Privacy Policy

Valid from: 10.02.2021

1. Introduction

For PONS GmbH (referred to below as the "publishing company") the protection of the personal data of our customers is a matter of the greatest importance. We are committed to ensuring that you can rely on the protection of your personal data by our company at all times, and know how our company both uses your data and ensures its protection.

This privacy policy informs you about the processing of personal data (referred to below as the "data") by our company when you make use of the services offered by one of our websites.

2. Data controller

PONS GmbH
Stöckachstr. 11
70190 Stuttgart
Tel.: 0711 / 89462111
Email: kundenservice@pons.de

3. Contact data of our Data Protection Officer

Michael Mayer, datenschutz@pons.de

4. Processing of personal data

Your data is processed and used in compliance with the applicable statutory regulations, in particular the General Data Protection Regulation (referred to below as the "GDPR").

4.1 Webshop orders

Why and on what legal basis data is processed?

When you place an order with one of our online shops (www.pons.de, langenscheidt.com, klett-lerntraining.de), the data required for the establishment of a contract and the processing of the order is recorded. The data includes your first name and surname, invoice address and, if necessary, delivery address, as well as your email address and, if available, the relevant educational institution. In addition, the status of the trainee teachers and the subjects taught are queried as part of the school stamp check. The data will be processed for the purpose of assigning the order to you as well as for the delivery of the goods and, if necessary, sending an invoice, together with the processing of payment and clarification of possible legal claims. If you order media on concessionary terms, we also process your data in order to check if the preconditions for this are met.

The legal basis for this is Art. 6 Section 1 b GDPR. If you wish you can create a customer account for future orders (registration). In this case your customer data is saved so that it can also be used for future orders placed with one of our online shops, without you having to enter it once more. When you register an account you also need to set a password (access data), so that access to this account is only available to you. In accordance with Art. 6 Section 1 b GDPR, we have the right to process the data you provide on registration, to the extent that this is necessary for the establishment or fulfilment of a contract. In addition we may process your data in accordance with Art. 6 Section 1 f GDPR for the purpose of simplifying your future orders.

If you have provided your consent we are also permitted, in accordance with Art. 6 Section 1 a and if relevant 1 f GDPR, to process any data which you have voluntarily provided us with when placing an order or registering an account. Such data may refer to your company/school and similar details, for example. The processing of these voluntarily provided details is implemented so that we can get in touch with you faster in the event of supply problems. The legal basis for this is Art. 6 Section 1 a and if relevant Section 1 f GDPR.

Is data passed on to other parties?

We pass on data, at least in part, to the following external contract processors and other recipients for the purposes described below:

Collection agencies

Data is only passed on for the collection of debts from customers who fail to pay the purchase price of goods.

Technical service providers

Data is passed on to contract processors for the purposes of hosting and maintaining our website, providing quality assurance or within the scope of any email services used.

for further recipients see 4.5 below

In relation to orders placed with our webshops we are jointly responsible for the processing of your data together with Stuttgarter Verlagskontor GmbH, Rotebühlstr. 77, 70178 Stuttgart (referred to below as "SVK"). SVK accepts the order, maintains the customer database, sends off the goods, issues the invoice and collects the invoice amount in its own name and for its own account ("non-recourse factoring"). We therefore pass on your order data to SVK for this purpose.

The legal basis for the transfer of data to SVK is Art. 6 Section 1 f GDPR. The publishing company and SVK are affiliates within the Klett Bildungsgruppe corporation. We therefore have a legitimate interest in transferring data to SVK for internal administrative purposes, because this is the only way that SVK can collect the price of their purchases from our customers.

The publishing company and SVK have concluded an agreement covering their respective responsibilities under data protection regulations, and the main elements of this agreement can be made available to you by email on request.

Orders from the following countries are passed on to our partners in these countries:

Switzerland: Balmer Bücherdienst AG, Kobiboden, CH-8840 Einsiedeln.

Austria: Medienlogistik Pichler - ÖBZ GmbH&Co. KG, PO Box 133, A-2355 Wiener Neudorf.

Ernst Klett AG, Rotebühlstr. 77, D-70178 Stuttgart, is responsible for providing uniform legal advice in relation to the division of working cooperation within the Klett Bildungsgruppe organisation. The legal basis for this is Art. 6 Section 1 f GDPR. In an agreement on joint responsibility in accordance with Art. 26 GDPR we have agreed with the company which party will fulfill the various applicable data protection obligations. We will make the essential content of this agreement available to you on request.

Do I have to enter my data?

