As of December 2020
Data protection has 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 which data we use on the Instagram presence, when and for what purpose. Instagram is an online photo and video sharing service, owned by 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 only use your personal data if we have your consent or legal permission.
We want to point out that there has been massive criticism of how Facebook works and its privacy practices. One of the biggest data protection problems is that, according to the prevailing opinion in the specialist literature, the NSA has access to Instagram and Facebook data through its programs such as PRISM and XKEYSCORE and that no deletion periods are provided for this data. At the same time, Facebook is one of the most important social media tools and we are dependent on working with Instagram in business life and try to make this as data protection compliant as possible.
Table of contents
- Principles of joint processing and contact data of the persons responsible. 2
- Contact details of the data protection officer. 3
III. General information on data processing at Instagram.. 4
I. Principles of joint processing and contact data of the persons responsible
1. Joint Controllers for the Processing of Personal Data
The purposes and means of processing personal data when visiting our Instagram page are managed by LEDVANCE GmbH, Bayerwaldstraße 9, 81737 Munich, Germany (hereinafter "we", "us", LEDVANCE) and Facebook Ireland Ltd. (“Facebook”) together within the meaning of Art. 26 EU General Data Protection Regulation (GDPR).
This results from the fact that LEDVANCE GmbH, as the operator of the Instagram page, gives Facebook, as the operator of the Instagram service, the opportunity to process personal data by setting up such an account.
As part of the shared responsibility, Facebook assumes primary responsibility in accordance with the GDPR for the processing of Insights data and fulfills 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 Article 32 to 34 GDPR). In addition, Facebook makes the essence of this Page Insights Addendum available to the data subjects (governed by the relevant “Page Insights Controller Addendum”).
Below you will find a description of how LEDVANCE GmbH and Facebook handle personal data when you visit the Instagram account. However, since LEDVANCE GmbH usually 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, if necessary, adapt this data protection declaration accordingly.
We would like to point out that you use the Instagram account and its functions at your own risk. This applies in particular to the use of the interactive functions (such as commenting, sharing, rating).
2. Name and address of joint controllers
- a) The primary controller is:
Facebook Ireland Ltd.
4 Grand Canal Square
Grand Canal Harbour
Dublin 2 Ireland
- b) Further person responsible is:
+49 89 780673-100
II. Contact details of the data protection officer
The data protection officer of the person responsible for LEDVANCE is:
Dachauer Strasse 65
+49 89 7400 45840
You can contact the data protection officer of Facebook Ireland using the online contact form provided on the Facebook platform.
II. General information on data processing at Instagram
1. Data processing by Facebook
2. Cookies from Facebook
If you visit our Instagram page and your browser allows the storage of cookies, Facebook Ireland stores information in the form of small text files in the memory of your browser (hereinafter referred to as "cookies") and can access this information when visiting the Facebook platform. You can find more information about the purpose of the cookies used, the integration of these cookies by other websites and your control options in this regard in the information on Instagram cookies.
We would like to point out that Facebook is able to track your user behavior using the cookies used. This applies to both those who are registered on the Instagram platform and 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 no cookies from the Facebook platform are saved. 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 Facebook page to your Instagram or Facebook user account, should you 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 react to our posts, to comment on them and to send us messages. Please check what personal information you share with us through our Instagram business page. If you wish to prevent Facebook from processing the personal data you have sent to us, please contact us using the contact details given above.
In addition to the content you submit, information about your profile and your contributions is visible to us, depending on your privacy settings. You can change this yourself using the settings on Instagram.
IV. Purposes and legal bases
Your personal data is collected in order to exchange information with LEDVANCE's customers and business partners, to market the products and thereby develop 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 Article 6 Paragraph 1 Sentence 1 lit. f GDPR. Our legitimate interest lies in answering your inquiry or in interacting with our customers as part of social media marketing. If your contact is aimed at concluding a contract, the additional legal basis for processing is Art. 6 (1) sentence 1 lit. b GDPR.
We process the data you provide in this context in order to safeguard our legitimate interests in customer communication. This also includes our legitimate interests in data processing in accordance with Article 6 Paragraph 1 Sentence 1 lit. f GDPR.
