https://www.instagram.com/bruehl_official/
We look forward to your visit to our website https://www.instagram.com/bruehl_official/ (hereinafter referred to as the “Instagram page”) and inform you in this Privacy Statement about how personal data is processed in connection with the visit or interactions with our Instagram page or its contents. Personal data is any information that relates to an identified or identifiable natural person (hereinafter referred to as the “Data Subject”).
A controller is the natural or legal person who alone or jointly with others decides on the purposes and means of the processing of personal data. If two or more controllers jointly determine the purposes and means of processing, they shall be joint controllers.
If you transmit personal data to us via our Instagram page and we decide solely about the purposes and means of processing,
Brühl & Sippold GmbH
Alter Bad Stebener Weg 1
95138 Bad Steben
info@bruehl.com
(hereinafter referred to as “we”, “us”, “site controller”) is the sole controller for the processing.
Insofar as personal data are processed in connection with our Instagram page and Meta Platforms Ireland Ltd decides solely on the purposes and means of processing,
Meta Platforms Ireland Limited
4 Grand Canal Square
Grand Canal Harbour
Dublin 2
Ireland
(“Meta Platforms Ireland”) is the sole controller for the processing.
Insofar as personal data of Meta Platforms Ireland and us are processed in connection with our Instagram page or with its contents and we make a contribution to the decision on the purposes and means of this processing, Meta Platforms Ireland and we are jointly responsible for the processing within the meaning of Art. 26 (2018) (1) of the General Data Protection Regulation (GDPR) and in accordance with the decision of the European Court of Justice of 5 June 1.
We assume that the scope of joint responsibility extends exclusively to the processing of so-called insights data. Insights data is personal data under the GDPR, which is collected and processed in connection with a visit to or an interaction of persons with a site and its contents, insofar as this is done
– under the influence and control of the site controller
– for the purpose of creating and evaluating site insights.
Page insights are statistics that Meta Platforms Ireland provides to the site manager.
We and Meta Platforms Ireland have stated in the information on page insights data (hereinafter referred to as the “agreement regarding the controller”) in accordance with Art. 26 (1) sentence 2 GDPR that Meta Platforms Ireland assumes the primary responsibility for the fulfillment of all obligations and in particular for the exercise of the rights of the data subject in accordance with the GDPR with regard to the processing of insights data. The Controller Agreement complements the Pages, Groups and Events Guidelines and the Terms of Use that we have agreed to in the context of operating our Instagram Page. We agree to the agreement regarding the person responsible by operating our Instagram page.
External Data Protection Officer of IST
FRT Consult GmbH
RA/StB Thomas Hesz
Kurt-Schumacher-Str. 23, 95326 Kulmbach
Phone: 09221 / 900 – 0, Fax: 09221 / 900 – 111
E-mail: edsb@frtconsult.de
You can contact the Instagram Data Protection Officer via the online contact form provided on the Facebook platform.
1. Information about Meta’s data processing
The Instagram Privacy Policy identifies the categories of personal data processed when using Meta products (see I.), describes in general terms the purposes for which this data is used (see II.), and identifies the categories of recipients to whom this data may be made available (see III., IV.). The link to the Data Policy also provides information on the legal basis for the processing of this data (see V.) and information on how you can revoke your consent with regard to the processing of personal data. See the Data Policy for information on how you can exercise your rights of access, rectification, portability and deletion against Meta (see VI.). This section also contains information on your right to object to certain processing of personal data. The Data Policy also includes information about the duration for which personal data is stored and information about the criteria for setting that duration and the possibility of blocking or deleting Instagram accounts (see VII.). The Data Directive refers to Meta’s intention to transmit personal data to third countries where appropriate (see IX.). According to Meta, the transmission is based on the adequacy decisions adopted by the European Commission within the meaning of Art. 45 (1) GDPR or approved standard contractual clauses within the meaning of Art. 46 (2) (c) GDPR.
2. Information on the use of cookies by Meta
When you visit our Instagram page and your browser allows cookies to be stored, Meta stores information in the form of small text files in the memory of your browser (“cookies”) and can access this information when you visit the Instagram platform or a website that incorporates Instagram technologies. For more information on the purpose of the cookies used, on the integration of these cookies by other websites and on your control options in this regard, please refer to the information on Instagram cookies.
We would like to point out to you that Meta is able to use the cookies used to track your user behavior (across devices for registered users) on other websites beyond the Instagram platform. This applies to people registered on the Instagram platform as well as to people not registered there.
We would also like to point out to you that we have no influence on the data processing carried out by Meta in connection with cookies. You can also visit our Instagram page if you configure your browser so that no cookies are stored by the Instagram platform. Information about how to adjust the settings for cookies in your browser is usually found in the help area of the browser you are using.
If you are registered or logged in to the Instagram platform and would like to avoid Meta being able to connect your visit to our Instagram page to your Instagram or to connect it, you should log out of Instagram or deactivate the “stay logged in” function, delete the cookies on your device and stop and restart your browser.
3. Data processing for interactions on our Instagram page
Our Instagram page gives you the opportunity to respond to our posts, comment on them and send us private messages. Please check carefully which personal data you share with us via our Instagram page. If you would like to avoid Meta processing personal data that you transmit to us, please contact us by other means.
A) Scope of data processing
In addition to the content you transmit, we can see information about your profile, your likes and your contributions, depending on your privacy settings. To change your privacy settings, see this help article.
B) Legal basis of data processing
The processing of your data in the event of contact or interaction with our site or its contents takes place by us on the basis of Art. 6 (1) sentence 1 lit. F GDPR. If your contact is aimed at the conclusion of a contract, then the additional legal basis for the processing is Art. 6 (1) sentence 1 lit. B GDPR.