There is no legal or contractual requirement for you to provide your data. However, for the purpose of establishing a purchase contract with us your name, address and email address are required as a minimum. Otherwise we will not be able to send the order to your address, or provide you with confirmation of your order by email. With all forms of payment except for purchases made on account the entry of payment data is necessary, because otherwise we will not be able to debit your account or credit card with the agreed price. In order to conclude a contract with us, no further details or registration are necessary.

When will my data be deleted at the latest?

We have the right to save data until the final fulfilment of the individual contract. In the case of purchase contracts, we are permitted to save data until the receipt of payment and for a period of up to 2 years after the goods have been delivered. If the saving of data is necessary for the purpose of compliance with our legal obligations in accordance with Art. 6 Section 1 c GDPR, in conjunction with Germany's Commercial Code or tax regulations, we have the right to save such data until the expiry of the retention periods which the applicable laws and regulations stipulate. This can lead to a retention period of up to 7 years. Unless we have the right or obligation to retain the data for a longer period of time for the reasons which are outlined above, the data you enter when you register an account with us will either be deleted as soon as possible at your request, or at the latest 4 years after you place your last order.

4.2 Advertising

In rare cases we also use your data to send you advertising by post or email for our products, provided that you have been a customer for three years, have provided us with your postal or email address, and have not refused your consent to such advertising (with regard to your right of objection, please see 5.4). The processing of your data is implemented on the basis of Art. 6 Section 1 f GDPR. We have a legitimate business interest in sending advertising by post or email to our customer base.

4.3 Making of contact

Any data you enter on our contact form or communicate to us by email or otherwise will be processed so that we can deal with and reply to your enquiry. If desired, it will also be processed for the purpose of sending a copy of your enquiry to your own email address.

In accordance with Art. 6 Section 1 a GDPR, we can process the data you have entered on our contact form, provided that you have given your consent to this by clicking on the "Send message" button. If you enter sensitive information in the "Message" field which contains specific categories of data (e.g. your origins, political opinions, religion, medical data), you also give your consent to the processing of such data. If you send us data by email or in some other form, the legal basis will be Art. 6 Section 1 f and if relevant Section 1 b GDPR.

The data concerned will be deleted at the latest 24 months after the receipt of your enquiry, unless we are entitled or obliged to save it for a longer period on the basis of legal requirements in conjunction with Art. 6 Section 1 c GDPR. This may lead to a maximum retention period of 7 years.

We provide your contact enquiry to the external contract processors stated under 4.1 and 4.6.1 and if appropriate also to the following recipients:

Prospero GmbH                                             Müllerstrasse 27, 80469 Munich

Amevida Freiburg GmbH                             Zinkmattenstraße 6a, 79108 Freiburg.

4.4 Job applications

Your data will - on the basis of Art. 88 GDPR in conjunction with § 26 Section 1 or Section 2 of the Federal Data Protection Act / BDSG - be processed for the purpose of making a decision on the establishment of an employment relationship with you. For the purpose of dealing with the application, the data will be stored by us for a period of six months from the conclusion of the application process, after which it will be deleted. If you take up employment with us on the conclusion of the application process, the processing of your data beyond this time is permitted in accordance with the above legal basis for the purpose of establishing and implementing an employment relationship.

You are not required to provide your personal data either contractually or in legal terms. However, an online application is not possible without the provision and saving of data. If you voluntarily provide us with special categories of data, including details of your origins, political, religious or ideological convictions, membership of a trade union, medical condition or sexual orientation, you also provide your consent to the processing of this data. Such processing will only take place to the extent that is absolutely necessary for the above-mentioned purposes. You are expressly requested not to communicate such data to us.

4.5 Newsletter

If you have subscribed to a newsletter distributed by our publishing company, we will process your email address for the purpose of sending you our newsletter on a regular basis. When you subscribe to the newsletter you will receive from us an email with a link for the purpose of verifying your email address.

The legal basis for sending you the newsletter is your consent, which you provide us with on subscribing to the newsletter (Art. 6 Section 1 a GDPR). The provision of data on your part is not mandatory, but your email address is required for the distribution of the newsletter. The entry of your name, title and place of residence is voluntary and serves the purpose of enabling us to address you in person and inform you about events in your area. Any data you have provided us with as part of your subscription to the newsletter will be deleted as soon as you unsubscribe from the newsletter. You can unsubscribe at any time by, for example, clicking on the relevant link at the foot of each newsletter (on the withdrawal of your consent, please see 5.5). When you cancel your subscription to the newsletter you will also no longer receive any promotional emails as described in Section 4.2.

Newsletter2Go is used as our newsletter software. In this process, your data is transmitted to Sendinblue GmbH. Sendinblue GmbH is prohibited from selling your data and using it for purposes other than sending newsletters. We also use the services of Emarsys Interactive Services GmbH in Berlin. Our newsletter is implemented on the basis of Art. 28 GDPR.

