Data Privacy Policy

1. An overview of data protection

 

General information

 

The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.

 

Data recording on this website

 

Who is the responsible party for the recording of data on this website (i.e., the “controller”)?

 

The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.

 

How do we record your data?

 

We collect your data as a result of your sharing of your data with us. This may, for instance, be information you enter into our contact form. Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.

 

What are the purposes we use your data for?

 

A portion of the information is generated to guarantee the error-free provision of the website. Other data may be used to analyze your user patterns.

 

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.

 

Please do not hesitate to contact us at any time if you have questions about this or any other data protection-related issues.

 

2. Hosting and Content Delivery Networks (CDN)

WIX

 

We host our website at Wix.com Ltd, 40 Namal Tel Aviv St., Tel Aviv 6350671, Israel (hereinafter: “WIX”). WIX is a tool for creating and hosting websites. When you visit our website, WIX analyses user behavior, visitor sources, region of website visitors and visitor numbers. The WIX stores cookies on your browser, which are necessary for the presentation of the website and to ensure security (necessary cookies).

The data is stored on the servers of WIX in Israel. Israel is considered to be a third country that is safe from data protection laws. This means that Israel has a level of data protection equivalent to that of the European Union. Details can be found in the privacy policy of WIX: https://de.wix.com/about/privacy. The WIX is used on the basis of Art. 6(1)(f) GDPR. We have a legitimate interest the most reliable presentation of our website. If consent has been requested, processing will be performed exclusively on the basis of Art. 6 (1)(a) GDPR; consent may be revoked at any time.

 

Execution of a contract data processing agreement

 

We have concluded a contract with the WIX for order processing. This is a data protection contract, which guarantees that WIX processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

3. General information and mandatory information

 

Data protection

 

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration. Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected. We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access. Information about the responsible party (referred to as the “controller” in the GDPR)

 

The data processing controller on this website is:

 

Anna Sibel Tschapke

Rudi-Dutschke-Str. 23

10969 Berlin

Phone: +49 (0)177 893 4785

Email: anna@klafreit.com

 

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).

 

Storage duration

 

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

 

Information on data transfer to the USA and other non-EU countries

 

Among other things, we use tools of companies domiciled in the United States or other from a data protection perspective non-secure non-EU countries. If these tools are active, your personal data may potentially be transferred to these non-EU countries and may be processed there. We must point out that in these countries, a data protection level that is comparable to that in the EU cannot be guaranteed. For instance, U.S. enterprises are under a mandate to release personal data to the security agencies and you as the data subject do not have any litigation options to defend yourself in court. Hence, it cannot be ruled out that U.S. agencies (e.g., the Secret Service) may process, analyze, and permanently archive your personal 5 / 19data for surveillance purposes. We have no control over these processing activities.

 

Revocation of your consent to the processing of data

 

A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

 

Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)

 

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21(1) GDPR). IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).

 

Right to log a complaint with the competent supervisory agency

 

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

 

Right to data portability

 

You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

 

SSL and/or TLS encryption

 

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line. If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

 

Encrypted payment transactions on this website

 

If you are under an obligation to share your payment information (e.g. account number if you give us the authority to debit your bank account) with us after you have entered into a fee-based contract with us, this information is required to process payments. Payment transactions using common modes of paying (Visa/MasterCard, debit to your bank account) are processed exclusively via encrypted SSL or TLS connections. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line. If the communication with us is encrypted, third parties will not be able to read the payment information you share with us.

 

Information about, rectification and eradication of data

 

Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.

 

Right to demand processing restrictions

 

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:

 

In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.

 

If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data. If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.

 

If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

 

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

 

Rejection of unsolicited e-mails

 

We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in our Site Notice to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.

 

 

4. Recording of data on this website

 

Cookies

 

Our websites and pages use what the industry refers to as “cookies.” Cookies are small text files that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser. In some cases, it is possible that third-party cookies are stored on your device once you enter our site (thirdparty cookies). These cookies enable you or us to take advantage of certain services offered by the third party (e.g., cookies for the processing of payment services). Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g., the shopping cart function or the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages. Cookies, which are required for the performance of electronic communication transactions (required cookies) or for the provision of certain functions you want to use (functional cookies, e.g., for the shopping cart function) or those that are necessary for the optimization of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of cookies to ensure the technically error-free and optimized provision of the operator’s services. If your consent to the storage of the cookies has been requested, the respective cookies are stored exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR); this consent may be revoked at any time. You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited. In the event that third-party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.

