Privacy policy for the social media presence of Freeworker GmbH on Facebook & Instagram

Data protection information for our Facebook business and Instagram page

The following information pursuant to Art. 13 et seq. GDPR on data protection serve the duty to inform in case of collection of personal data in connection with the call and use of our business Facebook Business & Instagram page.

1. Name and contact details of responsible persons (Art. 4 No. 7 GDPR, Art. 26 GDPR).

Responsible for the processing of your personal data when using our Facebook Business & Instagram page is:

Freeworker Ltd.
St. Gilgen 15
82205 Gilching

(hereinafter “Freeworker”, “we”, “us”).

jointly with:
Meta Platforms Ireland Ltd (formerly Facebook Ireland Ltd).
4 Grand Canal Square Grand Canal Harbour
Dublin 2

(hereinafter “Meta Platforms”)

Freeworker is (together with Meta Platforms) responsible for operation of the Facebook business page•

and the Instagram page

We have concluded a joint responsibility agreement with Meta Platforms pursuant to Art. 26 GDPR, the so-called Page Controller Addendum of Meta Platforms Ireland Ltd

However, we would like to point out that despite the joint responsibility with Meta Platforms, we do not have any full influence on the data processing conducted by Meta Platforms. Meta Platforms does not disclose in which way Meta Platforms uses visitor data of Facebook Business & Instagram pages for its own purposes, to what extent activities on the Facebook Business & Instagram page are assigned to individual users, how long Meta Platforms stores this data and whether data from a visit to the Facebook Business & Instagram page is passed on to third parties, remains therefore unknnown to us.

2. Contact details of the data protection officer of Freeworker:

Holzhofer Consulting GmbH
Martin Holzhofer
Lochhamer Str. 31
82152 Planegg
Tel.: (0 89) 1 25 01 56 00

Facebook also appoints a data protection officer. They can be reached under the following link:

3. Purposes for personal data processing and legal basis

We would like to point out that you are using the Facebook Business & Instagram page and its functions on your own responsibility. This applies in particular to the interactive functions (for example, commenting, sharing, liking and rating). Any data processing associated therewith by Meta Platforms is beyond our influence.

3.1 General

The Facebook Business Account is the user account provided to us by Meta Platforms. This enables us to present our company and services to Facebook users and other people who visit the Facebook Business page, and to interact with them. For each page view of our business sites, so-called “Insights Data” is collected in addition to so-called connection data (or access data). With the help of this data we, the operator of the business site, are able to view statistical evaluations of the use of our business pages on Facebook and Instagram. Personal data is also processed during the collection of “Insights Data” The data processing of “Insights Data” is carried out with Meta Platforms as part of a joint responsibility pursuant of Art. 26 GDPR.

3.2 Processing of access data

Each time a business page is accessed, Meta Platforms processes personal data (connection data). The collection of this data is technically necessary in order to establish and sustain a connection between your terminal device and the Meta Platforms servers.
The following data or categories of data may be collected in this process:

  • IP address
  • Source port of the calling device or a gateway (e.g. firewall or proxy)
  • Time stamp (date and time) of the request
  • Amount of data transferred
  • Message confirming a successful request (by means of http error code)
  • Message explaining a failed request (by means of HTTP error code)
  • Referrals (web pages from which our main page or sub-pages were called up)
  • User agent (type and version of browser used to access our website)
  • Width and height of your display screen
  • Language settings of your browser

3.3 Meta “Page Insights”

When you call up and use the Facebook Business page and/or the Instagram page, the “Page Insights” function enables us to access and process data (statistics on access to our Business pages, such as gender and age distribution). We cannot use this data identify you personally or to assign you to your personal account. In addition, Meta Platforms may show you further information or advertisement according to your preferences.
On our part, this function is a non-derogable part of the user agreement with Meta Platforms. This means that we cannot unilaterally decide whether or not to collect “Insights data”.
The personal data is collected with the help of cookies. These are small text files, usually consisting of letters and numbers, that your browser stores and archives on your computer whenever you visit Meta Platforms pages. By using cookies it is also possible to store information about users without a personal Facebook or Instagram account. According to Meta Platforms, the cookies used by Meta Platforms serve for the purpose of authentication, security, website and product integrity, advertising and measurement, website features and services, performance, and analytics and research.
For more information about Meta Platforms’ site insights feature and the use and settings of cookies, please visit:


You can restrict or completely prevent the setting of cookies in your browser settings. There, you can also trigger the automatic deletion of cookies when closing the browser window.
If you are using the Facebook app and the Instagram app, you can change settings for the setting of cookies by apps in the settings of your mobile device.
Information on the legal basis and the purpose of data processing by Meta Platforms is available here:

Insofar as by visiting our Facebook Business or Instagram page your personal data is processed by us, the permissibility of our data processing is based on Art. 6 (1) lit. f GDPR. In accordance with this, the processing is permissible if it is necessary for the protection of the legitimate interests of the responsible party or a third party, unless the interests or fundamental rights and fundamental freedoms of the data subject outweigh and thus require the protection of personal data. The legitimate interest is in evaluating the anonymized “Insights Data” in order to track usage behavior on our Facebook Business and Instagram pages and, as a result, to be able to optimize the service offering of the pages.

The “Insights Data” collected via the Business pages is made available to us in anonymized form. This means that the personal data collected is modified such that it can no longer be attributed to an identified or identifiable natural person, or can only be attributed to an identified or identifiable natural person with a disproportionate amount of time, cost and labor.