4.6 Visitors to our websites

4.6.1 Creation of log files

When you visit our websites, the following details are saved in a log file:

(1) the IP address and if relevant the MAC address of your computer or mobile device,

(2) the date and time of your punctual access,

(3) the names of the files you access and the data volume which is transmitted,

(4) the type of operating system and web browser used, including the language settings,

(5) the website from which you reach our website (referrer URL),

(6) the websites which are accessed from our website by the user's system in a journal file.

It is necessary for a large part of this data to be saved for technical reasons, so that the website can be displayed on your device, as well as to ensure system security. In addition, the above data is evaluated in anonymised form for statistical purposes and for the purpose of optimising our website. We do not link this data with your other personal data. In part the data is made available to external contract processors for the respective purposes which process the data on our behalf in accordance with Art. 28 GDPR.

4.6.2 Use of web fonts

On our websites we use external web fonts, so-called "Google Web Fonts" on our website. Google Fonts is a service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google") The integration of these web fonts takes place by a server call, usually in relation to a server operated by Google in the USA. This informs the server which of our websites you have visited. The IP address of the browser used by the terminal device of the visitor to the individual website is also stored by Google. For more information, please refer to Google's privacy policy, which can be found here:

www.google.com/fonts#AboutPlace:about

www.google.com/policies/privacy

The integration is based on our legitimate interests (Art. 6 Section 1 f GDPR) in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and taking into account possible licensing restrictions connected with their integration.

4.6.3 Use of cookies

a) General

In order to make visiting our websites attractive and to enable the use of certain functions, we use so-called "cookies" on various pages. These are small text files that are stored on your device. Some of the cookies we use are deleted again after the end of the browser session, i.e. after you close your browser (so-called "session cookies"). Other cookies remain on your device and enable us or our partner companies to recognise your browser on your next visit (so-called "persistent cookies"). Cookies can't be used to access other files on your computer or to determine your email address.

b) Use of cookies

Like most of the websites you visit, our website uses cookies to improve the user experience, both for single and repeat visits to the website. For example, you can quickly and easily switch between pages, save your configurations and use third-party tools (e.g. YouTube videos) on the website.

Cookies are generated either by our website ("first-party cookies") or by other websites whose contents appear on our website ("third-party cookies"). These third parties may set cookies when you are logged into their websites and visit our website. We have no influence on the cookie settings of these websites. Please visit the websites of the third-party providers in order to obtain further information on their use of cookies.

c) Legal basis for the storage of cookies

The storage of the cookies as follows is based on our respective individual legitimate interests (Art. 6 Section 1 f GDPR)

Necessary cookies

These cookies are necessary in order to make our website usable and cannot be deactivated in your system.  

Generally, these cookies are set only in response to actions you take that correspond to a service request such as setting your privacy preferences, logging-in or filling in forms. You can set your browser to block these cookies or to notify you of these cookies. However, some areas of the website will not work then. These cookies do not store any personal data.

Statistical cookies

These cookies collect information about the way a website is used - for example, which pages a visitor most frequently visits and whether he or she receives error messages from a page. We collect this information for our legitimate interest in being able to maintain an optimally usable and marketable website at all times. These cookies do not store any information that allows the user to be identified. The collected information is aggregated and therefore evaluated anonymously. These cookies are used to record usage in order to improve the performance of a website and thus the user experience.

Performance cookies

These cookies allow us to count visits and traffic sources so that we can measure and improve the performance of our website. They help us answer questions about which pages are most popular, which are the least used and how visitors move around the site. All information collected by these cookies is aggregated and is therefore anonymous. If you do not allow these cookies we will not be able to know when you visited our website.

Functional cookies

With these cookies the website is able to provide enhanced functionality and personalization. They may be set by us or by third parties whose services we use on our sites. If you do not allow these cookies, some or all of these services may not function properly.

The storage of the further cookies listed below is based on the user’s consent (Art. 6 Sect. 1 a) GDPR). Some of the relevant data are processed by the respective listed partners in the USA where – as a so-called third country - an adequate level of data protection cannot be assumed. By agreeing to the use of cookies for marketing purposes you consent to the processing of your data in the USA (Art. 49 Sect. 1 lit. a GDPR) However, these cookies are only set if the user consents to the storage by means of consent in the context of the cookie notice on the website.

Cookies for marketing purposes

These cookies may be set through our website by our advertising partners. They may be used by these companies to profile your interests and display relevant advertisements to you on other websites. They do not store directly personal information but are based on the unique identification of your browser and internet device. If you do not allow these cookies, you will receive less targeted advertising.

