Legal notice / netiquette / data protection
KfW Group is active on social networks:
Publication details
KfW’s social media offering is published by:
KfW
Group Communications Department
Gerd Hanow (responsible, in acting capacity)
Palmengartenstrasse 5-9
60325 Frankfurt am Main, Germany
Tel: 069 74 31 0
Fax: 069 74 31 29 44
KfW’s social media editorial team:
Sebastian Macán
Thomas Schmitt
Pia Carter
- KfW Treasury: Jürgen Köstner / Debroah Köhler
- KfW Careers: Clara Laux / Hanna Ngyuen
- KfW Research: Bettina Apfelbach
- KfW DigiOffice: Thomas Dapp
- KfW Development Bank: Nicolai Tust / Samiera Toma / Victoria Schuff
- KfW Country Offices:
@KfW_Maputo: X channel team Maputo Office | Julia Crause |
@KfW_Beirut: X channel team Beirut Office | Dr Solveig Buhl |
@KfW_en_CA: X channel team Central American Office | Alexander Ehlert |
@KfW_Zambia: X channel team Zambia Office | Stefan Lutz |
@KfW_Islamabad: X channel team Islamabad Office | Sebastian Jacobi |
@KfW_Ramallah: X channel team Ramallah Office | David Kunze |
@KfW_New Delhi: X channel team New Delhi Office | Wolf Muth |
Netiquette of KfW Group
Here you will find all the relevant guidelines and standards that KfW applies to discussions on its social media channels.
Welcome to KfW’s social media channels. We look forward to a lively and constructive exchange of ideas. Would you like to share with us your opinions, feedback, further information, criticism or praise? Our community would be happy to hear from you.
Everyone has the right to freely express an opinion within the limits of what is permitted by law. We strive to create a pleasant atmosphere for discussion so that interesting conversations can develop – even when differences or emotional topics arise. The comments columns are intended to be a place where everyone feels comfortable and is free to express their opinion. To ensure this, the comments on the social media channels are moderated by us within the scope of the commensurate. We therefore ask you to comply with the following rules.
- Communicate objectively and constructively. A respectful tone is important to us. Even if you do not share the opinions of other users or are not convinced of KfW’s reporting, make sure that the tone is friendly and appropriate. Avoid provocations, insults, defamation, threats and any kind of vilification.
- Calls for violence or the endorsement of criminal offences shall not be tolerated.
- It is not permitted to insult, discriminate against or defame users or user groups, whether based on their religion/ideology, ethnic origin, nationality, disability/chronic diseases, income, sexual identity, age, gender/gender identity or their external appearance.
- Extremist and radical ideology, racism and hate propaganda, sexist and misanthropic statements are also not tolerated.
- Statements and comments that propagate conspiracy narratives, especially those that include anti-Semitic narratives, are prohibited.
- Pornography and obscenities as well as the infringement of third-party rights are not permitted.
- The use of the comment function for advertising purposes, election or party advertising is not permitted. Also refrain from soliciting for campaigns, petitions, rallies or donations.
- Make sure your comments are related to the topic of the respective post. Non-subject-related comments have no place here.
- We check links to external websites. If they are not related to the actual topic, they are removed.
- The publication of forum/blog posts, personal correspondence and personal data (addresses, e-mail addresses or telephone numbers) is also not permitted.
- Always check whether you have the rights to distribute the published content. For quotes, videos and all other content of third parties, observe copyright law and label the content accordingly.
- If theories, claims or suspicions cannot be proven by credible sources, they can be removed. Therefore, check and name your sources.
- Do not repost the same subject matter. Spam is not wanted. Automatically or machine-generated comments (such as by bots) or comments that are obviously part of a campaign (for example, part of a public outcry) can be removed.
The aforementioned rules apply to the following KfW platforms: X, Instagram, YouTube, LinkedIn, Threads, Xing.
If a user does not comply with the above rules, we reserve the right (“virtual domiciliary rights”) to hide content, to delete it if necessary and/or to report it to the platform operators. If comments link to content that violates our rules, they will also be deleted. There is no right to publication of all contributions. If you are active on our social media channels, you understand you must comply with these rules. We reserve the right to exclude users who repeatedly or seriously violate the rules of our platforms. If a user commits a criminal offence, we reserve the right to file a charge.
