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Privacy policy LEDVANCE Instagram

Status December 2020

Data protection is a top priority for LEDVANCE. 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.

In the following, we explain to you which data we use on the Instagram site, at what time and for what purpose. Instagram is an online service for sharing photos and videos that belongs to Facebook.

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 will only use your personal data if we have your consent or legal permission.

We want to make you aware that there has been massive criticism of how Facebook operates 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. At the same time, Facebook is one of the most important social media tools and we rely on it in business to work with Instagram and try to make this as privacy compliant as possible.

Table of Contents

  1. Shared processing principles and controller cotact data. 2
  2. Contact details of the data protection officer. 3

III General information about data processing on Instagram.... 4

  1. Purposes and legal bases. 5
  2. Categories of data. 6
  3. Recipients of data. 6

VII Data transfers. 7

VIII. storage period 7

  1. Automated decisions. 7
  2. Business profile 7
  3. Rights of the data subject. 9

I. Principles of Joint Processing and Contact Data of Data Controllers

1. joint controllers for the processing of personal data.

The purposes and means of processing personal data when visiting our Instagram page are determined by LEDVANCE GmbH, Bayerwaldstraße 9, 81737 Munich, Germany (hereinafter "we", "us", LEDVANCE) and Facebook Ireland Ltd. ("Facebook") jointly within the meaning of Article 26 of the EU General Data Protection Regulation (GDPR).

This results from the fact that LEDVANCE GmbH, as the operator of the Instagram page, enables Facebook, as the operator of the Instagram service, to process personal data by setting up such an account.

Facebook assumes primary responsibility under the GDPR for the processing of Insights Data as part of the joint responsibility and fulfils all obligations under the GDPR with regard to the processing of Insights Data (including Articles 12 and 13 GDPR, Articles 15 to 22 GDPR and Articles 32 to 34 GDPR). In addition, Facebook makes the essence of this Page Insights Addendum available to data subjects (governed by the relevant "Page Insights Controller Addendum").

Below you will find a description of how personal data is handled by LEDVANCE GmbH and Facebook when visiting the Instagram account. However, as LEDVANCE GmbH generally or to a large extent has no influence on the data collected by Facebook and its processing by Facebook, we are currently unable to provide any clear information on the purpose and scope of the processing of your data by Facebook. However, we will monitor further developments in this regard and adapt this privacy policy accordingly if necessary.

We would like to point out that you use the Instagram account and its 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

  1. a) The primary responsible party is:


Facebook Ireland Ltd.

4 Grand Canal Square

Grand Canal Harbour

Dublin 2 Ireland

  1. b) Further responsible person is


Parkring 29-33

85748 Garching


+49 89 780673-100 details of the data protection officer

The data protection officer of the responsible LEDVANCE is:

DataCo GmbH

Dachauer Street 65

80335 Munich


+49 89 7400 45840

You can contact the Facebook Ireland Privacy Officer via the contact form provided on the Facebook platform. Online contact form contact.

II. general information on data processing by Instagram

1. data processing by Facebook

The InstagramPrivacy policy identifies the categories of personal data processed when using Facebook products such as Instagram. The policy describes in general terms the purposes for which this data is used. And that policy identifies the categories of recipients to whom that 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. The policy provides information on how you can exercise your rights of access, rectification, portability, and erasure against Facebook Ireland. For more information about your control options, please see Instagram's settings options or their help pages.

2. cookies from Facebook

When you visit our Instagram page and your browser allows cookies to be stored, Facebook Ireland 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 Facebook platform. For more information on the purpose of the cookies used, the integration of these cookies by other websites and your control options in this regard, please refer to the information on Instagram cookies.

We would like to point out that Facebook is able to track your user behaviour with the help of the cookies used. This applies both to those who are registered on the Instagram platform and to those who are not registered there.

We would also like to point out that we have no influence on Facebook's data processing in connection with cookies. It is also possible to visit our Instagram page if you configure your browser so that cookies are not stored by the Facebook platform. 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 would like to prevent Facebook from linking your visit to our Facebook page to your Instagram or Facebook user account, you should log out of Instagram, delete the cookies on your device and close and restart your browser.

3. data processing during interactions on our Instagram page.