Further cookies

Saving and/or retrieving information on a device

Cookies, device identifiers or other information may be stored on or accessed from your device for the processing purposes displayed to you.

Personalized ads and content, ad and content measurement, insights about target groups and product development.

  • Selection of simple ads

Ads can be displayed based on the content you are viewing, the application you are using and your approximate location or device type.

  • Creating a personalized ad profile

A profile about you and your interests can be created in order to show you personalized ads that are relevant to you.

  • Select personalized ads

Personalized ads can be shown to you based on your personal profile.

  • Use accurate location data

Your exact location data may be used for one or more processing purposes. This means that your location can be precisely determined to within a few meters.

  • Actively query device properties for identification

Your device can be identified by a query of its specific characteristics.

  • Ensure security, prevent fraud and correct errors

Your data may be used to identify and prevent fraudulent activities and to ensure systems and processes are functioning properly and securely.

  • Technical provision of ads or content

Your device may receive and send information necessary for you to view and use content and ads.

  • Select personalized content – Merge with offline data sources

Data from offline data sources may be merged with data from your online activities in order to use it for one or more processing purposes or for special processing purposes. Data from your online activities may be merged with offline data in order to use it for one or more processing purposes or for specific processing purposes.

  • Connect different devices

For the use of one or more processing purposes it can be determined whether different devices belong to you or your household.

  • Receive and use of automatically sent device properties for identification

Your device can be distinguished from other devices due to automatically sent information like e. g. IP-address or type of browser.

These processing operations are carried out in accordance with the specifications and guidelines of the European industry standard “IAB Europe Transparency & Consent Framework”. For further information on the providers and/or advertising partners, purposes and processing operations (such as e. g. storage period) for which we use cookies and similar technologies or on your privacy settings, please refer to our Consent Management Platform (CMP).

d) Turning off and deleting cookies

Most browsers are set to automatically accept cookies. If the default settings for cookies are stored in your browser, all processes run unnoticed by you in the background. However, these settings can be changed by you.

You can set your browser so that you are informed about the setting of cookies and decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general.

A general objection to the use of cookies used for marketing purposes can be declared for many of the services via the website http://www.aboutads.info/choices/ or the EU-website http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be prevented by deactivating them in the settings of the browser. Please note that not all functions of this online offer can be used in this case.

You can also set and change your settings for the use of cookies on our site at any time in our Consent Management Platform (CMP) https://de.pons.com/?!=privacysettings.

4.6.4 Cookie consent with OneTrust

Our website uses the cookie consent technology of OneTrust to obtain your consent to the storage of certain cookies on your terminal device and to document this in accordance with data protection regulations. The provider of this technology is OneTrust LLC (UK headquarters: Cannon Green, 27 Bush Lane, London EC4R 0AA, UK). We use OneTrust to store cookie settings for the entire website. OneTrust stores information about the categories of cookies used by the website and whether users have given or revoked their consent to the use of each category. This allows us to prevent cookies from being set in each category in the user’s browser unless consent is given. OneTrust uses cookies for information storage which have a normal lifetime of 30 days so that the preferences of returning visitors are stored.

4.6.5 Web analysis by Google Analytic (cookie based)

On our website we use the Google Analytics service. This is an analytical service provided by Google Ireland Limited, Gordon House 4, Barrow St., D04, ESW5, Ireland (Google).

Google uses cookies (see above 4.6.3). The information generated by the cookie about your use of our website is as a rule transmitted to Google in the USA, and processed there. The same applies to your anonymised IP address. In addition, Google Analytics analyses the data contained in the log files, the Internet address of the website which you accessed before your visit to our website (referrer URL), and the search term with which you found our website via a search engine.

Google processes the data on our behalf in order to evaluate the use of our website and compile reports on the activities on our website. Google uses the data contained in the log files, for example, in order to compile statistics on the frequency with which our website is accessed. In this process pseudonymised user profiles of visitors can be created on the basis of the processed data.

We only apply Google Analytics with activated IP anonymisation. This means that within the member states of the European Union or in the European Economic Area your IP address is truncated by Google. Only in exceptional cases the full IP address will be transmitted to Google in the USA and then truncated there.

You can prevent the storage of cookies by setting your browser as described above. You can also prevent the processing of data generated by the cookie by downloading and installing the plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de. With effect for our website an opt-out cookie is set in the browser which you are currently using. If you delete the cookies in this browser, you will need to click on this link again. If you use several devices or browsers, you must click on this link for each individual device in each individual browser.

