Privacy policy for the company pages on Instagram and Facebook of justETF GmbH

Data protection is a top priority for justETF GmbH. We know that careful handling of your personal information is important to you. Therefore, your data will be treated confidentially by us in strict compliance with the applicable data protection regulations.
We use the option of corporate presences on the Facebook and Instagram platforms.
Below we explain what data we use on the Instagram site, at what time and for what purpose. Instagram is an online service for sharing photos and videos, Facebook is an online service of various content (texts, images, videos, among others). Both services belong to Meta Platforms.
Our concern is that you can understand how the services work and how we ensure the protection of your personal data, which is very important to us. We only use your personal data if we have your consent or legal permission.
We want to bring to your attention that there is massive criticism of the way Meta Platforms works and its privacy practices. One of the biggest privacy issues is that the NSA has access to Instagram and Facebook data through its programs like PRISM and XKEYSCORE, according to the prevailing opinion in the literature, and no deletion periods are provided for this data. Thus, profiles on each person are supposed to be permanently created at the NSA intelligence agency. In addition, Meta Platforms uses Instagram's personal data to combine it with Facebook and WhatsApp data and other data to enable profiling. At the same time, Facebook and Instagram are one of the most important social media tools and many business professionals depend on working with Facebook and Instagram (keyword for example "social proof").
We try to make this as privacy compliant as possible by being transparent about it.

Agenda

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 GmbH
Dachauer 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
This information transmitted by Meta Platforms to justETF GmbH is anonymized and cannot be associated by us with your person as a user of the Instagram page or Facebook page. However, this does not mean that the data collection and data processing at Meta Platforms itself is anonymized.
On our Instagram company page and our Facebook company page, we provide information and offer Instagram users and Facebook users the opportunity to communicate. If you perform an action on our Instagram company page and our Facebook company page (e.g., comments, posts, likes, etc.), you may make personal data (e.g., clear name or photo of your user profile) public. However, since we generally and to a large extent have no influence on the processing of your personal data by Meta Platforms, we cannot make any binding statements about the purpose and scope of the processing of your data by Instagram or Facebook.
Our Instagram company page and our Facebook company page are used for communication and information exchange with (potential) customers and business partners. In particular, we use the corporate presences for:
  • Products
  • Raffles
  • Employer Branding
In this context, publications about the company's presence may include the following content:
  • Information about products
  • Raffles
  • Advertising
Every user is free to publish personal data through activities. The data generated by the company website is not stored in our own systems.
You can object at any time to the processing of your personal data that we collect in the course of your use of our Instagram company page and our Facebook company page and/or exercise your data subject rights set out in XI. of this privacy policy.
In order to assert your data subject rights against Meta Platforms as set forth in XI. of this Privacy Policy, you must contact Meta Platforms directly.

XI. Rights of the data subject

If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights vis-à-vis the controller:
1. Right to obtain information
If your personal data is processed, you have the right to obtain information from the controller about the data stored about you (Art. 15 DSGVO).
2. Right to rectification
If incorrect personal data is processed, you have a right to rectification (Art. 16 DSGVO).
3. Right to deletion or restriction as well as objection
If the legal requirements are met, you may request the erasure or restriction of processing as well as object to processing (Art. 17, 18 and 21 DSGVO).
4. Right to being informed
If you have asserted the right to rectification, erasure or restriction of processing against the controller, the controller is obliged pursuant to Art. 19 DSGVO to notify all recipients to whom the personal data concerning you has been disclosed of this rectification or erasure of the data or restriction of processing, unless this proves impossible or involves a disproportionate effort.
5. Right to data portability
If you have consented to the data processing or if a contract for data processing exists and the data processing is carried out with the help of automated procedures, you may have a right to data portability (Art. 20 DSGVO).
6. Right of objection
In accordance with Art. 21 DSVO, you have the right to object at any time to the processing of personal data concerning you that is carried out on the basis of Art. 6 (1) sentence 1 lit. e or f DSGVO for reasons that arise from your particular situation; this also applies to profiling.
7. Right to revoke the declaration of consent under data protection law
If you have consented to processing by the controller by means of a corresponding declaration, you can revoke your consent at any time for the future. The legality of the data processing carried out on the basis of the consent until the revocation is not affected by this.
8. Automated decision in individual cases including profiling
You have the right pursuant to Article 22 of the GDPR not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
9. Right to complain to a supervisory authority
Furthermore, there is a right of appeal to a supervisory authority (Art. 77 DSGVO).
This privacy policy was created with the support of DataGuard.
Status: June 2022