Axel Springer Ideas Engineering GmbH
Phone: +49 30 2591 78100
Responsible for the content according to § 6 Abs. 2 MDStV
District Court/Commercial Register
Based in Berlin, District Court of Charlottenburg, HRB 138466 B
VAT ID No. DE 287499537
Executive Directors: Samir Fadlallah, Michael Alber
Copyright 2018 Axel Springer Ideas Engineering GmbH. All rights reserved. All types of content (texts, photographs, graphics, sound, animations and videos) and their arrangement on the website of Axel Springer Ideas Engineering GmbH fall under the German Copyright Act and other protective laws. Without the prior consent of Axel Springer Ideas Engineering GmbH such content may only be used within the limiting provisions of the Copyright Act and subject to other applicable laws.
1. Data controller and general information
Your data will be processed by Axel Springer SE, Axel-Springer-Straße 65, 10888 Berlin, phone: +49 30 2591 0, email: firstname.lastname@example.org (service provider for the purposes of the Act for Telecommunication Media Services (TMG) and data controller for the purposes of the General Data Protection Regulation (GDPR).
When we use terms such as “we” or “us”, this is who we are referring to.There is one exception to this where data is processed in relation to Page Insights for our Facebook Fanpages (see point 10 below); in this case we are joint controllers with Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland (“Facebook”).
We consider Axel Springer Ideas Engineering GmbH to mean any sub-pages, content and functions (for instance discussion forums, prize draws) present in this document https://ideas-engineering.io and Facebook Fanpages. Individual elements of Axel Springer Ideas Engineering GmbH are also referred to as “online services” below. The same is meant wherever we refer to a website.
Our services are intended for the general public, and not for children. We do not knowingly collect personal data from users who are regarded as children under applicable national legislation.
2. Collection and processing of personal data
You can usually use online services that do not require payment or registration without providing personal data. In certain cases, however, we may process personal data listed under point 3. This is only done as is necessary to provide a functioning website, our content and our services. We also process personal data in connection with the use of Axel Springer Ideas Engineering GmbH insofar as you provide such data voluntarily, for instance for the purpose of registration, a prize draw, sending us an enquiry, submitting an application to us, subscribing to a publication, or some other legal basis (see point 4). If you do not wish to provide personal data, you will unfortunately not be able to make use of our services or will only be able to use them to a limited degree.
3. Categories of processed data
As soon as you make use of Axel Springer Ideas Engineering GmbH, our system will automatically collect information from the computing device accessing the service. The following data may be collected by way of example:
Information about the browser type and version used
The operating system of the user
Date and time of the access
Web analysis data / pseudonymised user profiles (cookie ID, ad ID, etc.)
Websites from which the users access our website
Websites that the users access from our website
4. Legal basis and purposes of processing
We only process your data on the basis of one or several potential legal bases.
Pursuant to the GDPR, personal data may be processed in particular under the terms of a contract or to perform pre-contractual activities, if consent is provided, if there is a legitimate interest or compelling statutory cause, or if it becomes necessary to protect vital or public interests.
We also use your email address to send you our newsletter if you have given us your prior express consent to receive a newsletter and/or marketing emails in this connection. In this case, we will process your email address in order to be able to send you the newsletter as requested (Art. 6 para. 1 point a GDPR). You can withdraw your consent at any time for the use of your email address for such purposes in writing or via electronic text communication media at email@example.com or Axel-Springer-Str. 65 in 10888 Berlin with effect for the future.
On our website and on individual blogs, we offer a comment function for which personal data that you enter voluntarily is stored. If you have provided consent for this purpose, you will be able to submit and subscribe to comments on our website in some cases. The same applies to surveys that you participate in. If you wish to publish a comment, you will need to complete the fields for this purpose. You can also post under a pseudonym. If you do not complete the fields, you cannot publish a comment. We collect and process the data that you provide in order to publish your comment as requested (Art. 6 para. 1 point b GDPR). In particular, we require your email address so that we can contact you about any objections to your comment and allow you make a statement in this connection (Art. 6 para. 1 point c GDPR).