The following applies in general: All users are themselves responsible for the comments they publish. By posting a comment, you agree that your statements may be made publicly available – including username, profile picture and comment text. KfW is not responsible for linked content.
And we hope you now enjoy discovering, commenting and discussing.
Thank you very much!
Privacy notice
As a promotional bank under the authority of the Federal Republic of Germany, KfW is committed to improving economic, social and environmental living conditions across the globe.
Public relations work for KfW also takes place on Instagram, X YouTube, Threads and LinkedIn.
Protecting your privacy is important to us. In this context, we would like to point out the existing data protection risks you face by using the above-mentioned social media platforms.
We therefore expressly draw your attention to the fact that the services used by KfW process the personal data of their users on their own responsibility for the business (commercial) purposes explained in their data protection and usage agreements. We expressly draw your attention to the fact that KfW has no knowledge of the purposes for which your personal data are used by the platform operators beyond the data processing described in the data protection notices of the service providers, nor does it have any influence on the collection of data and its further use by social networks. For example, there is no knowledge in particular about the extent to which personal data is stored, where it is stored and for what duration, to what extent the networks comply with the deletion obligations, which evaluations and links are carried out with the data and whom the data is passed on to. It can be assumed that your personal data will be processed in third countries and passed on to third parties.
KfW’s use of social media platforms does not include any endorsement of these media, the company guidelines or the data protection policy of these service providers. KfW recommends that all users find out more about the processing of their data by the platforms listed above and protect their privacy as best they can: this includes reading the data protection guidelines of the social media platforms. Please also check the options for protecting your privacy on the social networks on a regular basis. KfW has no influence on this.
Our legitimate interest results from the goal of optimising our social media channel. The options for exercising your rights to prevent these web tracking methods from be carried out can be found in the platform operators’ privacy notices listed above.
With the subsequent usage concepts for the respective services, KfW, as a public-sector body, assumes its responsibility and role model function for the use of social media.
Use concept for social media
KfW informs the general public about the tasks assigned to it by law and about the fulfilment of these tasks. Public relations work is one of these tasks, which it also carries out via social media channels. With this usage concept, KfW, as a public authority, assumes its responsibilities and role model function for the use of social media.
Please also note our privacy policy and assessment of the consequences of social media use.
KfW’s presence on social media is necessary because more and more young people are using this media as their primary or sole source of information (source: Media Perspectives/January 2021). The majority of our followers are between 25 and 34 years old. Without social media, KfW would find it difficult or impossible to reach some of its target groups.
Because KfW is covering the whole range of economic policies, its target groups are very different to one another. This requires messages to be distributed differently to the different target groups. To reach everybody, a differentiated range of channels is required. The social media sites mentioned are part of KfW’s public relations work, are intended solely for public information purposes and do not include any specific administrative services.
KfW processes personal data of platform users on its own responsibility. Although it does not collect any data about your accounts, it does process the data you provide for the respective services, in particular your username and the content published under your account, insofar as we share or comment on your posts, retweet or respond to your tweets or write our own posts/tweets that refer to your account, or we may share your videos, after consulting you, on our own channel. This may be the case if, for example, you are employed at KfW or are promoted as a company, business partner or institution, and a video was produced on the topic of your work/the respective promotion programme. The data that you freely publish and disseminate will thus be included in KfW’s offer and made available to its followers and subscribers.
As the provider site we do not collect or process any additional personal data from your use of our service. The page is for information and communication purposes only.