 

Server log files

 

The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

 

The type and version of browser used

The used operating system

Referrer URL

The hostname of the accessing computer

The time of the server inquiry

The IP address

 

This data is not merged with other data sources.

 

This data is recorded on the basis of Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.

 

Contact form

 

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent. 8 / 19The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or on your agreement (Art. 6(1)(a) GDPR) if this has been requested. The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions, in particular retention periods.

 

Request by e-mail, telephone, or fax

 

If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent. These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained. The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.

 

Use of Chatbots

 

We use chatbots to communicate with you. Chatbots have the capability to respond to your questions and other entries without the assistance of humans. To do this, chatbots analyze your entries and other data to give matching responses (e.g., names, email addresses and other contact information, customer numbers and other identification, orders, and chat progresses). The chatbot can also register your IP address, log files, location information and other meta data. The data is archived on the servers of the chatbot provider. It is possible to generate user profiles based on the recorded data. Moreover, the data can be used to display interest-related advertising if the other legal requirements are met (in particular if consent has been obtained). Moreover, it is possible to link chatbots to analytical and advertising tools. The recorded data can also be used to improve our chatbots and their response patterns (machine learning). We or the chatbot operator retain the data you enter until you ask us to delete it, revoke your consent to archive it or if the purpose for the data storage is no longer in effect (e.g., once your inquiry has been fully processed). This does not affect mandatory statutory provisions – in particular, retention time frames. The legal basis for the use of chatbots is Art. 6(1)(b) GDPR, if the chatbot is used to negotiate a contract or in conjunction with the fulfillment of a contract. If pertinent consent has been requested, the processing shall occur exclusively on the basis of Art. 6(1)(a) GDPR; the consent may be revoked at any time. In all other cases, the use is based on our legitimate interest in the most effective client communication possible (Art. 6(1)(f) GDPR).

 

The comment function on this website

 

When you use the comment function on this website, information on the time the comment was generated and, if you are not posting anonymously, the username you have selected will be archived in addition to your comments.

 

Storage of the IP address

 

Our comment function stores the IP addresses of all users who enter comments. Given that we do not review the comments prior to publishing them, we need this information in order to take action against the author in the event of rights violations, such as defamation or propaganda.

 

Storage period for comments

 

Comments and any affiliated information shall be stored by us and remain on this website until the content the comment pertained to has been deleted in its entirety or if the comments had to be deleted for legal reasons (e.g., insulting comments).

 

Legal basis

 

Comments are stored on the basis of your consent (Art. 6(1)(a) GDPR). You have the right to revoke at any time any consent you have already given us. To do so, all you are required to do is sent us an informal notification via e-mail. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

 

 

5. Social media

 

LinkedIn plug-in

 

This website uses functions of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. Any time you access a page of this website that contains functions of LinkedIn, a connection to LinkedIn’s servers is established. LinkedIn is notified that you have visited this website with your IP address. If you click on LinkedIn’s “Recommend” button and are logged into your LinkedIn account at the time, LinkedIn will be in a position to allocate your visit to this website to your user account. We have to point out that we as the provider of the websites do not have any knowledge of the content of the transferred data and its use by LinkedIn. The use of the LinkedIn plug-in is based on Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in being as visible as possible on social media. If a respective declaration of consent has been obtained, the data shall be processed exclusively on the basis of Art. 6(1)(a) GDPR. This declaration of consent may be revoked at any time. Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission.

Details can be found here: https://www.linkedin.com/help/linkedin/answer/62538/datenubertragung-aus-der-eu-dem-ewr-und-derschweiz?lang=en. For further information on this subject, please consult LinkedIn’s Data Privacy Declaration at: https://www.linkedin.com/legal/privacy-policy.