For processing activities encompassed by none or several of the aforementioned legal bases, processing is performed insofar as it is necessary to uphold a legitimate interest and insofar as this interest is not outweighed by your interests, fundamental rights or freedoms following a thorough consideration of the interests as a whole. A legitimate interest can be assumed if the data subject is a customer of the data controller. If personal data is processed on this basis, our particular legitimate interest here is in the performance of our business activities for the benefit of all of our employees and our shareholders.
Our legitimate interest in being able to offer you tailored products, informing you about our products, news and quality features, and continuously improving our services and products with a view to increasing our revenue provides the legal basis for processing by means of web/app analysis. See point 9 for details on Web analytics tools.
You can object to processing performed on the basis of a legitimate interest at any time (see point 14).
If data is processed for a purpose other than that specified upon collection, a compatibility test is performed pursuant to Art. 6 para. 4 of the GDPR. Continued processing is then only permitted if the original purpose is compatible with the new purpose or if this processing is permitted on a specific legal basis. Recognised compatible purposes include the establishment, exercise or defence of legal claims under civil law, unless outweighed by an interest of the data subject, in which case we will inform you about the change in purpose. If the new purpose is not compatible with the purpose specified upon collection, the data will be collected again on a new legal basis. We will also inform you about the change in purpose in this case.
5. Place of processing
We personally will not transmit your personal data to countries outside of the European Economic Area, except where permitted by the GDPR. We cannot know and cannot influence whether third parties with whom you have concluded a separate contractual agreement (for instance with Facebook, if you have a Facebook account) transmit data to countries outside of the European Economic Area.
6. Origin of data
In certain cases, we also receive data because you have consented to its transmission to us.
7. Transmission of your data to third parties
We will only transmit your personal data to third parties if transmission is required to comply with our contractual obligations to you if this evidently needs to be done through or jointly with another provider (e. g. partnerships), if we are permitted or required by law to transmit the data in any other fashion, or if you have provided us with the corresponding consent.
To provide our service, selected personal data may be transmitted to certain departments within our company, including employees of the Accounting, Product Management, Marketing and IT departments.
In certain cases we also employ external service providers or affiliates commissioned by us to process data on our behalf on the basis of instructions. We ensure that such service providers are contractually bound by the strict terms of the GDPR as data processors and that they are prohibited from using your data for any other purposes. Data processors employed by us provide the following services in particular: hosting, sending newsletters, survey/comment services and web/app analytics tools. See point 9 for details on Web analytics tools.
Data is transmitted to data processors on the basis of Art. 28 para. 1 of the GDPR, and also on the basis of our legitimate interest in economic and technical advantages afforded by the employment of specialist data processors as permitted by Art. 6 para. 1 point f of the GDPR.
Insofar as we are required to do so by law or are permitted to do so under data protection law, we will transmit personal data to public authorities such as the police or public prosecution service (Art. 6 para. 1 point c GDPR). This data is transmitted on the basis of our legitimate interest in preventing abuse, prosecuting criminal acts and securing, establishing and enforcing legal claims, unless outweighed by your rights and interests in the protection of your personal data, Art. 6 para. 1 point f of the GDPR.
8. Cookies and similar technologies
Cookies are small files that your browser places in a folder designated for this purpose on your device. This makes it possible, for instance, to determine whether you have visited a website before. With your consent, cookies can also be used to store account details for an online service, meaning that you do not need to enter these account details every time you open the website. Many cookies contain what is known as a “cookie ID”, which is a unique identifier for the cookie. It consists of a string of characters which websites and servers can associate with the specific web browser in which the cookie has been stored. This enables visited websites and servers to differentiate between the specific browser of the data subject and other web browsers containing different cookies. A specific web browser can be recognised and identified using the unique cookie ID. Without additional information, cookies cannot be used to identify you personally.
Advertisements are usually delivered by third-party providers. These may use information on your visits, provided that your device configuration allows this, so that advertisements on products and services that may be of interest to you are displayed. Specific contact details such as your name, postal address, email address or telephone number will not be transmitted under any circumstances.