The following entities have controllership of the data processing of persons living outside the United States:
Verantwortlich für die Datenverarbeitung von außerhalb der Vereinigten Staaten lebenden Personen ist bei
a) Facebook (Meta)
Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland
b) Instagram (Meta)
Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland
c) YouTube
Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland.
d) X
X Corp., 1355 Market Street, Suite 900. San Francisco, CA 94103, USA.
e) LinkedIn
LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Irland.
f) Threads (Meta)
Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Irland
The platform operators and KfW act as joint controllers for the web tracking methods used by the respective platform operators. Web tracking can also take place regardless of whether you are logged in or registered on the social media platform. KfW has no influence on the use of such tools by platform operators and has not been informed of such potential use. If such tools are used by platform operators for KfW’s social media profiles, KfW has neither commissioned nor agreed to this nor otherwise supported it in any way. KfW will also not be provided with the personal data obtained during the analysis. Only certain, non-personal, aggregated information about the activity, such as the numbers of likes or clicks on a particular post or profile, can be viewed by KfW via its accounts. KfW has no way of preventing or discontinuing the use of such tools on its social media profiles.
The legal basis for the processing described and the web tracking methods is Art. 6 Para. 1 sentence 1 lit. f) GDPR.
a) Instagram
Instagram is a social network focused on video and photo sharing, run by Meta Platforms, with its head office in Menlo Park, California. It is a free online service for sharing photos and videos, to which short texts can also be added to the image description. It is not possible to link images or texts to other websites. To view and use content, users must create an account and log in. Using a search function, users can search for specific content and follow people or organisations as subscribers and comment on posts.
You can find more information about Instagram here.
The advantages of Instagram are its enormous popularity with young target groups and its strong visual orientation.
aa) Purpose of use
The purpose of this social media presence is to reach those who we cannot reach on our website. This includes young people in training and those who are interested in KfW as a potential employer (18 to 34 years old). If we were to stop using Instagram, we would not be able to reach many young recipients.
In addition to informing users, it is also important to uphold KfW’s modern, engaging image.
KfW has set up three separate accounts for this purpose:
@kfw.de with content primarily based on the content of the KfW Stories magazine, the related website and information on KfW promotion for private individuals and companies.
@kfw.karriere with content from the KfW Careers department and KfW as an employer.
They complement the existing communication channels mainly through a higher proportion of visual communication and uphold KfW’s image as a digital transformation and promotional bank, including for younger target groups.
The possibility for users to interact with content, save it, share it, like it and comment on it also provides valuable opinions and indications of the perception and communicative added value of information about KfW’s activities among the target groups.
bb) Type and scope of use
KfW’s general Instagram account is primarily a supplement to the KfW Stories website and uses content posted there with less text and more images. The kfw.foerderung account also complements the existing online presence and primarily refers to our homepage. The account kfw.karriere presents information about training and further education opportunities, offers and requirements for potential employees, advisory services and reports on KfW careers events.
cc) Data processed by Instagram
Instagram processes the data you enter voluntarily, such as your name and username, e-mail address, telephone number or the contacts in your address book, when you upload or synchronise it. Instagram also evaluates the content you share to determine which topics you are interested in, saves and processes confidential messages that you send directly to other users and can determine your location based on GPS data, information on wireless networks or via your IP address, in order to send you advertising or other content.
Information about what data Instagram processes and for what purposes can be found in Instagram’s privacy policy:
https://help.instagram.com/155833707900388/
Further information on data protection issues can be found on the following Instagram support pages:
https://help.instagram.com/519522125107875
• View and download your personal data:
https://help.instagram.com/181231772500920?cms_id=181231772500920
• Findings about yourself through Instagram:
https://help.instagram.com/181231772500920and https://help.instagram.com/155833707900388/
• Information on personalisation and data protection settings options
https://help.instagram.com/116024195217477
• Questions, concerns, exercise of data subject rights and complaints about data privacy: https://help.instagram.com/contact/1845713985721890
b) YouTube
YouTube is an online platform for publishing and distributing videos. YouTube is one of the most widely used “search engines” worldwide. Registered users can utilise this service to publish videos free of charge. These videos are usually provided in a way that makes them publicly visible.
Google’s YouTube service is provided by Google Ireland Limited. A Google account is required to register with YouTube.
Registered YouTube users can follow other YouTube users, rate their videos and share the videos within YouTube, but also on other online platforms and websites. It is also possible to view video posts without having to use your own user account.
