Privacy Policy Social Media: Facebook and Instagram pages

We, DR Department GmbH, Attilastrasse 52, 12105 Berlin, telephone +49 (30) 86208400, e-mail: (hereinafter “DR Department”), maintain social media company profiles on the Instagram and Facebook platforms (hereinafter "social media page(s)"; in the event of differences or discrepancies, "Facebook page(s)" or "Instagram page(s)"). We use these social media pages to get in touch with the users of the social networks and regularly share content. The operator of this social media site, Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland (hereinafter "Facebook"), can use cookies and similar technologies to record your usage behavior. If you use the social networks (with a profile on our company website, in groups, etc.), the type, scope and purposes of processing the data in the social networks are primarily determined by the operators of the social networks. We can see general statistics on interests and demographics when you browse our social media sites.
In the following we would like to draw your attention to some aspects relevant to data protection law when using our social media pages.
You are responsible for using our social media pages. If you do not want any data processing in connection with Instagram or Facebook, you are welcome to contact us via our website .

I. Processing of personal data by Facebook

According to our information, Facebook processes user data in particular to provide the services, for advertising (analysis, measurements and creation of personalized advertising), market research, to promote protection, integrity and security, to communicate with you, to research and innovate for social purposes and to personalize and improve the products.

You can find more information on data processing by Facebook in the respective data protection declarations for the Facebook pages

and for the Instagram pages

Facebook uses so-called cookies to store and further process this information. These are text files that are stored on the end devices used by the users. If the user has a social media profile and is logged in, cookies can also be stored and analyzed across devices.
You can find more information on the use of cookies by Facebook and how to deactivate them in the respective cookie guidelines for the Facebook pages

and for the Instagram pages

II. Site Statistics

As the operator of the respective social media pages, Facebook provides us with page statistics (page insights), ie statistical data on the use of our Facebook and Instagram pages. These are aggregate statistics generated from specific events logged by the Facebook servers when people interact with Pages and the content associated with them. Information is provided by Facebook for certain categories (followers or fans, people reached, etc.) and periods of time.

1. Facebook Pages

On the Facebook pages we receive aggregated statistics about

  • Number of people who have seen one of our posts at least once, grouped by age and gender
  • Origin of our fans in terms of country, city and language
  • Likes of other pages that are most liked by our fans
  • Interactions with our posts, events or videos
  • relationship status
  • marital status (e.g. parents)
  • degree of education
  • job title
  • Interests
  • user behavior
  • Important events in life (e.g. wedding, engagement, birth of a child, birthdays, moving house)
  • device usage
  • activity frequency.

2. Instagram Pages

  • gender
  • age range
  • Most Popular Locations
  • 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
  • The number of times a photo or video has been shared
  • Profile visits, website clicks and conversations started, and how many people see content on our Instagram page
  • Insights about our posts, stories (subscriptions, calls, replies, emails, SMS messages, shared content, impressions, link clicks, view of the following story, leaving/following the story, website clicks on linked websites)
  • Route planning to linked places
  • Information about subscribers and audience, including but not limited to subscriber growth over a specified period of time
  • Information about when our subscribers are online.

The page statistics for these social media pages are generated and provided by Facebook, ie as the operator of these pages we have no influence on the generation and presentation.
We receive the data in aggregate form and use the statistics to make our posts and activities on our social media pages as appealing to users as possible.
Since the statistics are only shown from a certain number of people, they cannot be traced back to individuals.
You can find more information about page statistics in the information on page insights data

You can also find the joint controllership agreement we have concluded with Facebook on this link .
The processing of this data by DR Department  takes place on the basis of Art. 6 Para. 1 f) GDPR. The processing enables us to optimize the functionalities of our social media pages and to improve our offer. Our legitimate interest in the processing of the data according to Art. 6 Para. 1 f) GDPR also lies in these purposes.

III. Processing of other personal data by DR Department

We may be able to identify users of our social media pages and, depending on the visibility settings, view their profiles and shared information, e.g. if they publish posts or like posts on our social media pages. In this context, we process data (e.g. user names) to operate the social media fan page.

If you no longer want or want to restrict this data processing in the future, you can delete your posts or disconnect your Facebook profile from our site by using the "I don't like this site anymore" function.
If you provide us with your personal data directly via our social media pages (e.g. through posts), we use this exclusively in response to your posts or messages via the Instagram pages, e.g. to answer questions or to Processing of sweepstakes.
The legal basis for the associated data processing is Art. 6 Para. 1 b) GDPR for contract-related inquiries, otherwise Art. 6 Para. 1 f) GDPR, based on our interest in answering inquiries and contributions in a user-oriented manner and, if applicable, the result of the processing documented in case of queries.

IV. Sweepstakes

We regularly run sweepstakes on our social media pages. The prizes will always be sent directly to you by us. If this is not possible in individual cases due to the nature of a prize, e.g. because direct contact must be made with our competition partner or the package should not be endangered by additional transport routes, we will pass on your data to our respective cooperation partner. This is stated in the respective competition.
We use the data provided as part of the participation in the competition exclusively to process the competition. The legal basis for the processing of data in the context of the competition is Art. 6 Para. 1 b) GDPR. Any address data collected for sending the prize will be deleted no later than four weeks after the draw, unless a longer period is specified for the competition. The legal basis for the transmission of data to the respective cooperation partner is Art. 6 Para. 1 b) GDPR.

V. Duration of Storage

The stored personal data will be deleted if you have objected to the processing of your data, if knowledge is no longer required to fulfill the purpose for which it was stored or if storage is inadmissible for other legal reasons.

Please note that Facebook collects and stores your data when you visit our social media pages. This also applies to cookies that Facebook uses to provide the functionalities. Please read the notices from Facebook.

VI. Categories of recipients, transfer to third countries

In principle, we do not transmit your data to third parties unless we are legally obliged to do so (e.g. at the request of law enforcement authorities), we need them to carry out business processes or use them within the framework of an order processing agreement. This applies, for example, to shipping service providers, payment service providers, merchandise management service providers, service providers for order processing, web hosts, communication agencies, external call centers or IT service providers. In all cases, we strictly observe the legal requirements.

Data can also be transmitted to other countries in which the aforementioned contractual partners may be located or process the data. These are primarily states of the EEA and a few states outside the EEA if an appropriate level of data protection is ensured. In addition, we take measures such as agreeing EU standard data protection clauses with the receiving body in order to create suitable guarantees. You can find the contractual text of the EU standard data protection clauses on the website of the European Commission: -scc_en

You can find the relevant information on Facebook:

VII. Rights of the data subject

You have the right to information about the processing of personal data concerning you, a right to data transferability and, if applicable, rights to deletion, correction, restriction of processing and/or objection to processing and a right of appeal to a supervisory authority. You can obtain further information from our data protection officer, whose contact details can be found below.

For the processing of your Page Insights data together with Facebook, we have agreed with Facebook that Facebook is primarily responsible for providing you with the information about the processing of your Page Insights data and for enabling you to use your data to which you are entitled under the GDPR Exercise the rights of the data subject (e.g. right of objection).
We therefore generally recommend that you contact Facebook directly to exercise your rights. If you need support or have any questions, please contact us using the contact details below. We will then be happy to forward your request to Facebook.

VIII. Data Protection Officer

For inquiries about privacy or your personal information at DR Department  you can contact our data protection officer: by e-mail:

or by post:
DR Department GmbH
Team Data Protection
Attilastrasse 52
12105 Berlin

As of December 2020