1. Person responsible
As the operator of Lohnsteuer kompakt, we, forium GmbH, maintain social media pages on the networks of Facebook, Instagram, Twitter, YouTube, and LinkedIn. As the operators of these pages, we are jointly responsible with the respective network operators:
- Facebook: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, hereinafter: Facebook,
- Instagram: Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland, hereinafter: Instagram
- YouTube: Google Ireland Limited Gordon House, Barrow Street Dublin 4. Ireland, hereinafter YouTube
- Twitter: Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland, hereinafter: Twitter
- LinkedIn: LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland, hereinafter: LinkedIn
Responsible parties within the meaning of Art. 4 No. 7 General Data Protection Regulation (GDPR).
As joint controllers of these pages, we have agreements with the network operators that, among other things, regulate the conditions for the use of pages and similar presences. The relevant agreements are as follows:
Facebook: Facebook Terms of Use, the other terms and policies listed there, and the Joint Controller Addendum,
Instagram: The Instagram Terms of Use, the Instagram Data Policy, and, as Instagram is a Facebook offering, the Facebook policies and agreements described above.
YouTube: Privacy Policy and Terms of Use of Google
Twitter: The general Terms and Conditions of Twitter and the policies referred to therein
LinkedIn: Data Processing Agreement of LinkedIn.
When visiting our social media pages, personal data of the page visitors is processed by the controllers as follows.
1. Person responsible
2. Use of insights, analysis and cookies
In connection with the operation of our social media pages, we use the provided analysis functions to obtain anonymised statistical data about the users of our social media pages.
For this purpose, cookies and similar technologies such as pixels are used by the network operators on the user's device when they visit our website, and a unique user code is created. This user code can be linked to the data of users registered on the respective platform.
The information stored in the user code is processed by the respective platform operator, especially when the user visits these services. In addition, other parties such as partners of the respective platform or even third parties may use cookies within these services to provide services to companies advertising on the respective platform.
Facebook: In connection with the operation of our Facebook page, we use Facebook Insights to obtain statistical evaluations of the users of our Facebook page. Facebook provides information about Insights and Facebook pages in its privacy notices and here. Further information on the use of cookies by Facebook (also when using Instagram) can also be found in their Cookie Policy.
Instagram: In connection with the operation of our Instagram profile, we use Instagram Insights to obtain statistical evaluations of the users of our posts. Information about Instagram Insights can be found in Instagram's privacy notices and here.
YouTube: In connection with the operation of our YouTube account, we use YouTube's analysis functions. The analysis function allows us to analyse and statistically evaluate usage. More information can be found in Google's privacy notices.
Twitter: In connection with the operation of our Twitter account, we use Twitter's analysis options to statistically evaluate our channel and the reactions to our posts. More information can be found in their privacy notices.
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. Further information on the data protection of the LinkedIn platform can be found in LinkedIn's privacy policy.
2. Use of insights, analysis and cookies
3. Purposes of processing
The processing of information is intended, among other things, to enable network operators to improve the advertising distributed via the respective network. It should enable us, as operators of the social media pages, to receive statistics generated based on visits to our social media pages. This aims to manage the marketing of our activities. For example, this allows us to gain insight into the profiles of visitors who use our social media pages or applications, so we can provide them with more relevant content and develop features that may be of greater interest to them.
To better understand how we can achieve our goals with our social media page, demographic and geographic analyses are also created and made available to us based on the collected information. We can use this information, for example, to place targeted interest-based advertisements. However, we do not receive any direct knowledge of the visitor's identity. If visitors use social media services on multiple devices, data collection and evaluation can also take place across devices and platforms if they are registered visitors logged into their own profiles.
The visitor statistics created are transmitted to us exclusively in anonymised form. We do not have access to the underlying data.
Furthermore, we use our social media pages to communicate with our customers, interested parties, and users and to inform them about our services. In this context, we may receive further information, e.g. from user comments, private messages, or because you follow us or share our content. The processing is carried out solely for the purpose of communication and interaction with you.