More information on YouTube can be found here:
The advantage of YouTube is its large international reach and readability without the need for users to log in themselves, as well as its usability without using their real name.
aa) Purpose of use
YouTube is used by KfW to store and distribute its own videos. KfW’s YouTube channel complements existing social media activities and extends the reach of the information provided there to users who prefer to be active on YouTube. Our videos are uploaded to the platform free of charge. The importance of videos for sharing information has increased significantly over the past decade. The YouTube channel videos primarily inform the users about funding projects, funded project partners and events.
bb) Type and scope of use
KfW’s YouTube channel is used to upload and share its own videos. Consultations in particular cases are not offered via this communication channel. YouTube represents a supplement or excerpt from the website, meaning that there are no disadvantages, if it is not used.
cc) Data processed by YouTube:
YouTube processes the data you enter voluntarily, such as your name and username, e-mail address and telephone number. YouTube also evaluates the content you share to determine which topics you are interested in, stores and processes confidential messages that you send directly to other users and can determine your location based on GPS data, information on wireless networks or via your IP address in order to send you advertising or other content.
Information about what data YouTube processes and for what purposes can be found in YouTube’s privacy policy:
https://policies.google.com/privacy?hl=de&gl=de
Further information is available on the following pages of the YouTube support site:
https://support.google.com/youtube/answer/2801895?hl=en
• Conclusions about you through YouTube:
https://myactivity.google.com/?utm_source=my-account&utm_medium=&utm_campaign=my-acct-promo
• Information about personalisation and privacy settings:
https://support.google.com/youtube/answer/2801895?hl=en
• Questions, concerns, exercise of data subject rights and complaints about data privacy:
https://support.google.com/accounts/answer/162744?hl=en
c) X
X Corp., based in San Francisco, USA, is a communication platform for short messages. On X registered users can publish messages free of charge, which are generally visible to everyone. These messages are a maximum of 280 characters long. Images and videos can also be sent.
Network users can follow other accounts to receive their posts and direct messages.
One advantage of the network is its long reach and that it can be used by anyone without having their own account or using their real name. Twitter thrives on being up-to-date. The real-time medium uses "hashtags", i.e. linked keywords. These bundle topics, that can spread quickly across the social network. You can also refer to other accounts, reply to posts or reposts on your own channel. Twitter can be used by private individuals as well as organisations, companies and institutions.
More information on the network can be found here:
aa) Purpose of use
With the establishment of the X account, existing communication channels for information, opinion formation and interaction such as the website, press releases, print media as well as events and dates were expanded. KfW’s X accounts focus on selected news on KfW-relevant processes and reports or on topics related to KfW.
It is estimated that around 12 million people in Germany use X. KfW reaches a media-orientated, politically interested target group on X consisting of journalists, representatives of interest groups, politicians and citizens interested in politics, who have the opportunity to follow the account on a permanent basis and therefore be able to be informed even better on KfW’s promotional activities.
Since X users are often multipliers, for example from the areas of education, culture, science, associations and unions, X seems to be suitable for expanding KfW's reach in terms of its information and offers. KfW also wants to promote external impact, as the channels enable better networking with other institutions and more immediate reactions to the respective events or topics.
bb) Type and scope of use
The X account provides information on current topics and activities relating to KfW’s promotional and financing priorities. The aim is to communicate subject matter of interest and with added value for the target group.
KfW’s use of X does not imply unrestricted endorsement of this medium or of the company or X Corp.'s privacy policy. The following applies to X users: The X short message service offered and its functions are used on their own responsibility. This applies in particular to the use of interactive functions. KfW expressly points out that X stores the data of its users (e.g. personal information, IP address, etc.) in accordance with X data usage guidelines and uses it for business purposes. KfW has no influence on this data collection and the further use of the data by X.
