4.1. General information
Please note that we are entitled to outsource the processing of personal data in the context of data protection law provisions fully or partially to external service providers working on our behalf as data processors (Art. 4 no. 8 GDPR).
In general, our external service providers process your personal data within the European Union (EU) or the signatory states of the Agreement on the European Economic Area (EEA). However, in the event that your personal data is transferred to a service provider located in the third country outside of the EU or EEA, LAS ensures the protection of your personal data by means of adequate safeguards in accordance with legal and regulatory requirements, e.g. EU Standard Contractual Clauses.
For further information, in particular what adequate safeguards we have taken in specific individual cases when transferring your personal data to third countries, as well as to obtain a copy thereof, please contact us via the contact details specified in section 1.
4.2. Use of the newsletter deliver service provider MailChimp
For the delivery of our newsletter, we use the service “MailChimp” of the service provider Rocket Science Group LLC, 675 Ponce De Leon Ave. NE #5000, Atlanta, GA 30308, United States of America, which works as a data processor (Art. 4 no.8 GDPR) on behalf of LAS.
If you have signed up for our newsletter, your name and email address will be stored on the servers of MailChimp in the context of the use of the services. MailChimp processes and uses this personal data on our behalf for the delivery and evaluation of our newsletter.
To this end, the newsletters are provided with a so-called tracking pixel from MailChimp. Said tracking pixel is a pixel-sized file that is accessed by the MailChimp server when our newsletter is opened and via which the technical browser and system information (including your IP address) is collected in order to make technical improvements to the Services. Furthermore, information is collected on whether and when you have opened the newsletter and which links in the newsletter you clicked on. This serves the purpose of evaluating the reading habits of our newsletter recipients in general in order to allow us to customize and optimize our content accordingly.
Please note: If you use the link in the newsletter to access the newsletter online, e.g. for having it properly displayed, you will reach the MailChimp website. In this context, we would like to point out that the MailChimp website might use cookies, tracing pixels, or other technologies beyond our control. For the data processing involved solely MailChimp as controller is responsible. For further information please refer to the MailChimp Privacy Policy.
In addition to your consent for the registration of our newsletter (cf. in this regard section 3.2 lit. b and section 7 lit. f, the legitimate interests of LAS and MailChimp (Art. 6 (1) lit. f GDPR) form the legal basis for the processing of personal data in connection with the analytics of the newsletter. Said legitimate interests consists in our goal to provide a user-friendly newsletter system to you that meets your expectations and needs and serves our business interests.
If you do not consent to the delivery of the newsletter by MailChimp or the statistical evaluation of the newsletter by MailChimp, you can only withdraw your consent to the receipt of our newsletter in its entirety (cf. section 3.2 lit b). Unfortunately, the withdrawal of individual components is not possible.
4.3 Use of TikTok Pixel
We use so-called "TikTok Pixel" ofTikTok Technology Limited (10 Earlsfort Terrace, Dublin, D02 T380, Ireland) (hereinafter "TikTok") on our website to integrate advertising services.
Scope and purposes of data processing
We use the TikTok Pixel to integrate the advertising services offered by TikTok, the so-called "TikTok Advertiser Tools". These advertising services allow us to identify visitors of our website as potential customer groups for the placement of advertisements, the so-called "TikTok Ads", such as in particular by targeting our advertisements and for the improvement of ad delivery and personalised advertising. These customers groups then receive TikTok Ads within the feed of the TikTok social network that are adapted to their interests, i.e. advertisements related to certain keywords.
The TikTok Pixel triggers a process that allows TikTok to collect the following data: IP address, technical information about your browser and the end devices you use (e.g. language setting, screen resolution), your user behaviour (e.g. clicks, dwell time, bounce rates), achievement of "website goals" (so-called "conversions", e.g. newsletter sign-ups, downloads, purchases). You can find an overview of the data processed here. We transfer this data about your behaviour on our website to TikTok. We ourselves cannot identify any individuals by means of this behavioural data. However, TikTok is able to combine this data with other data held by TikTok and thus recognize individuals. Some of this data is information stored in the device you are using. In addition, the TikTok Pixel also uses cookies to store information on your used device.
If you are logged into your TikTok account, you also enable TikTok to associate your browsing behaviour directly with your personal profile. You can prevent this by logging out of your TikTok account.