The data is processed on the basis of your consent (Art. 6 Section 1 a) GDPR). For further information about Google Analytics please see the following Google website: https://support.google.com/analytics/answer/6004245?hl=de.

4.6.6 Web analysis by Hotjar

On our website we use "Hotjar", a web analysis service provided by Hotjar Ltd., Level 2, St Julian's Business Centre, 3, Elia Zammit Street, St Julian's STJ 1000, Malta (referred to below as "Hotjar")

Among other things Hotjar uses cookies to enable an analysis of your use of our website. The cookies used by Hotjar are stored on your terminal device for varying lengths of time, some of them only during your visit, others for 365 days. The information collected in this way is transmitted to Hotjar on a server in Ireland and stored there. The following information is collected by the tracking code: device-specific data collected by your end device and your web browser:

  • IP address of your terminal device (collected and stored in an anonymised format)
  • email address including your first and last name, if you have provided it to us through our website
  • screen size of your terminal device
  • device type and browser information
  • geographical data (country only)
  • language used to display our website
  • user interactions
  • mouse commands (movement, position and clicks)
  • keystrokes

Log data that is automatically used by our server when using Hotjar:

  • referring domain
  • visited websites
  • geographical data (country only)
  • language used to display our website
  • date and time of access

Hotjar uses this information to evaluate your use of our website, to create reports on the use of our website and to provide other services in connection with the evaluation of our website. Hotjar also uses the services of third parties (e.g. Google Analytics and Optimizely). These third parties may store or otherwise process information that your browser transmits during your visit to our website (possibly including the IP address).

We use Hotjar for the purpose of analyzing the use of our website and to be able to continuously improve individual functions and offers as well as the user experience. Through the statistical evaluation of user behaviour we can improve our offerand make them more interesting for you as a user. The legal basis  your consent to the processing of data (Art. 6 Section 1 a) GDPR.

For further information please see the Hotjar privacy policy here.

You can prevent the saving of your user profile and information about your visit to our website by Hotjar, together with the setting of Hotjar tracking cookies on other websites, by clicking on this Opt-Out-Link.

4.6.10 Advertising with DoubleClick

On our website we use DoubleClick, an online marketing tool from Google.

DoubleClick uses cookies to serve ads relevant to users, to improve campaign performance reports, and to prevent a user from seeing the same ads more than once. Google uses a cookie ID to help identify which ads are being served on which browser, so that it can prevent them from being shown more than once. DoubleClick may also use cookie IDs to track conversions related to ad-based enquiries: for example, when a user sees a DoubleClick ad and then visits the advertiser's site on the same browser to make a purchase. The data is processed on the basis of your consent (Art. 6 Section 1 a)GDPR).

If you do not wish to continue to have anonymised data collected by Doubleclick, please click on the following opt-out link https://adssettings.google.com/authenticated?hl=e. This opt-out cookie deletes the previously stored information and prevents any further collection of information.

For more information about Google's privacy policy, please visit https://privacy.google.com/intl/en/# and https://www.google.com/policies/privacy/?hl=de.

4.6.11 Advertising with Google Adwords

On our website we use Google Adwords, an online marketing tool from Google, to provide advertising on our website and on third-party websites for previous visitors to our website.

The ads are displayed based on information stored in cookies that Google places on your computer. The text files contain information about your visit to our website, in particular product views that are activated during subsequent visits to this or third-party websites for specific product recommendations. The cookie contains a random alias. If you visit our website within a certain period of time and view our products, Google can recognise you by your pseudonym. However, the information cannot be assigned to you personally. We or Google will not combine this information with your personal data and will not pass it on to third parties. The processing of the data is based on your consent (Art. 6 Section 1 a) GDPR).

You can prevent the storage and use of information in a cookie set by Google by clicking on the following link http://www.google.de/ads/preferences and making your settings there.

For more information about Google's privacy policy, please visit https://privacy.google.com/intl/en/# and https://www.google.com/policies/privacy/?hl=de.

4.6.12 Registering/signing in with your Facebook access data

If you are registered with Facebook Inc., 4 Grand Canal Square, Dublin 2, Ireland, you can register with our website using the button "Register with your Facebook user data". When you wish to register you are redirected to Facebook, and can sign into our website with your Facebook user data. If you register in this way, Facebook provides us with the following data from your Facebook profile: user name, surname, first name. We use this data exclusively for the purpose of your registration/login as a customer. For the purpose of the processing of your data by Facebook and your rights in this respect, please see the Facebook privacy policy: https://www.facebook.com/policy.php. We have no influence on the processing of data by Facebook. If you object to such an exchange of data between Facebook and ourselves, you should avoid registering with us via your Facebook account.