C) Purpose of data processing
We process the data provided by you and which may be accessible to us in the interest of communicating with you. We want to provide you with a platform where we can provide you with insights into our company and our activities, and with the help of which you can contact us quickly.
This also includes our legitimate interests in data processing in accordance with Art. 6 (1) sentence 1 lit. F GDPR.
D) Duration of data storage
Your data will be deleted, as far as we are able, when the operation of our Instagram page stops. If Meta stores this information further, it will only be governed by the provisions of the Instagram Privacy Policy and Instagram Terms of Use.
For our Instagram page, we use Page Insights provided by Meta Platforms Ireland that provide insights into the visitors to our Instagram page and their interactions with our Instagram page and its content.
A. Contribution to the decision on means and purposes of processing
We have no influence on the creation of page insights and cannot prevent their generation when operating our Instagram page. In particular, we do not parameterize or otherwise instruct Meta Platforms Ireland to process personal data for the creation of site insights in a specific way. The Controller Agreement states that only Meta Platforms Ireland can make and implement decisions regarding the processing of Insights data. Our contribution to the decision on the means and purposes of processing Insights data is therefore limited to the objectives of controlling or promoting our activities in connection with the operation of our Instagram page, for which we can evaluate the page insights provided to us by Meta Platforms Ireland and based on Insights data.
B. Scope of data processing
Meta Platforms Ireland explains in the information on page insights data which data are used for the creation of the page insights used by us. In principle, this data is only made available to us in anonymized form. However, if you have set your Page Likes to Public, we may associate this with your profile. Based on the aforementioned insights data, Meta Platforms Ireland provides us with page insights. The exact content of the page insights and the views available can be found in the explanations for the page insights. According to Meta Platforms Ireland, changing the views listed there does not lead to additional data processing. We will only use the Site Insights as part of the features provided by Meta Platforms Ireland and available to us above. No transfer or other further processing of this data takes place.
Meta Platforms Ireland has told us that Page Insights do not show information about people who are not registered or registered with the Instagram platform.
For specific information about Instagram, see the Instagram Insights notes
C. Legal basis of data processing
We assume that the processing of Insights data by Meta Platforms Ireland for the provision of the page insights we use is carried out in the context of the fulfillment of contractual services in connection with the contract concluded between Meta Platforms Ireland and the data subject concerning the terms of use of the Instagram platform pursuant to Art. 6 (1) (b) GDPR. In the case of persons with limited legal capacity, we assume that Meta Platforms Ireland may carry out the processing in order to safeguard a legitimate interest in accordance with Art. 6 (1) (f) GDPR. An overview of the interests cited by Meta Platforms Ireland in this context and further information on their legal bases can be found here.
We process the page insights provided to us in order to safeguard our legitimate interests in improving our information offer in accordance with Art. 6 (1) (f) GDPR, which are predominant in the context of a balancing of interests. We will only process data from individuals who have agreed to Instagram’s data policy and terms of use when you register with the Instagram platform. Meta Platforms Ireland’s Data Policy refers to the intent of this processing under the heading “Partners using our analytics services”.
D. Purpose of data processing
The purpose of processing the aforementioned insights data is to create page insights. These site insights may be evaluated by us to understand how visitors interact with our Instagram page and thus serve to improve the information available to visitors to our Instagram page. The site insights are used by us to understand trends. We do not use Page Insights to draw conclusions about individuals. Identification is only possible if we can assign individual profile pictures “Like” information for the page; however, this only if our fan page has been marked “Like” by the respective visitor and the “Like” information is set to “Public”.
For these purposes, we also have a legitimate interest in data processing in accordance with Art. 6 (1) (f) GDPR.
E. Duration of data storage
The site insights used by us include Insights data for a period of two years and will not be further processed by us thereafter. If Meta Platforms Ireland stores this information further, it will only be governed by the provisions of the Instagram Data Policy and Terms of Use.
The GDPR grants data subjects extensive rights that they can assert against the controller. These rights include:
– Right to information pursuant to Art. 15 GDPR
– Right to correction pursuant to Art. 16 GDPR
– Right to erasure pursuant to Art. 17 GDPR
– Right to restriction of processing pursuant to Art. 18 GDPR
– Right to information pursuant to Art. 19 GDPR
– Right to data portability pursuant to Art. 20 GDPR
– Right to objection pursuant to Art. 21 GDPR
– Right to revocation of granted consent pursuant to Art. 7 (3) GDPR
– Right to lodge a complaint with a supervisory authority pursuant to Art. 77 GDPR
If your aforementioned rights relate to processing operations that are the subject of our responsibility, you can assert them against us. For the assertion of rights with regard to further processing, please contact Meta Platforms Ireland.
If we process your personal data in the context of a balancing of interests on the basis of our overriding legitimate interest, you have the right at any time to object to this processing for reasons arising from your particular situation with effect for the future.
If we process your personal data in the context of a balancing of interests on the basis of our overriding legitimate interest, you have the right at any time to object to this processing for reasons arising from your particular situation with effect for the future.
If you exercise your right to object, we will terminate the processing of the data concerned. However, we reserve the right to further processing if we can demonstrate compelling legitimate grounds for processing that outweigh your interests, fundamental rights and freedoms or if the processing serves the assertion, exercise or defense of legal claims.
If your personal data are processed by us for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing purposes. You can exercise the objection as described above.
If you exercise your right to object, we will terminate the processing of the data concerned for direct advertising purposes.
Status: July 2023