Insofar as the data processing in the context of the provision and use of the "TikTok Advertiser Tools" is carried out on the basis of joint responsibility of LAS and TikTok pursuant to Art. 26 para. 1 GDPR, such as in particular the data transfer to TikTok for use in accordance with the applicable product terms of TikTok, we have concluded an agreement between joint controllers (so-called "Joint Controller Terms") with TikTok in accordance with the legal requirements, which you can view here. Please note that further processing following the data transfer is the sole responsibility of TikTok.
Recipients
The data stored by TikTok can also be accessed and processed by other TikTok companies worldwide.
The data stored by TikTok may also be processed by TikTok companies for their own purposes, such as providing TikTok's web analytics and tracking services, and may be linked to your TikTok account, search history and other data that TikTok has stored about you, such as your user data from other devices. LAS has no control over this data processing and TikTok is solely responsible for this data processing. For more information on how TikTok processes your data, please see TikTok's privacy policy.
Transfer to third countries
A transfer of personal data to third countries, such as TikTok based in the People's Republic of China, cannot be ruled out by LAS.
Please note that the People's Republic of China is a so-called third country that does not have an adequacy decision of the European Commission pursuant to Art. 45 GDPR, and therefore there is no guarantee that TikTok can ensure an adequate level of protection in accordance with the requirements of the GDPR. Therefore, it cannot be ruled out that Chinese authorities may be able to access this data and that EU citizens may not have effective legal remedies.
Legal basis and possibility of withdrawal
The use of the TikTok Pixel and the associated data processing for advertising purposes are based on your consent (Art. 6 para. 1 lit. a GDPR). Your consent can be withdrawn at any time with effect for the future. To withdraw a previously given consent, please use the link "Manage cookies" in the cookie banner on our website.
You can also prevent the collection of data generated by the cookie and related to your use of our website (including your IP address) and the processing of this data by TikTok by not giving your consent to the setting of the TikTok Pixel.
Further information
For further information on data processing by TikTok, please see TikTok's privacy policy.
4.4 Use of YouTube Plugins
We use so-called "YouTube plugins" from YouTube LLC (901 Cherry Ave., San Bruno, CA 94066, USA) on our website. Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) is responsible for the European region. YouTube is a company affiliated with Google LCC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) (hereinafter collectively "Google").
Scope and purposes of data processing
We use YouTube plugins to embed videos stored on the "YouTube" platform (hereinafter "YouTube Videos") on our website so that they can be played directly.
To ensure data protection on our website, YouTube plugins are deactivated when you first enter our website. A direct connection to Google's servers is only established when you independently activate YouTube plugins (consent according to Art. 6 para. 1 lit. a GDPR). Activation takes place when you agree to allow YouTube to be used in the data protection settings in the consent banner or you activate a single YouTube Video on our website individually by clicking on a video placeholder. This prevents your data from being transferred to Google when you first enter our website.
After activation, a connection to Google's servers is established and cookies are exchanged. These cookies tell Google which of our websites you have visited. Google also obtains your IP address. This also applies if you are not logged in to Google or do not have a Google-account. The information collected by Google is transferred to the Google server in the USA.
If you are logged into your Google account, you enable Google to associate your browsing behaviour directly with your personal profile. You can prevent this by logging out of your Google account.
Recipients
The data stored by Google may also be accessed by other Google companies, such as Google LLC, based in California, USA, and processed in the USA and other locations worldwide.
The data stored by Google may also be processed by Google companies for their own purposes, such as providing Google's web analytics and tracking services, and may be linked to your Google account, search history and other data Google has stored about you, such as your user data from other devices. LAS has no control over this data processing, so Google is solely responsible for this data processing. For more information on how Google processes your data, please see Google's privacy policy.
Transfer to third countries
A transfer of personal data to third countries, such as Google LLC, which is based in California, USA, cannot be ruled out by LAS.
Please note that the USA is a so-called third country that does not have an adequacy decision by the European Commission pursuant to Article 45 GDPR, and therefore there is no guarantee that Google can ensure an adequate level of protection in accordance with the requirements of the GDPR. Therefore, it cannot be ruled out that US authorities may be able to access this data and that EU citizens may not have effective legal remedies.
Legal basis and possibility of withdrawal
The use of YouTube and the associated data processing are based on your consent (Art. 6 para. 1 lit. a GDPR). Your consent can be withdrawn at any time with effect for the future. To withdraw a previously given consent, please use the link "Manage cookies" in the cookie banner on our website.
Furthermore, you can prevent the collection of the data generated by the cookie and related to your use of our website (including your IP address) as well as the processing of this data by Google by not giving your consent to the cookie being set.
Further information
For further information on YouTube, please see Google's privacy policy.