In turn data from our website can also be transmitted to Facebook Inc. The legal basis for the transmission of data from or to Facebook is your consent (Art. 6 Section 1 a GDPR). The provision of the data is voluntary. Registering with Facebook is not a requirement for the conclusion of a contract with us. The data which we receive from Facebook is deleted immediately after your registration/login.

4.6.13 a) Special data protection provisions relating to the "PONS ONLINE DICTIONARY"

In addition to the remaining terms of this privacy policy, the following applies to our "PONS ONLINE DICTIONARY" service on www.pons.com :

If you register with the "PONS ONLINE DICTIONARY" service, the processing of your data enables you to create your user account and your profile (so-called "visiting card"), so that other registered users can find out more about you and get in touch with you, the creation of personal vocabulary lists and the identification of your posts with the user name you select when you register.

In accordance with Art. 6 Section 1 b GDPR, the legal basis for this – if you have entered data in input fields which are not designated as mandatory – is your consent (Art. 6 Section 1 a GDPR). If and when you delete your user account, your data will also be deleted immediately. The data will be deleted at the latest if you have not signed in for a period of four years, unless the posts are relevant for copyright purposes. In this case the applicable periods will be determined by copyright legislation.

In addition to those mentioned above, additional recipients of the data will be all other registered users of the "PONS ONLINE DICTIONARY", who can view the data in your "visiting card" and your posts.

The processing of your data is not a requirement. The "PONS ONLINE DICTIONARY" can also be used without the provision of additional data. However, to register with the "PONS ONLINE DICTIONARY" the minimum requirement is the entry of your email address and user name, so that we can send you confirmation of your registration and you can log in later with your user name. You can also select a pseudonym as your user name. All other information you provide is on a voluntary basis. However, if you do not register, many functions of the "PONS ONLINE DICTIONARY" will not be available to you (e.g. changing or adding dictionary entries, access to forums, the sharing of posts and saving personal vocabulary lists).

4.6.13 b) Special data protection provisions relating to the "Langenscheidt Schule Wörterbuch App"

Special Terms of Use https://en.pons.com/p/conditions-of-use apply for the use of the “Langenscheidt Schule Wörterbuch App”. In order to access the app content, an access code has to be activated on the Langenscheidt website. This access code is connected to the corresponding user account and user device. To be able to manage your licenses, we store your device name, the date of your access code activation and the date of your last online access of the app. We will process this data until the withdrawal of your consent, but at least for 3 months after the end of the contract. The code activation is at least possible for a period of 36 months after publication of the printed edition

4.6.14 Survey Monkey

For the conduct of surveys on our website we use the services of SurveyMonkey Europe UC, 2 Shelbourne Buildings, Shelbourne Road, Dublin, Ireland. If you voluntarily participate in this survey, SurveyMonkey will collect information about the device and application you are using to participate in the survey. This includes your IP address, operating system version, device type, system and performance information, and browser type. If you are participating in the survey through a mobile device, SurveyMonkey will also collect the UUID of the device. SurveyMonkey also uses third-party tracking services, which in turn use cookies and page tags (also known as web beacons) to collect usage data and user statistics. We have no control over the amount of data collected by SurveyMonkey. For more information about the cookies SurveyMonkey uses, its privacy policy and how long each cookie is stored, please visit https://www.surveymonkey.de/mp/legal/privacy/#data-transfers-and-privacy-shield-certification.

You can prevent the installation of cookies by deleting existing cookies and deactivating the storage of cookies in the settings of your web browser. Please note that in this case you may not be able to use all functions of our website to their full extent.

We use SurveyMonkey to provide you with surveys. For this purpose, we have a legitimate interest in processing the above-mentioned data, which is based on Art. 6 Section 1 lt. f) GDPR.

SurveyMonkey Europe UC is a subsidiary of SurveyMonkey Inc., based in the United States. It cannot be ruled out that your data collected by SurveyMonkey may also be transferred to the USA. As such, SurveyMonkey is committed to complying with the standards and regulations of European data protection law.

4.7 Statistics and Analysis tools

4.7.1 Web analysis by InfOnline

Our website uses the measurement procedure ("SZMnG") of INFOnline GmbH (https://www.INFOnline.de) to determine statistical parameters about the use of our offers. The aim of the usage measurement is to statistically determine the number of visits to our website, the number of website visitors and their surfing behaviour statistically - on the basis of a uniform standard procedure - and thus to obtain values that are comparable across the market.

For all digital services that are members of the Informationsgemeinschaft zur Feststellung der Verbreitung von Werbeträgern e.V. (IVW - http://www.ivw.eu), the usage statistics are regularly compiled by the IVW with the performance values "Page Impression" and "Visits". These range figures and statistics can be viewed on the respective websites.