On our Instagram company page, you have the opportunity to respond to our posts, comment on them and send us messages. Please check what personal data you share with us through our Instagram company page. If you would like to prevent Facebook from processing the personal data you submit to us, please contact us using the contact details 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.

As far as we can, your data processed by us will be deleted when our Instagram company page is closed. If this data continues to be stored by Facebook, it will be based solely on the terms of the Instagram Privacy Policy and Instagram's Terms of Service.

IV. Purposes and legal basis

Your personal data is collected for the purpose of communicating with LEDVANCE's customers and business partners, 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 its content is carried out by us on the basis of Art. 6 (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 concluding a contract, the additional legal basis for processing is Art. 6 (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 (1) S. 1 lit. f DSGVO.

V. Categories of data

The information that Facebook processes:

  • Device attributesInformation such as the operating system, hardware and software versions, battery level, signal strength, available storage space, 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.
  • IdentifiersUnique identifiers, device IDs, and other identifiers, such as those of games, apps, or accounts in use, and family device IDs.
  • Device signalsBluetooth signals and information about nearby Wi-Fi access points, beacons, and cell towers.
  • Data from 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 service provider, language, time zone, mobile 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 -.

VI. recipients of data

The majority of personal data, such as photo, name or username are publicly displayed by Instagram. Only direct Instagram messages to LEDVANCE are data that are not public in the context of this privacy policy. Your personal data will be passed on by LEDVANCE to internal employees of the marketing and sales department and, if necessary, to contract processors such as a marketing agency.

The transfer of data to third parties or to authorities, such as the NSA, by Facebook is to be assumed and is described in their privacy policy and in the technical literature.

VII Data Transfers

Facebook's data policy explains Facebook's data transfers to third countries, as well as their legal basis.

LEDVANCE does not plan to transfer data to third countries.

VIII. storage period

In the Facebook data 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.

IX. Automated Decisions

Instagram uses automated decisions to display content to users. Instagram recommends content that Instagram believes users will like. LEDVANCE is not aware of the decision-making logic behind this. The scope of the use of Instagram and other similar social media and its implications are large and may be used in mass surveillance systems and for deepfakes and other facial recognition systems.

X. Business Profile

LEDVANCE's Instagram page is a business profile (hereinafter "Instagram business page" or "business presence") and therefore has the Instagram Insights feature. This means that part of the data collected by Facebook during use is made available to us as a statistical evaluation in anonymised form. This statistical analysis only relates to users, content and activities on our Instagram page. 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 viewed 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 it was clicked that the user no longer likes the page

This information transmitted by Facebook to LEDVANCE is anonymised and cannot be linked by us to you as a user of the Instagram page. However, this does not mean that the data collection and data processing at Facebook itself is anonymized.

On our Instagram company page, we provide information and offer Instagram - users the opportunity to communicate. If you carry out an action on our Instagram company page (e.g. comments, posts, likes, etc.), it may be that you thereby 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 Facebook, 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 is used for communication and information exchange with (potential) customers and business partners. In particular, we use the company presence for:

  • Products,
  • competitions, and
  • Employer branding.

In this context, publications via the corporate presence may contain the following content:

  • Information about products,
  • competitions, and
  • advertising.

Each user is free to publish personal data through activities.

The data generated by the company website will not be 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/or assert your data subject rights listed under XI. of this privacy policy.

To assert your data subject rights mentioned under XI. of this Privacy Policy against Facebook, you must contact Instagram directly.

XI. Data subject rights

If personal data is processed by you, you are a data subject within the meaning of the GDPR and you are entitled to the following rights against the controller:

1. right to 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 of rectification

If inaccurate personal data is processed, you have the right to rectification (Art. 16 DSGVO).

3. right to erasure or restriction as well as objection

If the legal requirements are met, you may request erasure or restriction of processing as well as object to processing (Art. 17, 18 and 21 DSGVO).

4. right to information

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 inform all recipients to whom the personal data concerning you have 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 be entitled to the 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 relating to 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 making a corresponding declaration, you may 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

According to Art. 22 DSGVO, you have the right not to be subjected to a decision based exclusively on automated processing - including profiling - which produces legal effects vis-à-vis you or similarly significantly affects you.

9 Right to complain to a supervisory authority

Furthermore, you have the right to lodge a complaint with a supervisory authority (Art. 77 DSGVO).

This privacy policy has been prepared with the assistance of DataGuard Created.