1. General terms and scope
The Fan Page is made available to the Operator by Facebook Ireland Ltd. (hereinafter ‘Facebook’) and the Operator administers it with a relevant user account. The Fan Page constitutes an opportunity for the Operator to reach Facebook and Instagram users and engage with them.
Insights Data shall be collected when you visit the Fan Page. This is anonymised data that enables us, the Operator, to view usage statistics of our Fan Page.
Personal data shall also be processed in connection with the collected Insights Data. The Operator and Facebook shall jointly process this data pursuant to Art. 26 of the GDPR. The essential content of the agreement entered into between Facebook and the Operator is explained below.
2. Controller and data protection officer
The Operator and Facebook shall be jointly responsible for the processing of your personal data with regard to your use of the Fan Page.
The contact details of the Operator can be found in the legal notice.
The contact details of Facebook are: Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. Facebook is represented by directors Gareth Lambe and Shane Crehan.
The data protection officer of the Operator can be reached at:
MORGENSTERN consecom GmbH
Grosse Himmelsgasse 1
Telephone: +49 (0)6232 100119 44
Facebook has appointed a data protection officer who can be contacted at the following URL: https://www.facebook.com/help/contact/540977946302970.
3 Degree of responsibility
Facebook shall assume primary responsibility for the processing of Insights Data on the Fan Page in view of the fact that there is a legal basis for its processing.
4 Opportunity to object
If you wish to object to the processing of your data by the Operator, on the Fan Page as a whole or for specific instances, you can do so by sending a personal message from the Fan Page. You can also object directly to the processing of Insights Data by Facebook. You can also object to the processing of data by Facebook by contacting the Operator. Your objection will be forwarded to Facebook without delay.
Please note that, in the event of such an objection, use of the Fan Page and the services and information accessed through it may be restricted or not at all possible.
5 Details about data processing
5.1 Page Insights
When the Fan Page is visited and used, the Page Insights feature shall make Insights Data (statistics about access to the Fan Page) available to the Operator, who shall process this data. The Operator shall not be able to personally identify you or associate you with your account. This feature is a non-negotiable component of the user agreement the Operator has entered into with Facebook. This means that the Operator cannot unilaterally decide whether Page Insights shall be collected or not.
Please note that the Page Insights feature can also collect personal data of people who do not have a Facebook or Instagram profile.
You can also restrict cookies or disable them altogether in your browser settings. In addition, you can also set your browser to automatically delete all cookies when the browser window is closed.
If you use the Facebook or Instagram app, you can change the settings for the storage of cookies by apps in your mobile device’s settings.
Information on the legal basis and purpose of Facebook’s processing, as well as the relevant storage periods is available at:
Insofar as your personal data shall be processed by the Operator when you visit the Fan Page, the lawfulness of this processing shall be in compliance with Art. 6 (1) lit. f of the GDPR (legitimate interest). The aim of the Operator is to evaluate the anonymised Insights Data in order to track user behaviour on the Fan Page and optimise its content.
The Operator requires many views of the Fan Page in order to market its services in the best possible manner. This is where Insights Data comes in.
The Insights Data collected through the Fan Page shall be anonymised before being made available to the Operator. This means that the collected personal data shall be modified in such a manner that association with a natural person is no longer possible or only possible with a disproportionate amount of time, cost and effort.
If you are a registered Facebook and/or Instagram user, the provision of Insights Data is stipulated in the agreement, otherwise you would not have been able to set up an account. In the case of non-registered users, the processing of Insights Data is voluntary. However, if you object to the processing of personal data or deactivate specific settings, you shall not be able to access the Fan Page.
5.2 Communicating using features of the Fan Page
You can use direct messages, the like button or comments on the Fan Page to engage with the Operator. The name stored as the username of your account shall be displayed for this purpose.
The lawfulness of this processing shall be in compliance with Art. 6 (1) lit. f of the GDPR (legitimate interest). In order to answer questions, respond to criticism, build a relationship and exchange information, it is important for the Operator to be able to communicate with users. It is only in this way that the Operator can improve its services and respond to the needs of its customers. Communicating via social media is an important element in reaching customers, the younger ones in particular. Direct messages are stored for an indefinite period of time. Comments on the Fan Page are also stored for an indefinite period of time and can be viewed by other users. The same applies to use of the like button.
6 Rights of the data subject
In the course of using the Fan Page, you shall have the right to assert all the rights described in this section against both Facebook and the Operator. Within the scope of the agreement between the Operator and Facebook, the Operator shall forward your enquiry to Facebook without delay, provided that Facebook alone has to comply with your affected rights.
You have the right of access (Art. 15 of the GDPR), right to rectification (Art. 16 of the GDPR), right to erasure (Art. 17 of the GDPR), right to restriction of processing (Art. 18 of the GDPR) and right to data portability (Art. 20 of the GDPR). The Operator shall endeavour to process any enquiry without delay.
If your personal data is processed on the basis of Art. 6 (1) lit. f of the GDPR, you have the right to object if there are grounds for doing so relating to your particular situation or if you object to direct marketing (Art. 21 of the GDPR). If you object to direct marketing, the Operator shall refrain from sending you promotional messages.
Any consent you have given for the processing of personal data may be withdrawn at any time with future effect. However, the lawfulness of the processing until your consent has been withdrawn shall remain unaffected. You shall have the right to lodge a complaint with the competent supervisory authority at any time. You can find a list of the competent supervisory authorities here:
The data collected when you visit and use the Fan Page, and the information you provide when you engage with the Operator shall be transferred to Facebook and stored there. Otherwise, your data can also be viewed by employees involved in the maintenance of the Fan Page and those replying to your messages.
Some of the Insights Data shall be transmitted to Facebook’s servers in the USA and stored there. This transfer to a third country shall only be permissible with the inclusion of standard data protection clauses. Further information is available at: https://www.facebook.com/legal/EU_data_transfer_addendum.