Legal basis for the processing

The measurement by means of the SZMnG measurement procedure by INFOnline GmbH is carried out within the scope of and participation in the IVW e.V. with a legitimate interest according to Art. 6 Paragraph 1 lit. f) DSGVO.

The purpose of the processing of personal data is the compilation of statistics. The statistics are used to track and document the use of our website. In order to market this website, it is essential to measure usage which ensures comparability with other market participants. Our legitimate interest results from the economic usability of the findings from the statistics and the market value of our website - also in direct comparison with websites of third parties - which can be determined on the basis of the statistics.

In addition, we have a legitimate interest in using the pseudonymised data of INFOnline and IVW for statistical purposes (INFOnline, IVW). Furthermore, we have a legitimate interest in using the pseudonymised data of INFOnline for the further development and provision of interest-based advertising media.

Type of data

INFOnline GmbH collects the following data,which, according to the EU-DSGVO, have a personal character.

IP address: In the Internet every device needs a unique address, the so-called IP address. The storage of the IP address at least for a short period of time, is technically necessary due to the way the Internet works. The IP addresses are shortened by 1 byte before any processing and are only processed anonymously. The unabridged IP addresses are not stored or further processed.
A randomly generated client identifier: The range processing uses alternatively either a third party cookie, a first-party cookie, a "local storage object" or a signature that is composed of various automatically transmitted information from your browser for the recognition of computer systems. This identifier is unique for a browser as long as the cookie or local storage object is not deleted. A measurement of the data and subsequent assignment to the respective ClientIdentifier is therefore also possible if you call up other websites that also use the measurement procedure ("SZMnG") of INFOnline GmbH.
The validity of the cookie is limited to a maximum of 1 year.

Use of the data

The measurement procedure of INFOnline GmbH used on this website collects usage data. This is done in order to collect the performance values page impressions, visits and clients.

In addition, the measured data is used as follows:

A so-called geolocation, i.e. the assignment of a website visit to the location of the visit is carried out exclusively on the basis of the anonymised IP address and only up to the geographical level of the federal states/regions. From the geographical information obtained in this way no conclusions about the user's actual location can be drawn.
The usage data of a technical client (e.g. of a browser on a device) is aggregated across all web pages and stored in a database.

Storage period of the data

The full IP address is not stored by INFOnline GmbH. The shortened IP address is stored for a maximum of 60 days. The usage data in connection with the unique identifier will be stored for a maximum of 6 months.

Passing on the data

The IP address as well as the shortened IP address will not be passed on.

Rights of the data subject

The data subject has the following rights:

Right to information (Art. 15 DSGVO).
Right to rectification (Art. 16 DSGVO)
Right to object (Art. 21 DSGVO)
Right to erasure (Art. 17 DSGVO)
Right to restriction of processing (Art. 18f. GDPR)
Right to data portability (Art. 20 DSGVO)
Right of revocation (Art. 7 para. 3 DSGVO) (in case of consent)
For these kind of requests, please contact datenschutz@pons.de.

Please note that in case of such requests, we must ensure that it is actually the person concerned.

Right to object

If you do not wish to participate in the measurement, you can object under the following link:

https://optout.ioam.de

To guarantee exclusion from the measurement, it is technically necessary to set a cookie. Should you delete the cookies in your browser, it is necessary to repeat the opt-out procedure under the above-mentioned link.

The data subject has the right to lodge a complaint with a data protection authority.

Further information on data protection in the measurement process can be found on the website of the INFOnline GmbH (https://www.infonline.de) which operates the measurement procedure and the data protection website of the IVW (http://www.ivw.eu).

4.7.2 Web analysis with Matomo

On our website we use Matomo.  This is an analysis service of the open source project Matomo which is represented by the ePrivacy Holding GmbH, Große Bleichen 21 in 20354 Hamburg, within the EU

Matomo uses cookies (see 4.6.3 above). The protection of your data is important to us that is why we have also configured Matomo in such a way that your IP address is only recorded in abbreviated form. We therefore process your personal usage data anonymously. It is not possible for us to draw any conclusions about your person. Further information on Matomo’s terms of use and data protection regulations can be found at: https://matomo.org/privacy/

Information about the individual cookies you find here: https://matomo.org/faq/general/faq_146/