V. Categories of data
The information that Facebook processes:
- Device attributes : Information such as the operating system, hardware and software versions, battery levels, signal strength, available storage space, browser type, app and file names and types, and plugins.
- Operations on the device : Information about the 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 used and family device IDs.
- Device Signals : Bluetooth signals and information about nearby WiFi access points, beacons, and cell towers.
- Data from device settings : Information from 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, the 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
Most of the 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 data protection declaration. Your personal data will be passed on by LEDVANCE to internal employees in the marketing and sales department and, if necessary, to processors such as a marketing agency.
It can be assumed that Facebook will pass on the data to third parties or to authorities such as the NSA and this is described in their data protection guidelines and specialist literature.
VII. Data Transfers
The Facebook data policy explains the data transfers from Facebook to third countries and their legal basis.
LEDVANCE does not plan to transfer the data to third countries.
VIII. Duration of storage
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 thinks users will enjoy. LEDVANCE is not aware of the underlying decision-making logic. The scope and impact of using Instagram and other similar social media is large and can be used in mass surveillance systems and for deepfakes and other facial recognition systems.
X. Business Profile
The LEDVANCE Instagram page is a business profile (hereinafter “Instagram company page” or “corporate presence”) and therefore has the Instagram Insights function. This means that part of the data collected by Facebook during use is made available to us as a statistical evaluation in anonymous form. This statistical evaluation only relates to users, content and activities on our Instagram page. The evaluation specifically includes the following data:
- Number of likes of our photos and videos
- Number of comments on our photos and videos
- Number of people who saw a photo or video
- Number of times a photo or video has been shared
- Number of times a photo or video was reported as spam
- Number of times the page was clicked on so that the user no longer likes it
This information transmitted by Facebook to LEDVANCE is anonymized and we cannot link it to you personally as a user of the Instagram page. However, this does not mean that the data collection and data processing on Facebook itself is anonymous.
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.), you may make personal data (e.g. real name or photo of your user profile) public. However, since we usually and to a large extent have no influence on the processing of your personal data by Facebook, we cannot provide any binding information on 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 corporate identity for:
- Sweepstakes, and
- employer branding.
The publications about the company’s appearance can contain the following content:
- information about products,
- Sweepstakes, and
Every user is free to publish personal data through activities.
The data generated by the company's appearance is not stored in our own systems.
You can object to the processing of your personal data that we collect as part of your use of our Instagram company page at any time and/or your under XI. assert the rights of data subjects mentioned in this data protection declaration.
To assert your under XI. You must contact Instagram directly to exercise the rights of the data subject in relation to Facebook mentioned in this data protection declaration.
XI. rights of the data subject
If personal data is processed by you, you are the data subject within the meaning of the GDPR and you have the following rights vis-à-vis the person responsible:
1. Right to information
If your personal data is processed, you have the right to receive information from the person responsible about the data stored about you (Article 15 GDPR).
2. Right to Rectification
If incorrect personal data is processed, you have the right to rectification (Article 16 GDPR).
3. Right to erasure or restriction and objection
If the legal requirements are met, you can request the deletion or restriction of processing and object to the processing (Articles 17, 18 and 21 GDPR)
4. Right to Information
If you have asserted the right to correction, deletion or restriction of processing against the person responsible, he is obliged in accordance with Art unless this proves impossible or involves a disproportionate effort.
5. Right to data portability
If you have consented to the data processing or if there is a contract for data processing and the data processing is carried out using automated procedures, you may have a right to data portability (Art. 20 GDPR).
6. Right to Object
You have the right pursuant to Article 21 GDPR, for reasons arising from your particular situation, to object at any time to the processing of your personal data, which is based on Article 6 Paragraph 1 Sentence 1 lit. e or f GDPR to file an objection; this also applies to profiling.
7. Right to revoke the declaration of consent under data protection law
If you have consented to the processing by the person responsible 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 individual decision-making including profiling
According to Art. 22 GDPR, you have the right not to be subject to a decision based exclusively on automated processing - including profiling - which has legal effect on you or significantly affects you in a similar way.
9. Right to lodge a complaint with a supervisory authority
Furthermore, there is a right of appeal to a supervisory authority (Article 77 GDPR).
This privacy statement was created with the support of DataGuard .