cc) Data processed by X
X processes the data you enter voluntarily, such as your name and username, e-mail address, telephone number and the contacts in your address book, when you upload or synchronise this. X also evaluates the content you share to determine which topics you are interested in, saves and processes confidential messages that you send directly to other users and can determine your location based on GPS data, information on wireless networks or via your IP address in order to send you advertising or other content. Information on what data Twitter processes and for what purposes can be found in X's privacy policy:
https://twitter.com/en/privacy
Further information is available on the following pages of the X support page:
https://help.twitter.com/en/safety-and-security/twitter-privacy-settings
https://help.twitter.com/en/search?q=privacy
• View and get informed about your own data:
https://support.twitter.com/articles/20172711#
• Findings about yourself on X:
https://help.twitter.com/en/rules-and-policies/data-processing-legal-bases
• Information about personalisation and privacy settings:
https://twitter.com/en/privacy
• Questions, concerns, exercise of data subject rights and complaints about data privacy:
https://help.twitter.com/en/forms/privacy
https://support.twitter.com/articles/20170320#
https://support.google.com/accounts/answer/162744?hl=en
d) LinkedIn
LinkedIn, with its head office in Mountain View, USA, is a social network for maintaining existing business contacts and for establishing new business connections. With over 350 million users worldwide, LinkedIn is currently the largest online professional network in the world. Therefore, LinkedIn achieves a greater international reach than other career networks, such as XING, which is predominantly used in German-speaking countries.
The network enables its users to communicate and exchange information directly with people with the same professional interests. The network is also used for recruitment; users present themselves as qualified employees, and companies and organisations advertise themselves as attractive employers. Although LinkedIn’s focus is typically on the professional sector, the network is also utilised by many users to establish private contacts.
You can create personal profiles or company pages on LinkedIn, whereby company pages can only be set up via a personal profile with administrator rights; there is no real name policy. To use the network functions, you must be registered as a user. Some content shared by the LinkedIn user can also be read without the need for a separate login.
Posts can be made on LinkedIn in the form of texts, photos, videos and live streams. Registered users can utilise this service to publish their content free of charge, network with other users or company sites, comment on their posts, and "like", unlike" and "share" posts. Users can recommend or subscribe to company pages so that relevant posts are displayed in their own LinkedIn feed.
More information on LinkedIn can be found here:
https://www.linkedin.com/help/linkedin
aa) Purpose of use
Social career networks are becoming increasingly important for success in the global labour market. KfW uses LinkedIn with an entrepreneurial profile to make itself identifiable and present itself as an attractive employer. Interested LinkedIn users can simply subscribe to the company page and will be notified of new posts. KfW’s LinkedIn presence therefore enables a wide-ranging dissemination of posts and impressions of KfW Group’s way of working, as well as observation of the reactions immediately following them. KfW also supports its employees in maintaining and expanding their professional network. Here, you can network directly with other KfW employees and exchange experiences.
bb) Type and scope of use
The content of the posts corresponds to the content posted on other KfW social media channels. KfW’s LinkedIn profile therefore informs users about current topics and activities. In addition to the company profile, the focus here is on the communication among employees and their personal professional networks.
cc) Data processed by LinkedIn
By using LinkedIn, your personal data is collected, transferred, stored, disclosed and used by LinkedIn Corporation. In addition to the data you provide voluntarily, such as profile, login, contact and calendar data, LinkedIn also collects and processes location and device information as well as Internet protocol addresses (IP addresses). Using cookies or similar technologies, LinkedIn can also identify you outside of its own services and across different devices. LinkedIn collects and analyses data from the content you publish and upload, news and messages, as well as data from partners and affiliated companies, such as information provided by your workplace/training centre, websites or third-party services. LinkedIn states that it analyses your personal data, by using, among other things, automated systems and its own conclusions, to offer you other services (including advertisements), and to adapt these to be more relevant and useful to you and others.
LinkedIn also states that it may use the services of third parties (partner companies and third-party service providers) to help them provide their services (for example maintenance, analysis, evaluation, payment, fraud detection, marketing and development). These third parties have access to your information to the extent reasonably necessary to perform the relevant tasks for LinkedIn and are required not to disclose or use your information for any other purpose. LinkedIn may also merge data internally via various services covered in its privacy policy.
Keep in mind that all information you enter in your profile is publicly visible by default, i.e. members who log into the network as well as customers of LinkedIn services can view them. This also applies to your activities within the service, such as comments on posts, "likes" or the “Follow” function. Group memberships are also publicly visible. If you share posts, this is set to be public by default. In the options, you can limit the visibility of these posts to your contacts. You can also choose to share your contact list with all your contacts on LinkedIn in Settings. Due to the fact that your profile is public, your content can also be found outside LinkedIn and on search engines.