The provision of your personal data is contractually required by Meta Platforms for registered users. The provision of your data is therefore mandatory. In consequence, users not providing personal data cannot use their Facebook account or their Instagram account.

Non-registered users are not required to provide personal data. However, failure to provide the data may result in disabling proper access to our Facebook Business and Instagram pages.
As long as you are logged into your Facebook and/or Instagram account and visit our Facebook Business and/or Instagram page, Meta Platforms can associate this with your profiles. We expressly state that Meta Platforms stores the data of its users (e.g. personal information, IP address, etc.) and may also utilize it for business purposes, in particular advertising. If you wish to avoid this, you should log out of your Facebook account and Instagram account or deactivate the “stay logged in” function, delete the cookies present on your device and close and restart your browser.

3.4 Communications via the Facebook Business Page

Via the message function, the “Like”-buttons and the option to comment on posts on our accounts included on the Facebook Business Page and the Instagram page, it is also possible for you to contact us, via. As part of the outreach, the name that is stored as the user name in your Facebook or Instagram profile will be shown to the operator.
The permissibility of this processing is based on Art. 6 (1) lit. f GDPR, according to which the processing is permissible if it is necessary for the protection of the legitimate interests of the responsible party or a third party, unless the interests or fundamental rights and fundamental freedoms of the data subject outweigh and thus require the protection of personal data. The processing of data for purposes of communication within the scope of business page usage with users of the business page constitutes a legitimate interest of the operator within the meaning of Art. 6 (1) lit. f GDPR.
The provision of your data is neither legally nor contractually required or necessary for the conclusion of a contract. You are not obliged to provide this data. However, the provision of the data is necessary so that you can contact the operator in the manner described above.

4. Automated decision-making including profiling

Automated individual case decisions including profiling according to Art. 22 (1) and (4) GDPR do not occur on the part of Freeworker.

5. Data transfer to a third country

Data transfers to countries outside the EU and the European Economic Area (“third countries”) only take place on the basis of:

  • an adequacy decision of the European Commission within the meaning of Art. 45 GDPR.
  • of an approved certification mechanism pursuant to Art. 42 GDPR together with legally binding and enforceable obligations of the controller or processor in the third country.
  • of standard data protection clauses adopted by the Commission in accordance with the examination procedure under Art. 93 (2) of the GDPR.
    In connection with accessing and using the Facebook Business and/or Instagram page, a transfer of personal data to third countries, in particular to the USA, occurs:
  • Transfer to Meta Platforms Inc. Deborah Crawford 1601 Willow Road Menlo Park, California 94025, USA.
    The USA is considered an unsafe third country. Unsafe third countries are countries outside the EU and the EEA that do not have data protection laws equivalent to the GDPR. If personal data is transferred to recipients in insecure third countries, an adequate level of data protection cannot be easily ensured, which may lead to negative consequences for the data subjects. For example, the guarantee of data subjects’ rights within the meaning of chapter 3 of the GDPR is not ensured.

6. Categories of data recipients

The data collected when accessing and using the business pages as well as the information you provide when contacting us will generally be transmitted to Meta Platforms and stored there.
In addition, your data may be passed on to the following categories of recipients:
• Server providers for the purpose of hosting
• IT service providers for maintaining the IT infrastructure
• External service providers for additional services
• Further processors within the meaning of Art. 28 GDPR in the course of order processing
• Affiliated companies as well as employees of the responsible data controller who are involved in the processing (e.g. marketing department)
Further information on recipients of data stored by Facebook is available here:

7. Storage period and criteria for determining duration of storage

As a matter of principle, personal data will only be stored for the time necessary to fulfil the purposes stated here, or for the retention periods stipulated by the legislator. After the respective purpose ceases to apply or after the retention periods have expired, the data will be deleted in accordance with the statutory provisions.
When accessing a Facebook or Instagram page, the IP address assigned to your terminal device is transmitted to Meta Platforms. According to information provided by Meta Platforms, this IP address is then anonymized (for “German” IP addresses) and deleted after 90 days.
Further information on the respective storage period of the data stored by Meta Platforms is available here:

8. Information on your data subject rights

In connection with the use of the business pages, you have the right to assert all the data subject rights listed here both against Meta Platforms and against us. Within the framework of the agreement that exists between us as the operator of the Business Accounts and Meta Platforms, we will, insofar as Meta Platforms alone is required to comply with your data protection rights, immediately forward your request to Meta Platforms.
You may request information from us at any time (Art. 15 GDPR) about the data stored about you and further request correction (Art. 16 GDPR) in the event of errors. Furthermore, you may demand the restriction of processing (Art. 18 GDPR), the transferability (Art. 20 GDPR) of the data provided to us by you in a machine-readable format or the deletion of your data (Art. 17 GDPR) – insofar as they are no longer required.
You also have the right to object at any time to the usage of your data based on public or legitimate interests (Art. 21 GDPR).
Insofar as we process your data on the basis of consent given by you, you may revoke this consent at any time with future effect (Art. 7 (3) GDPR). From the time we receive your revocation, we will no longer process your data for the purposes stated in the consent.
If you wish to exercise your rights as a data subject, please send your request via e-mail to or address your request by post to the address given in 2. above.

9. Right of complaint to a supervisory authority

Futhermore, you have the right to complain to a supervisory authority in accordance with Art. 77 (1) GDPR. You can obtain further information from your local supervisory authority. In our case, address the
Bavarian State Office for Data Protection Supervision
PO Box 1349
91504 Ansbach

Telephone: +49 (0) 981 180093-0