Privacy policy
Demo website: This page is a demonstration website published by Comprenders Open, showing the reference embedding of the booking widget. “Fahrschule Demo Berlin” does not exist; the policy below is an example of how a driving school would describe this website's data processing.
1. Controller
Fahrschule Demo Berlin
Max Mustermann
Demostraße 12
10999 Berlin
E-mail: info@fahrschule-demo.example
2. Hosting and server log data
This website is served as static pages. When you open it, the hosting provider automatically processes the technically necessary connection data (IP address, date and time of the request, page requested, user agent transmitted) in server log files. This processing is necessary in order to deliver the site and operate it securely (Art. 6 Abs. 1 lit. f DSGVO). The log data is not combined with any other data source.
3. Online appointment booking (booking widget)
To let you book advisory appointments and theory courses, this website embeds a booking widget from the scheduling platform Comprenders Open. When you make a booking, we process the data you enter into the widget:
- first and last name
- e-mail address
- telephone number (optional)
- the licence class you are interested in, or the course and date you selected
- the origin of this visit from the list in section 5 (referring host name, UTM parameters, the kind of any advertising click identifier, entry path, time) – so that the driving school can tell which route an enquiry came in by. This applies to every booking, including without the consent described in section 6: without it, these are the properties of this one page view, which the booking widget has in front of it anyway; with it, those of the first page view of your visit. If you have objected to the measurement described in section 5, no origin is attached to the booking.
Your booking request is transmitted to the driving school’s scheduling platform and processed there in order to create and manage your appointment. We use your e-mail address solely for the one-time confirmation code that verifies your address and for communication about your appointment (confirmation, changes, cancellations). It is not used for advertising. The legal basis is Art. 6 Abs. 1 lit. b DSGVO (steps taken prior to entering into a contract, and performance of a contract).
4. Cookie-free reach measurement inside the booking widget
In order to keep the booking process working and to improve it, the booking widget records anonymous usage events (e.g. “widget opened”, “appointment selected”, “booking completed”) and transmits them to an analytics platform operated for Comprenders Open (PostHog). In doing so:
- No cookies are set and no data is stored in your browser (no local storage).
- The events are assigned a random identifier that exists in memory for the current page visit only. No profile is built across visits or devices.
- Besides the event name, what is transmitted is the language selected, the identifier of the driving school, the address of the embedding page without URL parameters, the referring page, and any campaign parameters (UTM) of the page requested. The IP address is unavoidably transmitted along with the request and is evaluated to determine an approximate location (country, region, city), but it is not stored as an event property and is not used to build a profile.
The legal basis is Art. 6 Abs. 1 lit. f DSGVO (legitimate interest in the functioning and improvement of online appointment booking).
5. Reach measurement of this website
In addition to the booking widget, we record for the website as a whole how
often its pages are opened and by which route visitors reached us. That is the
only way we can judge whether our advertising works at all. Transmission is to
the same analytics platform operated for Comprenders Open (PostHog, hosted at
c.measureoptimize.com on our service provider’s servers in
Germany). What is recorded:
- the page view itself (address of the page requested, without URL parameters),
- whether you came from an external website, from one of our own pages, or with no referring page – in the first case additionally the host name of the referring website, never its full address,
- campaign parameters (UTM) of the address requested and – if present – the kind of an advertising click identifier (e.g. “gclid”), not its value,
- whether the booking section was scrolled into view and whether a telephone, e-mail or WhatsApp link was clicked,
- your decision in the consent dialogue itself – that is, which of the two questions you answered and how (allowed, declined or withdrawn) – together with the same origin properties as above. Without it we could not judge what proportion of visitors the counted figures actually stand for, or whether willingness to be measured differs by origin. Your decision is not linked to the identifier described in section 6.
This measurement itself stores nothing in your browser – the events receive a random identifier that exists in memory for the single page view only. (A cookie only comes into being once you decide in the consent dialogue; it holds nothing but your decision, see section 7.) Recognition across visits or devices is therefore technically impossible; we count page views, not people. Your IP address is unavoidably transmitted along with the request and is evaluated by the analytics platform to determine an approximate location (country, region, city) – for a driving school, its catchment area is a relevant figure. The IP address itself is not stored as an event property, and no profile is built. The legal basis is Art. 6 Abs. 1 lit. f DSGVO (legitimate interest in measuring the reach of our own offering).
You may object to this measurement at any time – through “Measurement settings” in the page footer. We then record in your browser nothing but the objection itself, so that it still applies the next time you open a page. After that, exactly one single event is transmitted: the objection itself (with the properties from the list above, so that we can gauge how much of our audience our figures cover) – and it is sent immediately before measurement is switched off. From then on, nothing further is sent from that page or on any subsequent visit.
One note on how accurate these figures are, because it applies to us too: what is counted is page views, and only those where JavaScript runs and the transmission is not blocked by a browser or a blocker add-on. The number is therefore a lower bound, not a complete count – and not a number of people.
6. Recognition – only with your consent
The measurement in section 5 cannot tell that several page views belong to one visit. That also makes it impossible to trace which route somebody originally came by if they only decide on an appointment after reading several pages – and that is exactly the question by which a driving school can read off what its advertising is worth.
If – and only if – you expressly consent in “Measurement settings”, we store the
following in your browser for that purpose (local storage, one entry named
cp_measure_v1):
- a randomly generated identifier that has no connection to your name, your e-mail address or your device, and which we do not combine with any other data source,
- the properties of your first page view from section 5 (referring host name, UTM parameters, the kind of any advertising click identifier, entry path, time) – so that the origin of your visit is preserved as you move around the website.
If you then book an appointment, the recorded origin of the first page view is attached to the booking record instead of merely the last one (as it would be without consent, see section 3); this lets the driving school see which channel an enquiry came from, but not your behaviour on individual pages. The legal basis is your consent (Art. 6 Abs. 1 lit. a DSGVO, § 25 Abs. 1 TDDDG). You may withdraw it at any time through “Measurement settings”; the identifier and the stored properties are then deleted from your browser, and measurement continues as described in section 5. Events already recorded are unaffected.
7. What is stored in your browser
In full, with purpose and retention period. This website places nothing beyond these two entries – no advertising cookies, no third-party cookies.
cc_cookie(cookie, 182 days) – your decision from the consent dialogue, so that we honour it and do not ask you again on every page view. This entry is created even if you decline everything: an objection we forget is an objection we cannot comply with. Besides the categories chosen it contains a timestamp and a random identifier for this record of consent; that identifier is neither read nor transmitted by us. Set by the “CookieConsent” software served from our own server, not by a third party. Legal basis: § 25 Abs. 2 Nr. 2 TDDDG (strictly necessary).cp_measure_v1(local storage) – only after you have consented to recognition, with the content described in section 6. It remains until you withdraw consent or clear your browser’s data; on withdrawal the entry is removed.
8. Your rights
You have the right to obtain from the driving school information about the data stored about you (Art. 15 DSGVO), to have inaccurate data corrected (Art. 16 DSGVO) and to have data erased (Art. 17 DSGVO). To do so, please use the contact details given in section 1. You also have the right to lodge a complaint with a data protection supervisory authority.
You may object at any time (Art. 21 DSGVO) to the processing under sections 4 and 5 (reach measurement) that is based on Art. 6 Abs. 1 lit. f DSGVO – most quickly through Measurement settings, where the objection takes effect immediately; alternatively a message to the e-mail address given in section 1 is enough. You withdraw the consent under section 6 in the same place.