You can generally ask LinkedIn to delete part of your personal data. However, there are also data usages that you cannot influence via settings.
You can find information about LinkedIn’s full data collection activities and other data protection setting options at:
http://www.linkedin.com/legal/privacy-policy
Further information is available on the following pages of the LinkedIn help page:
https://www.linkedin.com/help/linkedin
• View and download your personal data:
https://www.linkedin.com/psettings/member-data.
• Unsubscribe from interest-based advertising:
https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
• Questions, concerns, exercise of data subject rights and complaints about data privacy:
https://www.linkedin.com/help/linkedin/ask/PPQ
You can also reach LinkedIn by post:
LinkedIn Ireland Unlimited Company
Attn: Legal Dept. (Privacy Policy and User Agreement)
Wilton Plaza
Wilton Place, Dublin 2, Ireland
The only option you have if you do not agree to the use described above is to close your account:
https://www.linkedin.com/psettings/account-management/close-submit
e) Threads
Threads is a text-based app from Instagram where you can view and share public conversations. Depending on how you use Threads, you can also post your own threads, respond to threads from others, and follow profiles. Threads and responses may contain short text passages, links, photos, videos or any combination of these formats.
More information on Threads can be found here: https://help.instagram.com/788669719351544
The advantages of Threads include the quick exchange of content and messages and easy access by linking to Instagram
aa) Purpose and use
The purpose of this social media site is to reach people we cannot reach on our website. As with Instagram, the aim is to reach out to young people in training and those interested in KfW as a potential employer (18 to 34 years old). The channel also targets users who are interested in KfW topics in general.
The Thread channel @kfw.de’s content is primarily based on content from the KfW Stories magazine and associated website. It mainly provides information on KfW's promotional activities for private individuals and companies.
bb) Type and scope of use
KfW’s Threads account complements the Instagram channel and the KfW Stories website. It uses the content posted there in the form of compact picture-text posts. The account is primarily used to discuss and exchange experiences with the community on KfW-related topics.
cc) Data processed by Threads
Threads is part of Instagram and therefore processes both voluntary data entered and data from Instagram, such as profile information, activities, followers and other contacts. Twitter also evaluates the content you share to determine which topics you are interested in and can determine your location based on GPS data, wireless network information or your IP address in order to send you advertising or other content. Threads is interoperable with third-party services. Due to this linking of threads, shared content can also be forwarded to people other as Meta and Threads users.
Information about what data Threads processes and for what purposes can be found in Instagram’s Threads Supplemental Privacy Policy:
https://help.instagram.com/515230437301944?locale=en_GB&cms_id=515230437301944&force_new_ighc=false
Further information about privacy issues is available on the following page:
You can find instructions on how to view and download your own data under “Security and data”:
https://help.instagram.com/179980294969821?cms_id=179980294969821
Conclusions about your person by Instagram and Threads:
Access and download your information on https://help.instagram.com/181231772500920?cms_id=181231772500920
For information on personalisation and privacy settings options, see "Security and data”:
https://help.instagram.com/179980294969821/?helpref=hc_fnav
Questions, concerns, exercise of data subject rights and complaints about data privacy:
https://help.instagram.com/769983657850450
Meta Platforms Ireland Ltd
Merrion Road
Dublin 4,
D04 X2K5,
Ireland
KfW also processes your data. Although we do not collect any data ourselves on your social media profiles or your usage behaviour, we process the data you provide to the respective networks, in particular your username and the content published under your account, insofar as we comment on your posts, videos, images where necessary, repost or share your videos on our own channel, after consulting you if necessary, or also write posts that refer to your account. The data you freely publish and disseminate on the networks is therefore included in KfW’s offer and made available to its subscribers and followers.
As provider of our social media page, we do not collect or process any additional personal data from your use of our services. The pages are for information and communication purposes only.
The social networks named above transfer your data to third countries qualified according to the GDPR, in which no EU data protection level is established. By using these networks, your personal data will be collected, transferred, stored, disclosed and used by these providers and transferred, stored and used in the United States and any other country in which the providers do business, regardless of your place of residence.
