We maintain a publicly available profile on the social network Facebook. Based on the latest case law by the European Court of Justice (ECJ) of 5 June 2018, ref: ECJ C-210/16, according to which we are to be jointly responsible for our Facebook Fan Page together with Facebook, we would like to take this opportunity to inform you about how your data is processed. You can see the ruling here.
1. General information regarding processing
When you visit a Facebook page, your behaviour as a user may be extensively analysed. Visiting our Facebook page will also trigger processing operations relating to data protection. If you are logged in to your Facebook account when you visit our Facebook page, Facebook may link this visit to your user account. However, your personal data may still be collected even if you are not logged in, and even if you have no account with Facebook at all.
2. Use of insights and cookies
Data is usually collected using cookies, which are stored on your device, or by recording your IP address.
We use Facebook’s Insights function on our Facebook page. This provides us with anonymised statistical data about our users. The cookie stored on your device by Facebook for this purpose will remain active for a long period of time if you do not erase it, and contains user codes that may be compared when you use other websites.
Please understand that we are not privy to all of Facebook’s processing procedures. As such, should you require more information, you will need to access the relevant information pages on Facebook.
As the operator of this Facebook page, we are, together with Facebook (Facebook Ireland Ltd.), joint controllers as defined by Article 4, Paragraph 7 of the EU General Data Protection Regulation (GDPR). Despite this joint responsibility, we are unable to fully influence Facebook’s data processing.
Ultimately, Facebook’s Terms of Service and the other conditions and policies outlined therein shall apply.
4. Purpose of processing
The purpose of our processing pursuant to Article 5 GDPR is to optimise our advertising for our products and services. In addition to this, we want to obtain information compiled by Facebook based on visits to our Facebook page. By doing so, we gain findings that enable us to distribute our advertising in a more targeted and substantively more precise manner. We hope to use this information to better pique our users’ interest, not to bother individual users with uninteresting advertising.
The statistics compiled by Facebook are sent to us only in anonymised form, and we do not receive access to the data collected by Facebook.
5. Legal basis and legitimate interests
By using the services provided by Facebook, we are hoping to demonstrate as broad as possible a presence online, which represents a legitimate interest as defined by Article 6 Paragraph 1(f) GDPR. The analytical processes carried out by Facebook may be based on a different legal basis, e.g. consent as defined by Article 6 Paragraph 1(a) GDPR.
6. Disclosure of data
We do not know whether the information collected by Facebook is also processed outside of the European Union. However, Facebook is certified under the Privacy Shield data protection framework and has committed itself to complying with the standards of EU data protection law.
7. Your right to object
As a user of our services on Facebook, you have the right to information, rectification, erasure, restriction to processing, data portability and the right to object to both us and Facebook.
8. Definition of joint responsibility
Although we bear joint responsibility with Facebook for the data processing, the fact that our Facebook page is embedded in the Facebook platform means that we have no direct control over Facebook’s processing of data. As such, only Facebook is able to take direct action to protect your data and provide information on said action. However, should you have any questions, please do not hesitate to contact us.
9. Data retention periods
We erase data collected directly by us as soon as the purpose of its retention no longer applies, if you request that we erase your data or, where applicable, if you revoke the consent you have granted us to retain your data. The cookies stored on your device will remain there until you erase them.
However, please note that we have no control over the retention period for the data stored by Facebook for their own purposes.
10. More information
You can view our contact details, your rights in respect to us and information about how and why we process data in our Privacy Notice here on our website.
You can view more information about how Facebook processes data by clicking this link: Data Policy
You can adjust your advertising settings at any time in your Facebook user account. To do so, please click this link.