 211 1634 3499
Phone NL: +31 (0) 616 1594 93

E-Mail: info@21words.org

The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, e-mail addresses, etc.).

Revocation of your consent to data processing

Many data processing operations are only possible with your express consent. You can withdraw your consent at any time. All you need to do is send us an informal email. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Right to object to data collection in special cases and to direct advertising (Art. 21 GDPR)

If data processing is carried out on the basis of Art. 6 para. 1 lit. e or f GDPR, you have the right to object to the processing of your personal data at any time for reasons arising from your particular situation; this also applies to profiling based on these provisions. The respective legal basis on which processing is based can be found in this privacy policy. If you object, we will no longer process your personal data concerned unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or the processing serves the establishment, exercise or defence of legal claims (objection pursuant to Art. 21 (1) GDPR).

If your personal data are processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is associated with such direct marketing. If you object, your personal data will subsequently no longer be used for the purpose of direct marketing (objection pursuant to Art. 21 (2) GDPR).

Right to lodge a complaint with the competent supervisory authority

In the event of infringements 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 place of the alleged infringement. The right to lodge a complaint is without prejudice to any other administrative or judicial remedy.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfilment of a contract handed over to you or to a third party in a commonly used, machine-readable format. If you request the direct transfer of the data to another controller, this will only take place if it is technically feasible.

SSL or TLS encryption

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the site operator. You can recognise an encrypted connection by the fact that the address line of the browser changes from ‘https://’ to ‘https://’ and by the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Information, blocking, erasure and rectification

Within the framework of the applicable legal provisions, you have the right to free information about your stored personal data, its origin and recipients and the purpose of the data processing and, if necessary, a right to correction, blocking or deletion of this data at any time. You can contact us at any time at the address given in the legal notice if you have further questions on the subject of personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. To do so, you can contact us at any time at the address given in the legal notice. The right to restriction of processing exists in the following cases:

If you dispute the accuracy of your personal data stored by us, we generally need time to verify this. For the duration of the review, you have the right to request that the processing of your personal data be restricted.
If the processing of your personal data was/is carried out unlawfully, you can request the restriction of data processing instead of erasure.
If we no longer need your personal data, but you need it for the exercise, defence or assertion of legal claims, you have the right to request the restriction of the processing of your personal data instead of its erasure.
If you have lodged an objection in accordance with Art. 21 para. 1 GDPR, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.
If you have restricted the processing of your personal data, this data – apart from its storage – may only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or of a Member State.

3. Hosting

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

EuroDNS
The provider is EuroDNS, 24 Rue Léon Laval, 3372 Leudelange, Luxembourg. When you visit our website, EuroDNS collects various log files including your IP addresses. Details can be found in the EuroDNS privacy policy: www.eurodns.com.

The use of EuroDNS is based on Art. 6 para. 1 lit. f GDPR. We have a legitimate interest in displaying our website as reliably as possible. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.

Order processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law, which ensures that the service provider only processes the personal data of our website visitors in accordance with our instructions and in compliance with the GDPR.

4. Data collection on our website

Cookies

Some of the Internet pages use so-called cookies. Cookies do not cause any damage to your computer and do not contain viruses. Cookies serve to make our website more user-friendly, effective and secure. Cookies are small text files that are stored on your computer and saved by your browser.

Most of the cookies we use are so-called ‘session cookies’. They are automatically deleted at the end of your visit. Other cookies remain stored on your end device until you delete them. These cookies enable us to recognise your browser on your next visit.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be restricted.

Cookies that are required to carry out the electronic communication process or to provide certain functions that you have requested (e.g. shopping basket function) are stored on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the storage of cookies for the technically error-free and optimised provision of its services. Insofar as other cookies (e.g. cookies for analysing your surfing behaviour) are stored, these are treated separately in this privacy policy.

Server log files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are

• Browser type and browser version
• Operating system used
• Referrer URL
• Host name of the accessing computer
• Time of the server enquiry
• IP address
• This data is not merged with other data sources.

This data is collected on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of its website – the server log files must be recorded for this purpose.

Contact form

If you send us enquiries via the contact form, your details from the enquiry form, including the contact data you provide there, will be stored by us for the purpose of processing the enquiry and in the event of follow-up questions. We will not pass on this data without your consent.

