Privacy policy for the company pages on Instagram and Facebook of justETF GmbH
- On Facebook you can find our corporate presence at https://www.facebook.com/justETF
- On Instagram you can find our corporate presence at https://www.instagram.com/justETF.de
Agenda
- I Principles of joint processing and contact details of the controllers
- II Contact details of the data protection officer
- III General information about data processing on Instagram
- IV Purposes and legal bases
- V Data categories
- VI Data recipient
- VII Data transfers
- VIII Storage duration
- IX Automated decisions
- X Business Profil
- XI Rights of the data subject
I Principles of joint processing and contact details of the controllers
1. Joint controllers for the processing of personal data
The purposes and means of processing personal data when visiting our Instagram page are jointly determined by justETF GmbH, Bahnhofstr. 26, 72138 Kirchentellinsfurt, Germany ("justETF GmbH") and Meta Platforms Ireland Ltd ("Meta Platforms") within the meaning of Art. 26 of the EU General Data Protection Regulation (GDPR). This results from the fact that justETF GmbH, as the operator of the Instagram page and the Facebook page, enables Meta Platforms, as the operator of the Facebook Instagram services, to process personal data by setting up such an account. Meta Platforms assumes primary responsibility under the GDPR for the processing of Insights Data as part of its shared responsibility and complies with all obligations under the GDPR with respect to the processing of Insights Data (including, without limitation, Articles 12 and 13 of the GDPR, Articles 15 to 22 of the GDPR, and Articles 32 to 34 of the GDPR). In addition, Meta Platforms provides the essence of this Page Insights Addendum to Data Subjects (governed by the relevant "Page Insights Controller Addendum"). Below you will find a description of the handling of personal data by justETF GmbH and Meta Platforms when visiting the Instagram account and the Facebook account. However, since justETF GmbH generally or to a large extent has no influence on the data collected by Meta Platforms and its processing by Meta Platforms, we are currently unable to provide clear information on the purpose and scope of the processing of your data by Meta Platforms. However, we will monitor further developments in this regard and, if necessary, adapt this privacy policy accordingly. We would like to point out that you use the Instagram account and the Facebook account and their functions on your own responsibility. This applies in particular to the use of the interactive functions (such as commenting, sharing, rating).2. Name and address of the jointly responsible persons
a) The primary responsible party is: Meta Platforms Ireland Ltd.4 Grand Canal Square
Grand Canal Harbour
Dublin 2, Ireland b) Further responsible person is: justETF GmbH
Bahnhofstr. 26
72138 Kirchentellinsfurt Deutschland Telephone: +49 7121 766 22 50
Fax: +49 7121 766 22 59
Email: info(at)justetf.com
II. Contact details of the data protection officer
You can reach the data protection officer of the other data controller justETF GmbH under 2.b) at: DataCo GmbHDachauer Straße 65
80335 München Deutschland
Telephone: +49 89 7400 45840
www.dataguard.de You can contact the Data Protection Officer of Meta Platforms Ireland via the online contact form provided on the Facebook platform.
III. General information on data processing at Instagram
1. Data processing by Meta Platforms
The Instagram Privacy Policy identifies the categories of personal data that are processed when using Meta Platforms products such as Instagram and Facebook. The policy describes in general terms the purposes for which this data is used. This policy identifies the categories of recipients to whom this data is sent. You will also find information about the legal basis for the processing of this data, as well as information about how you can withdraw your consent to the processing of personal data. In the policy, you will find information on how to exercise your rights of access, rectification, portability, and erasure against Facebook Ireland. For more information about your control options, see Instagram's settings options or their help pages.2. Cookies from Meta Platforms
When you visit our Instagram page and/or Facebook page and your browser allows cookies to be stored, Meta Platforms stores information in the form of small text files in your browser's memory (hereinafter referred to as "cookies") and can access this information when you visit the Instagram or Facebook platform. For more information about the purpose of the cookies used, the integration of these cookies by other websites and your control options in this regard, please refer to Meta Platforms' information on Meta Cookies. We would like to point out that Meta Platforms is able to track your user behavior with the help of the cookies used. This applies both to those who are registered on the Instagram Platform or Facebook Platform and to those who are not registered there. We would also like to point out that we have no control over Meta Platforms' data processing in connection with cookies. It is also possible, if you configure your browser accordingly, to visit our Instagram page or Facebook page without cookies being stored by Meta Platforms. Information on how to adjust the settings for cookies in your browser can usually be found in the help section of the browser you are using. If you are registered or logged in to the Instagram or Facebook platform and want to prevent Facebook from linking your visit to our Instagram page or Facebook page to your Instagram or Facebook user account, you should log out of Instagram and Facebook, delete the cookies on your device, close your browser and then restart it.3. Data processing during interactions on our Instagram page or Facebook page.
