Table of Contents
- Controller
- Overview of Processing Activities
- Applicable Legal Bases
- Provision of the Online Offering and Web Hosting
- Use of Cookies
- Presence in Social Networks (Social Media)
Controller
Primo Gastronomie Betriebs GmbH & Co. KG
Bahnhofstraße 20
85591 Vaterstetten
Authorized representatives: Nassim Husain, Tim Angerbauer
Email address: office@primo.restaurant
Phone: +49 89 97373111
Imprint: www.primo.restaurant/impressum
Overview of Processing Activities
The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.
Types of Data Processed
- Contact data.
- Content data.
- Usage data.
- Meta, communication, and procedural data.
- Log data.
Categories of Data Subjects
Purposes of Processing
- Provision of contractual services and fulfillment of contractual obligations.
- Communication.
- Security measures.
- Feedback.
- Provision of our online offering and user-friendliness.
- Information technology infrastructure.
- Public relations.
Applicable Legal Bases
Applicable legal bases according to the GDPR: In the following, we provide an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. If, in individual cases, more specific legal bases are applicable, we will inform you of these in the privacy policy.
Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR)
The data subject has given their consent to the processing of their personal data for one or more specific purposes.
Legitimate Interests (Art. 6 para. 1 sentence 1 lit. f) GDPR)
Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
National Data Protection Regulations in Germany:
In addition to the data protection regulations of the GDPR, national regulations on data protection apply in Germany. This includes, in particular, the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains special provisions on the right to information, the right to erasure, the right to object, the processing of special categories of personal data, processing for other purposes, and transmission, as well as automated individual decision-making, including profiling. Furthermore, state data protection laws of the individual federal states may apply.
Note on the applicability of the GDPR and the Swiss DPA:
This privacy policy serves to provide information according to both the Swiss Federal Act on Data Protection (FADP) and the General Data Protection Regulation (GDPR). For this reason, please note that due to the broader spatial application and comprehensibility, the terms of the GDPR are used. In particular, instead of the terms used in the Swiss DPA such as ‘processing’ of ‘personal data’, ‘overriding interest’, and ‘particularly sensitive personal data’, the terms ‘processing’ of ‘personal data’, ‘legitimate interest’, and ‘special categories of data’ used in the GDPR are employed. However, the legal meaning of the terms will continue to be determined by the Swiss DPA within its scope of application.
Provision of the Online Offering and Web Hosting
We process user data to be able to provide them with our online services. For this purpose, we process the user's IP address, which is necessary to transmit the content and functions of our online services to the user's browser or terminal device.
Processed Data Types:
Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons); log data (e.g., log files concerning logins or data retrieval or access times). Content data (e.g., textual or visual messages and contributions, as well as information concerning them, such as information on authorship or time of creation).
Data Subjects:
Users (e.g., website visitors, users of online services).
Purposes of Processing:
Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); security measures. Provision of contractual services and fulfillment of contractual obligations.
Storage and Erasure:
Erasure in accordance with the information in the 'General Information on Data Storage and Erasure' section.
Legal Bases:
Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further Information on Processing Activities, Procedures, and Services:
Collection of Access Data and Log Files:
Access to our online offering is logged in the form of 'server log files'. The server log files may include the address and name of the retrieved web pages and files, the date and time of retrieval, the amount of data transferred, a message about successful retrieval, the browser type and version, the user's operating system, the referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider. The server log files can be used for security purposes, e.g., to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks), and to ensure the stability and optimal utilization of the servers; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Erasure of data: Log file information is stored for a maximum of 30 days and then erased or anonymized. Data whose further retention is required for evidentiary purposes is exempt from erasure until the final clarification of the respective incident.
Emailing and Hosting:
The web hosting services we use also include the sending, receiving, and storing of emails. For these purposes, the addresses of the recipients and senders, as well as further information concerning the email transmission (e.g., the providers involved) and the content of the respective emails, are processed. The aforementioned data may also be processed for the purpose of SPAM detection. Please note that emails on the Internet are generally not sent in encrypted form. As a rule, emails are encrypted on the transport route, but (unless a so-called end-to-end encryption method is used) not on the servers from which they are sent and received. We can therefore not assume any responsibility for the transmission path of the emails between the sender and the reception on our server; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
1&1 IONOS:
Services in the field of providing information technology infrastructure and related services (e.g., storage space and/or computing capacities); Service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.ionos.de; Privacy policy: https://www.ionos.de/terms-gtc/terms-privacy. Data processing agreement: https://www.ionos.de/hilfe/datenschutz/allgemeine-informationen-zur-datenschutz-grundverordnung-dsgvo/vereinbarung-zur-auftragsverarbeitung-avv-mit-ionos-abschliessen/.