The data entered in the contact form is therefore processed exclusively on the basis of your consent (Art. 6 para. 1 lit. a GDPR). You can revoke this consent at any time. All you need to do is send us an informal email. The legality of the data processing operations carried out until the revocation remains unaffected by the revocation.

We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Mandatory statutory provisions – in particular retention periods – remain unaffected.

Enquiry by e-mail, telephone or fax

If you contact us by e-mail, telephone or fax, your enquiry including all personal data (name, enquiry) will be stored and processed by us for the purpose of processing your request. We will not pass on this data without your consent.

This data is processed on the basis of Art. 6 para. 1 lit. b GDPR if your enquiry is related to the fulfilment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on your consent (Art. 6 para. 1 lit. a GDPR) and / or on our legitimate interests (Art. 6 para. 1 lit. f GDPR), as we have a legitimate interest in the effective processing of the enquiries addressed to us.

The data you send to us via contact requests will remain with us until you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

Processing of data (customer and contract data)

We collect, process and use personal data only insofar as it is necessary for the establishment, content or amendment of the legal relationship (inventory data). This is done on the basis of Art. 6 para. 1 lit. b GDPR, which permits the processing of data for the fulfilment of a contract or pre-contractual measures. We collect, process and use personal data about the use of our website (usage data) only insofar as this is necessary to enable the user to use the service or to bill the user.

The customer data collected will be deleted after completion of the order or termination of the business relationship. Statutory retention periods remain unaffected.

5. analysis tools and advertising

Google Tag Manager

We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Tag Manager is a tool that enables us to integrate tracking or statistical tools and other technologies on our website. Google Tag Manager itself does not create any user profiles, does not store any cookies and does not carry out any independent analyses. It is only used to manage and display the tools integrated via it. However, Google Tag Manager records your IP address, which may also be transmitted to Google’s parent company in the United States.

The Google Tag Manager is used on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the fast and uncomplicated integration and management of various tools on its website. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time.

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider is Google Ireland Limited (‘Google’), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyse the behaviour of website visitors. In doing so, the website operator receives various usage data, such as page views, length of visit, operating systems used and origin of the user. This data may be summarised by Google in a profile that is assigned to the respective user or their end device.

Google Analytics uses technologies that enable the recognition of the user for the purpose of analysing user behaviour (e.g. cookies or device fingerprinting). The information collected by Google about the use of this website is generally transmitted to a Google server in the USA and stored there.

The use of this analysis tool is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in analysing user behaviour in order to optimise both its website and its advertising. If a corresponding consent has been requested (e.g. consent to the storage of cookies), the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the consent can be revoked at any time.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.

IP anonymisation

We have activated the IP anonymisation function on this website. This means that your IP address will be truncated by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. Google will use this information on behalf of the operator of this website to analyse your use of the website, to compile reports on website activity and to provide the website operator with other services relating to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

Browser plugin

You can prevent the collection and processing of your data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

You can find more information on how Google Analytics handles user data in Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=de.

Order processing

We have concluded an order processing contract with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

Demographic characteristics with Google Analytics

This website uses the ‘demographic characteristics’ function of Google Analytics in order to be able to display suitable adverts to website visitors within the Google advertising network. This allows reports to be generated that contain statements about the age, gender and interests of site visitors. This data comes from interest-based advertising from Google and from visitor data from third-party providers. This data cannot be assigned to a specific person. You can deactivate this function at any time via the ad settings in your Google account or generally prohibit the collection of your data by Google Analytics as described in the section ‘Objection to data collection’.

Storage period

Data stored by Google at user and event level that is linked to cookies, user identifiers (e.g. User ID) or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) is anonymised or deleted after 14 months. For details, please see the following link: https://support.google.com/analytics/answer/7667196?hl=de

Google Web Fonts

This site uses so-called web fonts provided by Google for the standardised display of fonts. The Google fonts are installed locally. There is no connection to Google servers.

Google Maps (with consent)

This site uses the Google Maps map service via an API. The provider is Google Inc, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA.

To ensure data protection on our website, Google Maps is deactivated when you enter our website for the first time. A direct connection to Google’s servers is only established when you activate Google Maps yourself (consent in accordance with Art. 6 para. 1 lit. a GDPR). This prevents your data from being transmitted to Google the first time you enter the site.

After activation, Google Maps will save your IP address. This is then usually transmitted to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer once Google Maps has been activated.

You can find more information on the handling of user data in Google’s privacy policy: https://www.google.de/intl/de/policies/privacy/.