Unless indicated otherwise, the legal basis is Art. 6 para. 1 point f GDPR and Section 15 para. 3 Telemedia Act (TMG). Where consent is given within the meaning of Art. 6 para. 1 point a GDPR, you have the right to withdraw this at any time, without this having any effect on the lawfulness of processing previously undertaken on the basis of consent before it was withdrawn. In the event of legitimate interest within the meaning of Art. 6 para. 1 point f GDPR, our legitimate interest lies in particular in the purposes mentioned above, and in the fundamental purposes of our business operations and journalism.
9. Web analytics tools
We have integrated Google Analytics (with anonymisation function). Google Analytics is a web analytics tool from Google Ireland Limited („Google“), Gordon House, Barrow Street, Dublin 4, Irland. Web analytics is the collection and analysis of data about the behaviour of website visitors. A web analytics tool collects, among other things, data about the website from which a data subject arrived at particular website (known as the referrer), the subpages of the website that were accessed and how often and for how long a subpage was looked at. Web analytics is primarily used to optimise a website and for cost-benefit analysis of online advertising.
For web analytics via Google Analytics we use the suffix "_gat._anonymizeIp". This means that the IP address of the data subject's Internet connection is truncated and anonymised by Google if our websites are accessed from a Member State of the European Union or from a contracting state of the Agreement on the European Economic Area.
The purpose of the Google Analytics component is to analyse visitor flows on our website. Among other things, Google uses the data and information obtained to analyse the use of our website, to compile online reports for us detailing activities on our websites, and to provide other services connected with the use of our website.
Google Analytics sets a cookie on the data subject's IT system. An explanation of what cookies are is provided above. Setting the cookie enables Google to analyse the use of our website. Each time one of the individual pages of this website is accessed, which is operated by us and incorporates a Google Analytics component, the web browser on the data subject's IT system is automatically prompted by the respective Google Analytics component to transmit data to Google for the purposes of online analysis. As part of this technical process, Google gains knowledge of personal data, such as the IP address of the data subject, which Google uses, among other things, to track the origin of visitors and clicks, and to subsequently enable commission to be calculated.
Using the cookie, personal information is stored, such as time and location of access and the frequency of visits to our website by the data subject. Each time our website is visited, this personal data, including the IP address of the Internet connection used by the data subject, is transferred to Google. This personal data is stored by Google. In some cases, Google may share the personal data collected through this technical process with third parties.
The data subject can prevent cookies from being set by our website at any time, as explained above, by configuring the web browser they use to block cookies. Configuring the web browser in this way will also prevent Google from setting a cookie on the data subject's IT system. A cookie already set by Google Analytics can also be deleted at any time using a web browser or another software solution.
10. Social networks
You can also find us on the social networks of external companies such as Facebook and Twitter. We have also integrated certain functions of these networks into our own online services. However, it is only possible to use either of them if you are registered and logged in to the relevant social network. Please note that use of each of the social networks fundamentally is governed by the relevant terms of service and privacy policies of the respective companies and we have no influence over these.
At the following links we use Facebook Fanpages, for which we are joint controllers with Facebook Ireland Limited: https://www.facebook.com/AxelSpringerIdeas/.
As joint controllers with Facebook, we analyse how you use our Fanpage (Page Insights). The information required under the GDPR regarding data processing in relation to Page Insights can be obtained from Facebook; it is currently available in Facebook privacy policies at https://www.facebook.com/privacy/explanation.
Facebook also provides the relevant content of the contract concluded between Facebook and us on processing under joint controllership pursuant to Art. 26 GDPR; this is currently available at the following link: https://www.facebook.com/legal/terms/page_controller_addendum.
In relation to Page Insights, we only receive anonymised statistics. We have no access to personal data processed by Facebook. Anonymised data is processed by us on the basis of statutory provisions that allow us to process personal data because we have an overriding legitimate interest in obtaining a better understanding of the interests of visitors to our Fanpages (Art. 6 para. 1 point f GDPR).
On the Fanpages, Facebook offers various community functions which enable you to interact with other users, for example by making posts, leaving comments or liking or sharing posts. We would point out that these areas are publicly accessible and any personal information that you post or provide during sign-in can be seen by others. We have no control over how other Fanpage users use this information. In particular, we cannot stop unwanted messages being sent to you.