Use of Cookies
The term 'cookies' refers to functions that store and read information on users' end devices. Cookies can also be used for various purposes, such as for the functionality, security, and comfort of online offerings, as well as for the creation of analyses of visitor flows. We use cookies in accordance with the statutory provisions. Therefore, we obtain prior consent from users where required. If consent is not required, we rely on our legitimate interests. This applies when the storage and reading of information is essential to provide expressly requested content and functions. This includes, for example, the storage of settings and ensuring the functionality and security of our online offering. Consent can be revoked at any time. We provide clear information about their scope and which cookies are used.
Notes on Data Protection Legal Bases:
Whether we process personal data with the help of cookies depends on consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained in this section and in the context of the respective services and procedures.
Storage Duration:
With regard to the storage duration, the following types of cookies are distinguished:
• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed their end device (e.g., browser or mobile application).
• Permanent cookies: Permanent cookies remain stored even after the end device is closed. For example, the login status can be saved and preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., when obtaining consent), they should assume that they are permanent and that the storage period can be up to two years.
General Information on Revocation and Objection (Opt-Out):
Users can revoke their consent at any time and also object to processing in accordance with the statutory provisions, including by means of their browser's privacy settings.
Processed Data Types:
Meta, communication, and procedural data (e.g., IP addresses, time stamps, identification numbers, involved persons).
Data Subjects:
Users (e.g., website visitors, users of online services).
Legal Bases:
Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Processing of Cookie Data Based on Consent:
We use a consent management solution in which users' consent to the use of cookies or to the procedures and providers mentioned in the consent management solution is obtained. This procedure serves to obtain, log, manage, and revoke consent, in particular with regard to the use of cookies and comparable technologies used to store, read, and process information on users' end devices. Within the scope of this procedure, users' consent for the use of cookies and the associated processing of information, including the specific processing and providers mentioned in the consent management procedure, is obtained. Users also have the option to manage and revoke their consent. The consent declarations are stored to avoid a new query and to be able to prove consent in accordance with the legal requirements. Storage takes place on the server side and/or in a cookie (so-called opt-in cookie) or by means of comparable technologies in order to be able to assign the consent to a specific user or their device. Unless specific information on the providers of consent management services is available, the following general information applies: The duration of the storage of consent is up to two years. A pseudonymous user identifier is created, which is stored together with the time of consent, information on the scope of consent (e.g., concerning categories of cookies and/or service providers), and information about the browser, system, and end device used; Legal bases: Consent (Art. 6 para. 1 sentence 1 lit. a) GDPR).
Presence in Social Networks (Social Media)
We maintain online presences within social networks and in this context process user data in order to communicate with the users active there or to offer information about us.
We would like to point out that user data may be processed outside the European Union. This can result in risks for users because, for example, the enforcement of users' rights could be made more difficult.
Furthermore, user data is usually processed within social networks for market research and advertising purposes. For example, usage profiles can be created from the usage behavior and the resulting interests of the users. The usage profiles can in turn be used, for example, to place advertisements within and outside the networks that presumably correspond to the interests of the users. For this purpose, cookies are usually stored on the users' computers, in which the usage behavior and the interests of the users are stored. Furthermore, data can also be stored in the usage profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).
For a detailed presentation of the respective forms of processing and the possibilities of objection (opt-out), we refer to the data protection declarations and information provided by the operators of the respective networks.
Also in the case of requests for information and the assertion of data subject rights, we would like to point out that these can be asserted most effectively with the providers. Only the providers have access to the users' data and can take appropriate measures and provide information directly. If you still need help, you can contact us.
Processed Data Types:
Contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and contributions, as well as information concerning them, such as information on authorship or time of creation). Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
Data Subjects:
Users (e.g., website visitors, users of online services).
Purposes of Processing:
Communication; feedback (e.g., collecting feedback via online form). Public relations.
Storage and Erasure:
Erasure in accordance with the information in the 'General Information on Data Storage and Erasure' section.
Legal Bases:
Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further Information on Processing Activities, Procedures, and Services:
Instagram:
Social network, allows sharing of photos and videos, commenting and favoriting of contributions, sending messages, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: Data Privacy Framework (DPF).