On our Instagram company page and Facebook company page, you have the opportunity to react to our posts, comment on them and send us messages. Please review what personal information you share with us through our Instagram company page or Facebook company page. If you would like to prevent Meta Platforms from processing the personal data you submit to us, please contact us using the contact information provided above. In addition to the content you submit, information about your profile and posts will be visible to us, depending on your privacy settings. You can change this yourself using the settings on Instagram and Facebook. As far as we can, your data processed by us will be deleted when our Instagram company page and Facebook company page is closed. If Meta Platforms continues to store this data, it will be based solely on the terms of the Meta Platforms Privacy Policy and the Instagram and Facebook Terms of Use.IV. Purposes and legal bases
Your personal data is collected for the purpose of exchanging information with customers and business partners of justETF GmbH, marketing the products and thereby developing better products for our customers. The processing of your data when contacting or interacting with our Instagram account or Facebook account or its content is carried out by us on the basis of Art. 6 para. 1 p. 1 lit. f DSGVO. Our legitimate interest is to respond to your inquiry or to interact with our customers in the context of social media marketing. If your contact is aimed at the conclusion of a contract, the additional legal basis for processing is Art. 6 para. 1 p. 1 lit. b DSGVO. We process the data you provide in this context to protect our legitimate interests of customer communication. This also includes our legitimate interests in data processing pursuant to Art. 6 para. 1 p. 1 lit. f DSGVO.V. Categories of data
The information that Meta Platforms processes:- Device attributes: Information such as the operating system, hardware and software versions, battery level, signal strength, available memory, browser type, app and file names and types, and plugins.
- Operations on the device: Information about operations and activities performed on the device, such as whether a window is in the foreground or background, or mouse movements.
- Identifiers: Unique identifiers, device IDs and other identifiers, such as those of games, apps or accounts being used, and family device IDs.
- Device signals: Bluetooth signals and information about WLAN access points, beacons and wireless cell towers in the vicinity.
- Data from the device settings: Information from the device settings, such as access to GPS location, camera or photos.
- Network and connections: Information such as the name of the mobile or Internet provider, language, time zone, cell phone number, IP address or connection speed, and in some cases information about other nearby devices.
- Cookie data: Data from cookies stored on the device, including cookie IDs and settings.
VI. Recipients of data
The majority of personal data, such as photo, name or username are publicly displayed by Instagram and Facebook. Only direct Instagram messages and direct Facebook messages to justETF GmbH are data that are not public in the context of this privacy policy. Your personal data will be passed on by justETF GmbH to internal employees of the marketing and sales department, as well as to contract processors, such as a marketing agency, if applicable. The disclosure of data to third parties or to authorities, such as the NSA, by Meta Platforms is to be assumed and is described in their privacy policy and technical literature.VII. Data transfers
The Meta Platforms Privacy Policy explains Meta Platforms' data transfers to third countries, as well as their legal basis. On the part of justETF GmbH, it is not planned to transfer data to third countries.VIII. Storage duration
In the Meta Platforms Privacy Policy you will also find information on the duration of the storage of personal data, as well as information on the criteria for determining this duration and the possibility of blocking or deleting Instagram accounts and Facebook accounts.IX. Automated decisions
Instagram and Facebook use automated decisions to display content to users. Instagram and Facebook recommend content that Instagram and Facebook believe users will like. The decision logic behind this is not known to justETF GmbH]. The scope of the use of Instagram, Facebook and other similar social media and their effects are large and can be used in mass surveillance systems and for deepfakes and other facial recognition systems.X. Business Profil
The Instagram page and the Facebook page of justETF GmbH are business profiles and therefore have the function of Instagram Insights and Facebook Audience Insights. This means that part of the data collected by Meta Platforms during use is made available to us as a statistical evaluation in anonymized form. This statistical evaluation only relates to users, content and activities on our Instagram company presence and our Facebook company presence. Specifically, the evaluation includes the following data:- Number of "likes" of our photos and videos
- Number of comments on our photos and videos
- Number of people who have seen a photo or video
- Number of times a photo or video was shared
- Number of times a photo or video was reported as spam
- Number of times clicked that the user no longer likes the page
- Products
- Raffles
- Employer Branding
- Information about products
- Raffles
- Advertising