Data protection information Social Media Channels

1. Controller

We, HÄRTING Rechtsanwälte PartmbB, maintain social media pages on the platforms of Facebook, Instagram, LinkedIn, X and YouTube. As operators of these pages, we are jointly responsible with the respective network operators

• Facebook: Meta Platforms Ireland Ltd Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, hereinafter: Facebook,
• Instagram: Meta Platforms Ireland Ltd, 4 Grand Canal Square, Dublin 2, Ireland, hereinafter: Instagram
• LinkedIn: LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland, hereinafter: LinkedIn
• YouTube: Google LLc, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA, hereinafter referred to as YouTube
• X (formerly Twitter): Twitter International Unlimited Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland, hereinafter referred to as X

Controller within the meaning of Art. 4 No. 7 General Data Protection Regulation (GDPR).

As joint controllers of these pages, we have entered into agreements with the network operators that regulate, among other things, the conditions for the use of pages and similar appearances. The following agreements apply in each case

Facebook: Meta’s terms of use, the other terms and policies listed at the end there, and the joint responsibility agreement,

Instagram: Instagram’s Terms of Use and, because Instagram is a Meta offering, also the Meta policies and agreements described above.

LinkedIn: Data processing agreement from LinkedIn.

YouTube: Google’s privacy policy and terms of use

X: The general terms and conditions of X and the guidelines referenced therein

When visiting our social media pages, personal data of page visitors is processed by the controller as follows.

2. Use of insights, analyses and cookies etc.

In connection with the operation of our social media pages, we use the analysis functions provided there to obtain statistical analyses of the users of our social media channels.

For this purpose, cookies and similar technologies such as pixels are used by the network operators when you visit our pages, and a unique user code is created in each case. This user code can be linked to the data of users who are registered with the platform operators.

The information stored for the user code is processed by the platform operators, in particular when the user visits these services. Other entities, such as partners or even third parties, may also use cookies within these services in order to provide services to the companies advertising on the platforms.

Facebook: In connection with the operation of our Facebook page, we use Meta’s Page Insights function to obtain statistical analyses of the users of our Facebook page. Meta provides information on Page Insights and Facebook pages in its privacy policy and here.

You can also find more information on the use of cookies by Meta (also in the context of the use of Instagram) in their cookie policy.

Instagram: In connection with the operation of our Instagram profile, we use the Instagram Insights function to obtain statistical analyses of the users of our posts. Information on Instagram Insights can be found in Instagram’s privacy policy.

LinkedIn: In connection with the operation of our LinkedIn profile, we use LinkedIn Page Analytics. This provides us with information about the use of our content. You can find more information on data protection on the LinkedIn platform in LinkedIn’s privacy policy.

YouTube: In connection with the operation of our YouTube account, we use the YouTube analysis functions. We can use the analysis function to analyse and statistically evaluate usage. You can find more information in Google’s privacy policy.

X: In connection with the operation of our X account, we use Twitter’s analysis options to statistically analyse our channel and the reactions to our posts.  You can find more information on this in the X privacy policy.

3. Purposes of the processing

On the one hand, the processing of this information is intended to enable the network operators, among other things, to improve their system of advertising, which they distribute via their networks. On the other hand, it should enable us as the operator of the social media pages to obtain statistics that are generated based on visits to our social media pages. The purpose of this is to manage the marketing of our activities. For example, it allows us to learn about trends in the profiles of visitors who like our social media pages or use applications on the pages in order to provide them with more relevant content and develop features that may be of greater interest to them.

To help us better understand how we can use our social media pages to further our business objectives, demographic and geographic analyses are also created using the information collected and made available to us. We can use this information, for example, to place targeted interest-based adverts. However, we do not obtain any direct knowledge of the visitor’s identity. If visitors use social media services on multiple devices, the data can also be collected and analysed across devices and platforms if the visitors are registered and logged into their own profile.

The visitor statistics compiled are only transmitted to us in anonymised form and we do not have access to the underlying data.

We also use our social media pages to communicate with our customers, interested parties and users and to inform them about our range of services. In this context, we may receive further information, e.g. due to user comments, private messages or because you follow us or share our content. The processing takes place exclusively for the purpose of communication and interaction with you.

You may respond to a specific job advertisement via social media or send us your unsolicited application via social media. We will then process your personal data as part of our application procedure and refer you to our data protection information for application procedures.

4. Legal basis and legitimate interests

We operate our social media pages to present ourselves to and communicate with the users of these platforms and other interested persons who visit our social media pages. The processing of users’ personal data is based on our legitimate interests in an optimised company and product presentation (Art. 6 para. 1 sentence 1 lit. f GDPR). In the case of an (unsolicited) application, we refer to our data protection information for application procedures.

5. Transfer of data

Facebook, Instagram, YouTube, X and LinkedIn may also process some of the information collected outside the European Union in the USA.

Insofar as a decision of the European Commission on the existence of an adequate level of protection (see Art. 45 para. 3 GDPR) exists in relation to the third country, no additional measures are required for the data transfer. If data is transferred to recipients based in the USA, this is done on the basis of the Transatlantic Data Privacy Framework (DPF) of 10 July 2023, provided the recipient has appropriate certification. A list of currently certified companies is available here. In other cases and in the case of data transfers to other so-called non-secure third countries, data will only be transferred if the requirements of Art. 46 et seq. GDPR are met.

The social media platforms used here have their headquarters in the USA and are certified accordingly. An adequate level of protection comparable to the GDPR can therefore be assumed.

6. Nature of joint responsibility / assertion of data subject rights

With the agreement that we have with Meta for our Facebook and Instagram presences, the operators recognise the joint data protection responsibility with regard to so-called Insights data and assume essential data protection obligations to inform data subjects, to ensure data security and to report data protection violations. The agreement with Facebook also stipulates that Facebook is the primary point of contact for exercising the rights of data subjects (Art. 15 – 22 GDPR). As the provider of the social network, Facebook alone has direct access to the necessary information and can also immediately take any necessary measures and provide information. Should our support nevertheless be required, we can be contacted at any time.

The agreement we have concluded with LinkedIn stipulates that LinkedIn will inform us as soon as a data subject exercises their data subject rights (Art. 15 – 22 GDPR). LinkedIn will provide support in responding to requests for information. You can assert your data subject rights against us and LinkedIn.

The agreement we have concluded with Google regarding our YouTube channel also provides that you can assert your data subject rights against us and Google.

7. Right to Object

In particular, you have the following options to object:

Facebook and Instagram: Facebook and Instagram users can influence the extent to which their user behaviour may be recorded when visiting our Facebook page or Instagram profile under the settings for advertising preferences. The Facebook settings or the form provided via Facebook for the right to object offer further options for objecting. The form can also be used to make settings for Instagram.

LinkedIn: You can object to LinkedIn processing here. Further settings can be made via the objection form.

YouTube: The processing of YouTube can be objected to via the setting in the Google account. You can find more information on how to make adjustments to the data protection settings here.

X: You can partially object to the processing of X via the settings in your X account. You can find more information here.

8. Further information

Further information on our contact details, the rights of data subjects vis-à-vis us and how we otherwise process personal data can be found in the data protection information on our website.

Further information on the handling of personal data can be found in the privacy policies of Facebook, Instagram, YouTube, LinkedIn and the privacy policy of X.

This data protection information was last updated in March 2024.