Although network operators are non-European providers with a European office only in Ireland, they are bound by the GDPR. This applies, for example, to your rights to access, block or erase data.
If you are located in one of the designated countries of the GDPR, you also have the right to lodge a complaint with the Irish Data Protection Officer:
The social network operators may use analysis tools such as Instagram Insights or Google Analytics for evaluation. Widgets integrated into websites and the use of cookies enable network operators to record your visits to these websites and assign them to your profile. This data can be used to offer content or advertising tailored to you.
Via YouTube buttons or widgets integrated into websites and the use of cookies, network operators can record your visits to these websites and trace them back to your profile. This data can be used to tailor content or advertising to you.
Finally, the network operators also receive information if, for example, you view content, even if you have not created an account. This “log data” may include the IP address, browser type, operating system, information about the previously visited website and the pages you accessed, your location, your mobile phone provider, the end device you are using (including device ID and application ID), the search terms you used and cookie information.
KfW has no knowledge of the content of your data transmitted to the social network operators and cannot provide any information about what data about you is stored through the use of the respective services. The manner, in which the data from visits to social network pages is used for their own purposes, the extent to which activities on the pages are assigned to individual users, how long the network operators store this data and whether data from a visit to the pages is passed on to third parties is not conclusively and clearly stated by the respective network operators and is not known to KfW.
Any analysis tools used by the social network operators for KfW’s account have not been commissioned, approved or otherwise supported by KfW in any way, nor will the data obtained from the analysis be made available to it. Only certain non-personal information about social media activity can be viewed by KfW via its account. Furthermore, KfW has no way of preventing or discontinuing the use of such tools on its social media accounts. KfW has no influence on the scope of the data processed by the network operators, the type of processing and use or the transfer of this data to third parties. In this respect, it also has no effective control options.
KfW has no influence on the data processed by Instagram, the type of processing and use or the disclosure of this data to third parties. In this respect, it also has no effective control options. Given the data protection problems, KfW does not place advertisements on Instagram and therefore does not actively use the data collected by Instagram to manage its communication in a targeted manner. KfW also refrains from placing widgets on its websites in this context.
You can limit the processing and visibility of your data in your account navigation under “Settings/History and Data Protection” or the menu items listed there. With mobile devices (smartphones and tablet computers), you can use the settings to limit the network operators’ access to contact and calendar data, photos, location data, etc. However, this depends on the operating system used.
KfW operates its own online presence on the aforementioned social media channels (hereinafter “offers”).
On the basis of the provisions of the General Data Protection Regulation (hereinafter “GDPR”), KfW’s offers pursuant to Art. 35 para. 1 GDPR are subject to data protection impact assessment, if a form of processing, in particular when using new technologies, is likely to result in a high risk to the rights and freedoms of natural persons due to the nature, scope, circumstances and purposes of the processing.
KfW’s own social media services do not trigger the consequence described in Art. 35 GDPR due to the very limited scope of its own data processing (see in this respect under 5). However, some of the posts also have a direct personal reference. When creating and publishing its own content, KfW therefore ensures that, in addition to the copyright of the photos, the image rights of the persons depicted are also taken into account. If KfW posts refer to other social media users (by reposting or mentioning them) or show natural persons in videos uploaded by KfW, only the data that they themselves voluntarily provided will be processed.
However, KfW’s use of social media has far-reaching effects, particularly with regard to the evaluation of data by the respective platform operators for advertising purposes. This represents high-risk processing, for which a data protection impact assessment must be carried out.
By using a social media account, the respective user comes under systematic monitoring by the network operators listed above. Sensitive data such as political views, sexual orientation and health problems can also be disclosed, which can be linked and used to create a personality profile. Particularly vulnerable persons such as minors, for example, can also be social media users and therefore may also be affected. Sensitive data may be collected from them, too, through the collection of log data, for example the previously visited websites or the location data of the user.
This is all the more important, as the relevant social networks cannot be checked or can only be checked to a limited extent. Since the data of users based in Germany is not processed within Germany, but in Ireland and third countries, the barriers to accessing (judicial) legal protection are greater than with a company based in Germany.
In this regard, KfW assumes that public bodies that use a social network for public relations and to provide general information have their part of responsibility.