 

XING plug-in

 

This website uses functions of the XING network. The provider is the New Work SE, Dammtorstraße 30, 20354 Hamburg, Germany. Any time one of our sites/pages that contains functions of XING is accessed, a connection with XING’s servers is established. As far as we know, this does not result in the archiving of any personal data. In particular, the service does not store any IP addresses or analyze user patterns. 10 / 19Data are stored and analyzed on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the highest possible visibility on social media. If a respective declaration of consent has been obtained, the data will be processed exclusively on the basis of Art. 6(1)(a) GDPR. Any such consent may be revoked at any time. For more information on data protection and the XING share button please consult the Data Protection Declaration of Xing at: https://www.xing.com/app/share?op=data_protection.

 

6. Analysis tools and advertising

 

Google Ads

 

The website operator uses Google Ads. Google Ads is an online promotional program of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. Google Ads enables us to display ads in the Google search engine or on third-party websites, if the user enters certain search terms into Google (keyword targeting). It is also possible to place targeted ads based on the user data Google has in its possession (e.g., location data and interests; target group targeting). As the website operator, we can analyze these data quantitatively, for instance by analyzing which search terms resulted in the display of our ads and how many ads led to respective clicks. The use of Google Ads is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in marketing the operator’s services and products as effectively as possible. Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://policies.google.com/privacy/frameworks and https://privacy.google.com/businesses/controllerterms/mccs/.

 

Facebook Pixel

 

To measure conversion rates, this website uses the visitor activity pixel of Facebook. The provider of this service is Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Facebook’s statement, the collected data will be transferred to the USA and other third-party countries too. This tool allows the tracking of page visitors after they have been linked to the website of the provider after clicking on a Facebook ad. This makes it possible to analyze the effectiveness of Facebook ads for statistical and market research purposes and to optimize future advertising campaigns. For us as the operators of this website, the collected data is anonymous. We are not in a position to arrive at any conclusions as to the identity of users. However, Facebook archives the information and processes it, so that it is possible to make a connection to the respective user profile and Facebook is in a position to use the data for its own promotional purposes in compliance with the Facebook Data Usage Policy. This enables Facebook to display ads on Facebook pages as well as in locations outside of Facebook. We as the operator of this website have no control over the use of such data. The use of Facebook Pixel is based on Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in effective advertising campaigns, which also include social media. If a corresponding agreement has been requested (e.g., an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6(1)(a) GDPR; the agreement can be revoked at any time. Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: 11 / 19https://www.facebook.com/legal/EU_data_transfer_addendum und https://de-de.facebook.com/help/566994660333381. Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook, we and Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook. The processing by Facebook that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found under: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook tool and for the privacy-secure implementation of the tool on our website. Facebook is responsible for the data security of Facebook products. You can assert data subject rights (e.g., requests for information) regarding data processed by Facebook directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook. In Facebook’s Data Privacy Policies, you will find additional information about the protection of your privacy at: https://www.facebook.com/about/privacy/. You also have the option to deactivate the remarketing function “Custom Audiences” in the ad settings section under https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you first have to log into Facebook. If you do not have a Facebook account, you can deactivate any user-based advertising by Facebook on the website of the European Interactive Digital Advertising Alliance: http://www.youronlinechoices.com/de/praferenzmanagement/.

 

7. Newsletter

 

Newsletter data

 

If you would like to subscribe to the newsletter offered on this website, we will need from you an e-mail address as well as information that allow us to verify that you are the owner of the e-mail address provided, and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis. We shall use such data only for the sending of the requested information and shall not share such data with any third parties. The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent (Art. 6(1)(a) GDPR). You may revoke the consent you have given to the archiving of data, the e-mail address and the use of this information for the sending of the newsletter at any time, for instance by clicking on the “Unsubscribe” link in the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date. The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter or after the purpose has ceased to apply. We reserve the right to delete or block e-mail addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest in accordance with Art. 6(1)(f) GDPR. After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) 12 / 19GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.