Facebook Pages:
Profiles within the social network Facebook - The controller is jointly responsible with Meta Platforms Ireland Limited for the collection and transmission of data of visitors to our Facebook page ('fan page'). This includes in particular information about user behavior (e.g., viewed or interacted content, actions performed) and device information (e.g., IP addresses, operating system, browser type, language settings, cookie data). Further information can be found in the Facebook Data Policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us with statistical evaluations via the 'Page Insights' service, which provide information on how people interact with our page and its content. The basis for this is an agreement with Facebook ('Information on Page Insights': https://www.facebook.com/legal/terms/page_controller_addendum), in which, among other things, security measures and the fulfillment of data subject rights are regulated. Further information can be found here: https://www.facebook.com/legal/terms/information_about_page_insights_data. Users can therefore direct requests for information or erasure directly to Facebook. The rights of users (in particular to information, erasure, objection, and complaint to a supervisory authority) are not affected by this. The joint responsibility is limited exclusively to the collection of data by Meta Platforms Ireland Limited (EU). Meta Platforms Ireland Limited is solely responsible for further processing, including a possible transfer to Meta Platforms Inc. in the USA; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
LinkedIn:
Social network - We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitor data used to create 'Page Insights' (statistics) for our LinkedIn profiles. This data includes information about the types of content that users view or interact with, and the actions they take. Details about the devices used are also recorded, such as IP addresses, operating system, browser type, language settings, and cookie data, as well as information from user profiles, such as job function, country, industry, seniority, company size, and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy. We have concluded a special agreement with LinkedIn Ireland ('Page Insights Joint Controller Addendum', https://legal.linkedin.com/pages-joint-controller-addendum), which in particular regulates which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, direct requests for information or erasure directly to LinkedIn). The rights of users (in particular to information, erasure, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.linkedin.com/dpa). Possibility of objection (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Presence in Social Networks (Social Media)
Processed Data Types:
Contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and contributions, as well as information concerning them, such as information on authorship or time of creation). Usage data (e.g., page views and dwell time, click paths, usage intensity and frequency, device types and operating systems used, interactions with content and functions).
Data Subjects:
Users (e.g., website visitors, users of online services).
Purposes of Processing:
Communication; feedback (e.g., collecting feedback via online form). Public relations.
Storage and Erasure:
Erasure in accordance with the information in the 'General Information on Data Storage and Erasure' section.
Legal Bases:
Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR).
Further Information on Processing Activities, Procedures, and Services:
Instagram:
Social network, allows sharing of photos and videos, commenting and favoriting of contributions, sending messages, subscribing to profiles and pages; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.instagram.com; Privacy policy: https://privacycenter.instagram.com/policy/. Basis for third-country transfers: Data Privacy Framework (DPF).
Facebook Pages:
Profiles within the social network Facebook - The controller is jointly responsible with Meta Platforms Ireland Limited for the collection and transmission of data of visitors to our Facebook page ('fan page'). This includes in particular information about user behavior (e.g., viewed or interacted content, actions performed) and device information (e.g., IP addresses, operating system, browser type, language settings, cookie data). Further information can be found in the Facebook Data Policy: https://www.facebook.com/privacy/policy/. Facebook also uses this data to provide us with statistical evaluations via the 'Page Insights' service, which provide information on how people interact with our page and its content. The basis for this is an agreement with Facebook ('Information on Page Insights': https://www.facebook.com/legal/terms/page_controller_addendum), in which, among other things, security measures and the fulfillment of data subject rights are regulated. Further information can be found here: https://www.facebook.com/legal/terms/information_about_page_insights_data. Users can therefore direct requests for information or erasure directly to Facebook. The rights of users (in particular to information, erasure, objection, and complaint to a supervisory authority) are not affected by this. The joint responsibility is limited exclusively to the collection of data by Meta Platforms Ireland Limited (EU). Meta Platforms Ireland Limited is solely responsible for further processing, including a possible transfer to Meta Platforms Inc. in the USA; Service provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.facebook.com; Privacy policy: https://www.facebook.com/privacy/policy/. Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://www.facebook.com/legal/EU_data_transfer_addendum).
LinkedIn:
Social network - We are jointly responsible with LinkedIn Ireland Unlimited Company for the collection (but not the further processing) of visitor data used to create 'Page Insights' (statistics) for our LinkedIn profiles. This data includes information about the types of content that users view or interact with, and the actions they take. Details about the devices used are also recorded, such as IP addresses, operating system, browser type, language settings, and cookie data, as well as information from user profiles, such as job function, country, industry, seniority, company size, and employment status. Data protection information on the processing of user data by LinkedIn can be found in LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy. We have concluded a special agreement with LinkedIn Ireland ('Page Insights Joint Controller Addendum', https://legal.linkedin.com/pages-joint-controller-addendum), which in particular regulates which security measures LinkedIn must observe and in which LinkedIn has agreed to fulfill the rights of data subjects (i.e., users can, for example, direct requests for information or erasure directly to LinkedIn). The rights of users (in particular to information, erasure, objection, and complaint to the competent supervisory authority) are not restricted by the agreements with LinkedIn. The joint responsibility is limited to the collection and transmission of data to LinkedIn Ireland Unlimited Company, a company based in the EU. The further processing of the data is the sole responsibility of LinkedIn Ireland Unlimited Company, in particular with regard to the transfer of data to the parent company LinkedIn Corporation in the USA; Service provider: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland; Legal bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f) GDPR); Website: https://www.linkedin.com; Privacy policy: https://www.linkedin.com/legal/privacy-policy; Basis for third-country transfers: Data Privacy Framework (DPF), Standard Contractual Clauses (https://legal.linkedin.com/dpa). Possibility of objection (opt-out): https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.