4.7.3 Web analysis by Google Analytics (without cookies)

PONS carries out evaluations of a purely statistical nature and completely anonymously at the request of the customer and also itself for the purpose of analysing usage by the customers. The data collected by the statistics are used solely to optimise the performance of the services. In this way we can e. g. improve the functioning and ensure for example the way to find the word you are looking for in the online dictionary. These statistics are partly carried out with an implementation of Google Analytics that does not use cookies. We have also added the configuration parameter “anonymizeIp” to Google Analytics. Your IP address is only recorded in abbreviated form by the code. We therefore process your personal usage data in Google Analytics anonymously. Apart from that, your data is only processed pseudonymously. It is not possible for us to draw any conclusions about your person. Further information on the terms of use of Google Analytics and the data protection regulations can be found at: http://www.google.com/analytics/terms/de.html   or under https://www.google.de/intl/de/policies/

If you want to deactivate Google Analytics in your browser, please go to https://tools.google.com/dlpage/gaoptout?hl=de, download and install the appropriate add-on.

5. Rights of data subjects

If your data is processed by us you are a data subject as defined by the GDPR, and you have the following rights in relation to the data controller. You can assert all of these rights by sending an email to kundenservice@pons.de or to one of the addresses indicated in Sections 2 and 3.

5.1 The right to information and data transferability

In accordance with Art. 15 GDPR you have the right to require us to provide you with information:

  • about whether we have saved your data and, if so, what data and for what purpose,
  • about the source of the data
  • and to what recipients or categories of recipients your data may  be passed on.

In accordance with Art. 21 GDPR you have the right to receive the data you have transmitted to us on the basis of your consent or a contract, provided that the processing of the data was automated. If you wish and if it is technically possible, we will also transmit this data to a third party at your request.

5.2 The right to correction

If the data relating to you is incorrect or incomplete, you have the right to demand that your data should be corrected and if relevant completed by the data controller (Art. 16 GDPR).

5.3 The right to the deletion or blocking of data

You have the right to demand that we delete your data in accordance with Art. 17 GDPR or block it in accordance with Art. 18 GDPR. If you delete your customer account with our publishing company we will delete your data, unless we have the right to save it for the fulfilment of contracts which have not yet been completed, for the assertion of legal claims, or in compliance with statutory obligations.

5.4 The right of objection

To the extent that we process data exclusively for the purpose of safeguarding our interests on the basis of Art. 6 Section 1 f GDPR you have the right to object to the processing of your data for reasons arising from your individual situation. If you make such an objection, we will no longer process the relevant data, unless we can prove that such processing is essential for the protection of those of our interests which take precedence over your interests, rights and freedoms, or if the processing is for the purpose of asserting legal claims.

In addition, you can at any time object to the processing of your data for advertising purposes without incurring any other charges than the transmission cost at basic rates. You can at any time and free of charge object to being sent advertising emails, for example by clicking on the relevant unsubscribe link at the foot of an advertising email. Such an objection will also mean that you will no longer receive newsletters in accordance with 4.5.

5.5 The right to withdraw consent

If you have given your consent to the processing/use of your data, you can withdraw this consent at any time by sending an email to kundenservice@pons.de. Such withdrawal will not affect the legality of the processing of your data prior to the withdrawal of your consent. We will then delete your data, unless we have the statutory right or obligation to retain and process it.

5.6 The right to complain to the regulatory authorities

You have the right to register a complaint with the regulatory authorities, in particular with the State Office for Data Protection and Freedom of Information Baden-Württemberg, Lautenschlagerstraße 20, 70173 Stuttgart

6. Links

If our website contains links to other websites which are not operated by us, we are not responsible for the compliance with data protection regulations on the part of such websites.

7. Data transfer to third countries

As part of our data processing operations described above, we may transfer your personal data to other countries (including countries outside the EEA) where data protection standards may differ from those of your place of residence. Please note that data processed in third countries may be subject to local laws and may be accessible to foreign governments, courts, law enforcement and supervisory authorities.

However, when transferring your personal data to such countries, we will take reasonable steps to maintain an adequate level of data protection.

In the case of a transfer to a state outside the EEA, this transfer is either authorised by your consent in accordance with Art. 49 Section 1a GDPR or it is protected by concluding the EU Standard Contractual Clauses in accordance with Art. 46 GDPR. For specific information on the individual protection measures, you can also contact our data protection officer by e-mail at datenschutz@pons.de.

8. Security

Personal data which is exchanged between you and our publishing company via our websites is in principle transmitted in encrypted form. In addition, we take technical and organizational security precautions to protect the data which you have entrusted to us against manipulation, loss, destruction or access by unauthorised persons. Please note, however, that in the case of email communications we are unable to guarantee full data security, which means that it is advisable to send confidential information by mail.

Notice: This Privacy Policy document is a translation from the Datenschutzerklärung document to be found here . In case of doubt, the version in German language prevails.

Valid from: 10.02.2021