 

Sendinblue

 

This website uses Sendinblue for the sending of newsletters. The provider is the Sendinblue GmbH, Köpenicker Straße 126, 10179 Berlin, Germany. Sendinblue services can, among other things, be used to organize and analyze the sending of newsletters. The data you enter for the purpose of subscribing to the newsletter are archived on Sendinblue’s servers in Germany.

 

Data analysis by Sendinblue

 

Sendinblue enables us to analyze our newsletter campaigns. For instance, it allows us to see whether a newsletter message has been opened and, if so, which links may have been clicked. This enables us to determine, which links drew an extraordinary number of clicks. Moreover, we are also able to see whether once the e-mail was opened or a link was clicked, any previously defined actions were taken (conversion rate). This allows us to determine whether you have made a purchase after clicking on the newsletter. Sendinblue also enables us to divide the subscribers to our newsletter into various categories (i.e., to “cluster” recipients). For instance, newsletter recipients can be categorized based on age, gender, or place of residence. This enables us to tailor our newsletter more effectively to the needs of the respective target groups. If you do not want to permit an analysis by Sendinblue, you must unsubscribe from the newsletter. We provide a link for you to do this in every newsletter message. Moreover, you can also unsubscribe from the newsletter right on the website. For detailed information on the functions of Sendinblue please follow this link: https://www.sendinblue.com/newsletter-software/.

 

Legal basis

 

The data is processed based on your consent (Art. 6(1)(a) GDPR). You may revoke any consent you have given at any time by unsubscribing from the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place prior to your revocation.

 

Storage period

 

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected. After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest. For more details, please consult the Data Protection Regulations of Sendinblue at: 13 / 19https://de.sendinblue.com/datenschutz-uebersicht/.

 

Execution of a contract data processing agreement

 

We have executed a contract with Sendinblue, in which we require Newsletters2Go to protect our customers’ data and to refrain from sharing such data with third parties.

 

8. Plug-ins and Tools

 

YouTube

 

This website embeds videos of the website YouTube. The website operator is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. If you visit a page on this website into which a YouTube has been embedded, a connection with YouTube’s servers will be established. As a result, the YouTube server will be notified, which of our pages you have visited. Furthermore, YouTube will be able to place various cookies on your device or comparable technologies for recognition (e.g. device fingerprinting). In this way YouTube will be able to obtain information about this website’s visitors. Among other things, this information will be used to generate video statistics with the aim of improving the user-friendliness of the site and to prevent attempts to commit fraud. If you are logged into your YouTube account while you visit our site, you enable YouTube to directly allocate your browsing patterns to your personal profile. You have the option to prevent this by logging out of your YouTube account. The use of YouTube is based on our interest in presenting our online content in an appealing manner. Pursuant to Art. 6(1)(f) GDPR, this is a legitimate interest. If a corresponding agreement has been requested, the processing takes place exclusively on the basis of Art. 6(1)(a) GDPR; the agreement can be revoked at any time. For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy under: https://policies.google.com/privacy?hl=en.

 

Google Maps

 

This website uses the mapping service Google Maps. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. To enable the use of the Google Maps features, your IP address must be stored. As a rule, this information is transferred to one of Google’s servers in the United States, where it is archived. The operator of this website has no control over the data transfer. In case Google Maps has been activated, Google has the option to use Google web fonts for the purpose of the uniform depiction of fonts. When you access Google Maps, your browser will load the required web fonts into your browser cache, to correctly display text and fonts. We use Google Maps to present our online content in an appealing manner and to make the locations disclosed on our website easy to find. This constitutes a legitimate interest as defined in Art. 6(1)(f) GDPR. If a respective declaration of consent has been obtained, the data shall be processed exclusively on the basis of Art. 6(1)(a) GDPR. This declaration of consent may be revoked at any time. Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: 14 / 19https://privacy.google.com/businesses/gdprcontrollerterms/ and https://privacy.google.com/businesses/gdprcontrollerterms/sccs/. For more information on the handling of user data, please review Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en.