11. Other services
We use additional third-party services referred to below for purposes of, and in pursuit of our interests in, ensuring the functionality of our website and/or our app and in order to display content that may be of interest to you. The provider of each respective service is the controller for data processing purposes within the meaning of Art. 4 para. 7 GDPR. Unless indicated otherwise, the legal basis is Art. 6 para. 1 point f GDPR and section 15 para. 3 TMG.
12. Integration of third-party providers
We integrate services from the third-party service providers listed below for purposes of, and in pursuit of our interests in, displaying and optimising our website. Without limitation, this includes video and audio players as well as embedded and appropriately labelled content and partner modules such as such as weather and maps, job markets, real estate, currency converter and competitions. In this respect we collect no personal data whatsoever, nor do we transmit any to the third-party providers. Where these types of services are integrated, your browser routinely establishes a direct connection to the servers of the third-party provider and transmits data to the provider, even when content is simply loaded and displayed. In general, however, the only data concerned is the user’s IP address, without which the third-party provider would not be able to send the embedded content to the browser of the user in question. The IP address is therefore required in order for this content to be displayed. The respective third-party provider is exclusively responsible for data processing in accordance with Art. 4 Abs. 7 GDPR. The legal basis for the integration of these services is Art. 6 para. 1 point f GDPR.
13. Storage duration
We only store personal data as long as we are authorised to do so and as long as the purpose of processing is still relevant. Statutory retention periods govern how long personal data is stored for. Once this period has expired, the corresponding data is routinely erased, provided it is no longer needed to initiate or perform a contract.
14. Contact details and your right as a data subject
Should you have any queries or comments on data protection and privacy or wish to exercise your rights as a data subject, please contact our data protection officer at any time:
Axel Springer SE
Information and rectification
You can receive information at any time and at no charge about whether we are processing personal data related to you and also about which information we are specifically storing about you. You are also entitled to receive a copy of the stored information. You can also have errors in your data corrected and missing information completed.
Erasure, restriction of processing and “right to be forgotten”
You can request that your data be erased and its processing restricted. Please note that statutory retention obligations are in effect for contracts relating to paid services (such as the purchase of a subscription to Axel Springer Ideas Engineering GmbH) and that we will therefore not always be able to fully erase your data completely in all cases. In this case, your data will be labelled to the effect that future processing should be restricted.
Where applicable, you also have the right to have your personal data transmitted to you or to another data controller in a structured, standardised and machine-readable format, as long as processing is performed on the basis of consent or contract using automated procedures. This does not apply, however, where the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. You also have the right to have the personal data transmitted directly from one data controller to another, provided that it is technically feasible to do so and does not infringe upon the rights and freedoms of other persons.
Withdrawal of consent, objecting to processing
You can withdraw your previously-given consent at any time with effect for the future by contacting the aforementioned address. In particular, you may express your objection in writing or via electronic text communication media at firstname.lastname@example.org or Axel-Springer-Str. 65 in 10888 Berlin regarding the use of your email address for the purpose of newsletter delivery with effect for the future without incurring any transmission costs beyond the base costs imposed by your provider.
Moreover, you have the right to object to the processing of your personal data at any time (where such processing is based on a legitimate or public interest) for reasons arising from your particular circumstances. This also applies to profiling activities based on these provisions. If such an objection is received, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing that override the interests, rights and freedoms of the data subject, of if the processing is for the establishment, exercise or defence of legal claims.
If we are processing personal data for the purpose of direct marketing, you have the right to object to the processing of your personal data at any time for the purpose of such marketing by contacting the aforementioned address. This also applies to profiling insofar as it is connected with such direct marketing. You also have the right to file an objection for reasons arising from your particular circumstances against processing of your personal data that we are engaged in for scientific, historical research or statistical purposes, unless such processing is required to perform a task that is in the public interest.
Right of complaint
You also have the right to submit a complaint to the competent supervisory authority and to seek legal remedies. The supervisory authority to whom the complaint was submitted will notify the complainant about the status and result of their complaint, including the option of seeking a legal remedy through a court of law.
Existence of automated decision-making processes
We do not perform any automated decision-making or profiling.
Last revised: September 26, 2019