3. Purposes of processing
4. Legal basis and legitimate interests
We operate our social media pages to present ourselves to users of the respective platform and other interested parties who visit our social media pages, and to communicate with them. The processing of users' personal data is based on our legitimate interests in optimised corporate and product presentation (Art. 6 para. 1 lit. f GDPR).
4. Legal basis and legitimate interests
5. Data sharing
There is a possibility that some of the information collected on Facebook, Instagram, YouTube, Twitter, and LinkedIn may also be processed outside the European Union in the USA.
The USA is considered an unsafe third country. A third country is deemed unsafe if the EU Commission has not issued an adequacy decision for that country under Art. 45 (1) GDPR, confirming that the country provides an adequate level of protection for personal data.
With the ECJ ruling of 16 July 2020 (C-311/18), the (partial) adequacy decision for the USA, the so-called Privacy Shield, was declared invalid. The USA does not offer a level of data protection comparable to that in the EU. When personal data is transferred to the USA, the following risks exist. There is a risk that US authorities may access personal data based on surveillance programmes PRISM and UPSTREAM under Section 702 of the FISA (Foreign Intelligence Surveillance Act), as well as on the basis of Executive Order 12333 or Presidential Policy Directive 28. EU citizens have no effective legal remedies against such access in the USA or the EU.
Facebook and Instagram: Facebook Ireland Ltd. transfers data based on standard contractual clauses approved by the European Commission to Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, US (hereinafter: Facebook Inc.), based in the USA. We have no influence on these processes. We do not pass on any personal data that we receive via our Facebook page.
YouTube: YouTube transfers data based on standard contractual clauses approved by the European Commission to Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA (hereinafter: Google). We have no influence on these processes. We do not pass on any personal data that we receive via our YouTube channel.
Twitter: Twitter transfers data based on standard contractual clauses approved by the European Commission to Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. We have no influence on this processing. We do not pass on any personal data that we receive via our Twitter presence.
LinkedIn: LinkedIn transfers data based on standard contractual clauses approved by the European Commission to LinkedIn Corporation, 1000 W Maude Ave Sunnyvale, CA, US (hereinafter: LinkedIn Corporation). We have no influence on these processes. We do not pass on any personal data that we receive via our LinkedIn profile.
We do not pass on any personal data.
5. Data sharing
6. Nature of joint responsibility / Assertion of data subject rights
Facebook and Instagram: Under the agreement we have with Facebook and Instagram for our Facebook and Instagram pages, the operators acknowledge joint data protection responsibility regarding so-called Insights data and assume essential data protection obligations for informing data subjects, ensuring data security, and reporting data protection breaches. The agreement with Facebook also stipulates that Facebook is the primary contact for exercising data subject rights (Art. 15 – 22 GDPR). As the provider of the social network, Facebook alone has direct access to the necessary information and can also take any required measures and provide information directly. If our support is needed, we can be contacted at any time.
YouTube: The agreement we have with Google regarding our YouTube channel allows you to exercise your data subject rights with both us and Google.
LinkedIn: The agreement we have 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 assist in responding to information requests. You can exercise your data subject rights with both us and LinkedIn.
6. Nature of joint responsibility / Assertion of data subject rights
7. Objection options
You have the following options to object:
Facebook and Instagram: Users of Facebook and Instagram can influence the extent to which their user behaviour is recorded when visiting our Facebook page or Instagram profile under the advertising preferences settings. Further options for objection are offered by the Facebook settings or the objection form provided by Facebook. Settings for Instagram can also be made via the form.
YouTube: You can object to the processing by YouTube via the settings in your Google account. More information on how to make adjustments to the privacy settings can be found here.
Twitter: You can partially object to the processing by Twitter via the settings in your Twitter account. More information can be found here.
LinkedIn: You can object to the processing by LinkedIn here. Further settings can be made via the objection form.
7. Objection options
8. Further Information
Further information on our contact details, the rights of individuals affected by us, and how personal data is otherwise processed by us can be found in the Lohnsteuer kompakt privacy policy.
Information on how personal data is handled can be found in the privacy policies of Facebook, Instagram, YouTube, Twitter, and LinkedIn.
8. Further Information