 

OpenStreetMap

 

We are using the mapping service provided by OpenStreetMap (OSM). The provider of this service is the Open-Street-Map Foundation (OSMF), 132 Maney Hill Road, Sutton Coldfield, West Midlands, B72 1JU, United Kingdom. When you visit any website, into which OpenStreetMap has been embedded, your IP address and other information concerning your behavior patterns on this website will be transferred to the OSMF. Under certain circumstances, OpenStreetMap will save cookies in your browser or uses comparable technologies for recognition. Furthermore, your location may be recorded if you have permitted this in your device settings, for instance on your cell phone. The provider of this website has no control over this type of data transfer. For details, please consult the Data Privacy Policy of OpenStreetMap under the following link: https://wiki.osmfoundation.org/wiki/Privacy_Policy. We use OpenStreetMap with the objective of ensuring the attractive presentation of our online offers and to make it easy for visitors to find the locations we specify on our website. This establishes legitimate grounds as defined in Art. 6(1)(f) GDPR. If a corresponding agreement has been requested (e.g. an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6(1)(a) GDPR; the agreement can be revoked at any time.

 

Google reCAPTCHA

 

We use “Google reCAPTCHA” (hereinafter referred to as “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. The purpose of reCAPTCHA is to determine whether data entered on this website (e.g., information entered into a contact form) is being provided by a human user or by an automated program. To determine this, reCAPTCHA analyzes the behavior of the website visitors based on a variety of parameters. This analysis is triggered automatically as soon as the website visitor enters the site. For this analysis, reCAPTCHA evaluates a variety of data (e.g., IP address, time the website visitor spent on the site or cursor movements initiated by the user). The data tracked during such analyses are forwarded to Google. reCAPTCHA analyses run entirely in the background. Website visitors are not alerted that an analysis is underway. Data are stored and analyzed on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the protection of the operator’s websites against abusive automated spying and against SPAM. If a respective declaration of consent has been obtained, the data will be processed exclusively on the basis of Art. 6(1)(a) GDPR. Any such consent may be revoked at any time. For more information about Google reCAPTCHA please refer to the Google Data Privacy Declaration and Terms Of Use under the following links: https://policies.google.com/privacy?hl=en and https://policies.google.com/terms?hl=en.

 

9. eCommerce and payment service providers

 

Processing of data (customer and contract data)

 

We collect, process, and use personal data only to the extent necessary for the establishment, content organization or change of the legal relationship (data inventory). These actions are taken on the basis of Art. 6(1)(b) GDPR, which permits the processing of data for the fulfilment of a contract or pre-contractual actions. We collect, process, and use personal data concerning the use of this website (usage data) only to the extent that this is necessary to make it possible for users to utilize the services and to bill for them. The collected customer data shall be eradicated upon completion of the order or the termination of the business relationship. This shall be without prejudice to any statutory retention mandates.

 

Data transfer upon closing of contracts for online stores, retailers, and the shipment of merchandise

 

We share personal data with third parties only if this is necessary in conjunction with the handling of the contract; for instance, with companies entrusted with the shipment of goods or the financial institution tasked with the processing of payments. Any further transfer of data shall not occur or shall only occur if you have expressly consented to the transfer. Any sharing of your data with third parties in the absence of your express consent, for instance for advertising purposes, shall not occur. The basis for the processing of data is Art. 6(1)(b) GDPR, which permits the processing of data for the fulfillment of a contract or for pre-contractual actions. Data transfer upon closing of contracts for services and digital content We share personal data with third parties only if this is necessary in conjunction with the handling of the contract; for instance, with the financial institution tasked with the processing of payments. Any further transfer of data shall not occur or shall only occur if you have expressly consented to the transfer. Any sharing of your data with third parties in the absence of your express consent, for instance for advertising purposes, shall not occur. The basis for the processing of data is Art. 6(1)(b) GDPR, which permits the processing of data for the fulfillment of a contract or for pre-contractual actions.

 

Credit checks

 

We may conduct a credit check in the event that purchases are made on account or based on other payment terms that require us to extend credit (scoring). For this purpose, we transmit the data you have entered (e.g., name, address, age, or banking information) to a credit information agency. Based on this data, the probability of non-payment is determined. If the likelihood of non-payment is excessive, we may reject the respective payment term. The credit check is performed on the basis of contractual fulfillment (Art. 6(1)(b) GDPR) and to avert nonpayment (justified interest pursuant to Art. 6(1)(f) GDPR). If consent has been obtained, the credit check shall be performed on the basis of this consent (Art. 6(1)(a) GDPR); the consent may be revoked at any time.