Responsibility in this context does not mean that KfW confirms or guarantees the data protection conformity of the products of social media networks. It cannot do this under the given circumstances. Instead, responsibility means that KfW makes itself and others aware of the risks of social networks. Social networks currently need to be improved in many respects from a data protection perspective. This is why social media users are shown alternative, more data protection-friendly communication channels by referring to KfW’s website and legally compliant social media platforms (XING and Mastodon).
Users are also made aware of the risks generally associated with the use of social media.
KfW has committed itself to these measures in its usage concept. The advantages and disadvantages of using social media are regularly evaluated, taking into account the network operators’ terms of use.
Social media use is therefore embedded in a package of measures. Against this background, KfW’s assessment of the consequences of its use is as follows:
a) Risk identification
The risks associated with the use of social media described are essentially independent of KfW’s own use. KfW’s posts on the offers themselves do not relate to personal data in the vast majority of cases, but instead their own relevant content is disseminated.
After all, the data processed through interaction with the respective account on social media or other accounts is already publicly accessible or freely available on the Internet.
However, through its appearance on KfW’s respective offer and the interrelationship, the content is made available to a wider/ "more specific" public and may therefore attract greater attention and further dissemination than without this interaction.
The fact that KfW connects with other accounts on social media also creates additional cross connections and information about the respective user of the account. Finally, log data is also collected by the respective platform provider when the user passively reads the page.
There is also a risk of identity theft, discrimination, reputational damage, financial loss or disclosure of sensitive data.
b) Risk analysis
The expansion of the distribution range and the enlargement of the link options favours the processing of the data for other purposes by the operator of the respective social media network and a secret profiling. Openness to visitor posts can also lead to adverse social consequences such as inappropriate or discriminatory comments or the dissemination of sensitive data.
Although these damages may be considered to be material when caused by the respective platform operator, they will only be increased to a very limited extent by the respective offer from KfW. Since the respective posts are also published elsewhere, there is no compulsion to participate in one of the social media networks.
c) Risk assessment
The risk assessment is based on the criteria of the severity of the damage and the probability of occurrence.
Overall, the additional risk caused by the offers can be classified as low to medium.
KfW also actively contributes to further reducing risk. This includes, in particular, providing information about KfW’s respective privacy notice and the alternative offer provided. The data subjects are free to choose which form of information source they wish to operate and use.
However, the majority of these measures lie within the user’s sphere of influence: for example, there is no obligation to use your real name when using social media. In addition, the users can protect themselves to a certain extent through various options, such as deleting their browser history, deactivating cookies, and not sharing their location when using photos.
In addition, continuous editorial support enables KfW to intervene in the event of any slanderous or defamatory comments up to and including blocking the account of the “disruptive” user.
d) Conclusion
KfW’s offers on the social media channels mentioned are justifiable in view of the risks described and the binding measures stipulated. KfW also undertakes to monitor further developments and, if necessary, to repeat and further develop the appraisal carried out here.
We would like to point out to users that the KfW social media profiles are only an additional option for contacting or receiving information from KfW Group. Alternatively, the information offered via KfW social media profiles can also be accessed via the corresponding links on our website at www.kfw.de or on the other linked websites. Alternatively, such information can also be accessed via Xing.
You can always contact our central inbox at with all enquiries. Press enquiries can be sent to . You can reach the social media team at .
You can contact KfW by telephone on +49 69 7431 0.
Address:
KfW
Palmengartenstrasse 5-9
60325 Frankfurt am Main
Germany
An overview of the various ways to contact KfW can be found on the contact webpage.
We evaluate this usage concept once a year with regard to the scope and manner of social media use. This evaluation takes into account the usage figures and ranges as well as the target group structure and usage behaviour of the networks.
We make users aware of the risks to their right to informational self-determination on a regular basis.
You can find KfW’s privacy notice here.
Information on the exercise of your data subject rights regarding access, restriction, rectification, erasure, data portability, revocation and objection can be found in KfW’s privacy notice under point 7 et seqq.
Further information on data protection issues can be found on the websites of the Federal Commissioner for Data Protection and Freedom of Information here.
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