 

Payment services

 

We integrate payment services of third-party companies on our website. When you make a purchase from us, your payment data (e.g. name, payment amount, bank account details, credit card number) are processed by the payment service provider for the purpose of payment processing. For these transactions, the respective contractual and data protection provisions of the respective providers apply. The use of the payment service providers is based on Art. 6(1)(b) GDPR (contract processing) and in the interest of a 16 / 19smooth, convenient, and secure payment transaction (Art. 6(1)(f) GDPR). Insofar as your consent is requested for certain actions, Art. 6(1)(a) GDPR is the legal basis for data processing; consent may be revoked at any time for the future. We use the following payment services / payment service providers within the scope of this website:

 

PayPal

 

The provider of this payment service is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal”). Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.paypal.com/de/webapps/mpp/ua/pocpsa-full. Details can be found in PayPal’s privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

 

Klarna

 

The supplier is Klarna AB, Sveavägen 46, 111 34 Stockholm, Sweden (hereinafter “Klarna“). Klarna offers various payment options (e.g., hire purchase). If you choose to pay with Klarna (Klarna checkout solution), Klarna will collect various personal data from you. Klarna uses cookies to optimize the use of Klarna checkout solution. For details on the use of Klarna cookies, please see the following link: https://cdn.klarna.com/1.0/shared/content/policy/cookie/de_de/checkout.pdf. Details can be found in Klarna’s privacy policy under the following link: https://www.klarna.com/de/datenschutz/.

 

10. Online-based Audio and Video Conferences (Conference tools)

 

Data processing

 

We use online conference tools, among other things, for communication with our customers. The tools we use are listed in detail below. If you communicate with us by video or audio conference using the Internet, your personal data will be collected and processed by the provider of the respective conference tool and by us. The conferencing tools collect all information that you provide/access to use the tools (email address and/or your phone number). Furthermore, the conference tools process the duration of the conference, start and end (time) of participation in the conference, number of participants and other “context information” related to the communication process (metadata). Furthermore, the provider of the tool processes all the technical data required for the processing of the online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or loudspeaker and the type of connection. Should content be exchanged, uploaded, or otherwise made available within the tool, it is also stored on the servers of the tool provider. Such content includes, but is not limited to, cloud recordings, chat/ instant messages, voicemail uploaded photos and videos, files, whiteboards, and other information shared while using the service. Please note that we do not have complete influence on the data processing procedures of the tools used. Our possibilities are largely determined by the corporate policy of the respective provider. Further information 17 / 19on data processing by the conference tools can be found in the data protection declarations of the tools used, and which we have listed below this text.

 

Purpose and legal bases

 

The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6(1)(b) GDPR). Furthermore, the use of the tools serves to generally simplify and accelerate communication with us or our company (legitimate interest in the meaning of Art. 6(1)(f) GDPR). Insofar as consent has been requested, the tools in question will be used on the basis of this consent; the consent may be revoked at any time with effect from that date.

 

Duration of storage

 

Data collected directly by us via the video and conference tools will be deleted from our systems immediately after you request us to delete it, revoke your consent to storage, or the reason for storing the data no longer applies. Stored cookies remain on your end device until you delete them. Mandatory legal retention periods remain unaffected. We have no influence on the duration of storage of your data that is stored by the operators of the conference tools for their own purposes. For details, please directly contact the operators of the conference tools. Conference tools used We employ the following conference tools:

 

Zoom

 

We use Zoom. The provider of this service is Zoom Communications Inc, San Jose, 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA. For details on data processing, please refer to Zoom’s privacy policy: https://zoom.us/en-us/privacy.html. Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://zoom.us/de-de/privacy.html.

 

Execution of a contract data processing agreement

 

We have entered into a contract data processing agreement with the provider of Zoom and implement the strict provisions of the German data protection agencies to the fullest when using Zoom.