PRIVACY POLICY

ROOM 3D COMMUNICATIONS SA. (“ROOMco”, “we”, “us” or “our'') is committed to protecting and respecting your privacy. Accordingly, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Privacy Policy (“Privacy”).

When you visit our website and social media channels (the “Website” or “Site”) and/or register and/or  log in and use the ROOM platform and services (“ROOM” or the “Service”) a variety of personal information will be collected. 

Personal data means any information relating to an identified or identifiable natural person and comprises data that can be used to personally identify you, such as your name, address, email addresses, IP address, or user behaviour. 

This General Privacy Policy explains how we process personal data in connection with the use of ROOM, including our websites, mobile applications and all our external online presences (e.g. our social media profiles) as well as in the context of the provision of our services. It is the basis of our actions and an integral part of the business relationship with you and all  visitors and users (collectively “User” or “Users”) of our Service and Site, including, but not limited to, users who browse the Site, customers,contractual partners, and/or third parties.

In addition to this Privacy Policy, please read our Terms and Conditions for detailed information regarding your use of ROOM.

We herewith advise you that the transmission of data via the internet may be prone to security gaps. It is not possible to completely protect data against third-party access.

Content overview

Overview of the data processing

The following information will provide you with an overview of what will happen with your personal data when you visit the Site and/or use ROOM. 

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 Privacy below.

We process personal data in accordance with the provisions of the European General Data Protection Regulation (GDPR) and the national german regulations on data protection including, in particular, the Act on Protection against Misuse of Personal Data in Data Processing (Federal Data Protection Act - BDSG). 

Responsible party

The responsible party for the recording of data on the website and in the service (referred to as “controller” in the GDPR) is:

ROOM 3D COMMUNICATIONS SA
14-16 Avenue Pasteur
L-2310 Luxembourg

E-Mail: dataprotection@room3d.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.).

How do we record your data?

We receive certain information when you visit our Site and/or use ROOM. This includes:

Information you provide to us

We receive your data as a result of your sharing of your data with us. You may give us your personal data, contact and communications data by filling in forms, by registering, creating a ROOM account, requesting a demo, subscribe to any of the services or publications; request marketing or our newsletter to be sent to you. This includes personal information you provide when you give us feedback or contact us by phone, email or otherwise through use of our Site and or Service. 

We may collect, use and process different kinds of personal data about you, grouped together as follows:

  • Personal data (e.g. names, addresses)
  • Username and password, if applicable
  • Contact data (e.g. e-mail, telephone numbers) and Communications data ( Information about your communications with us, including relating to support questions and other inquiries.)
  • Content data (e.g. entries in online forms) 
  • Contacts and calendar integrations
    Contact information added by Users to create a list of participants to invite to a ROOM meeting. This may include contact information that Users  integrate from a third-party app. Furthermore Users can also integrate their calendars from other providers into their ROOM Account.
  • Meeting data
    This is information related to the virtual meetings you host or attend, including audio and visual recordings of those events, actions you take, and copies of chat logs between you and other users; 
  • Content
    Content generated in meetings, chats or messages that take place in ROOM, which may include audio, video, in-meeting messages, chat messaging content, transcriptions, written feedback, responses to polls and Q&A, and files, as well as related context, such as User name, or meeting agenda. Content may contain the voice and image, depending on what you choose to share, your settings.

Information we collect automatically

Other data shall be recorded by our IT systems automatically when you access the Site and/or the Service. or after you consent to its recording during your visit the Website and/ or use of the Service. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This is statistical data, and does not identify any individual. We also use your IP address to help diagnose problems with our Site and administer the Site.

We may collect:

  • Meta/communication data (e.g. device information, IP addresses)
  • Device Information
    Information about the computers and other devices you use when interacting with the Site and/or ROOM, which may include information about the speakers, microphone, camera, OS version, hard disk ID, PC name, MAC address, IP address (which may be used to infer general location at a city or country level), device attributes (like operating system version and battery level), WiFi information, and other device information (like Bluetooth signals).
  • Usage data (e.g. websites visited, interest in content, access times)
    Information about how users and their devices interact with the Site and inside ROOM, e.g. when Users join and leave a room; whether Users sent messages and who they message with; performance data; mouse movements, clicks, keystrokes or actions (such as mute/unmute or video on/off), and other User inputs that help us to understand feature usage, improve design, and suggest features; which third-party apps Users add to a ROOM session and what information and actions the app is authorised to access and perform; features used (e.g. screen sharing); and other usage information and metrics. This also includes information about when and how Users visit and interact with our Site, including what pages they accessed, their interaction with the website features, and whether or not they signed up for ROOM.
  • Settings
    Information associated with the preferences which may include audio and video settings, recording file location, screen sharing settings, and other settings and configuration information.
  • Contract data (e.g. subject matter of contract, term, customer category)
  • Payment data (e.g. bank details, invoices, payment history)

Information we receive from other sources, analysis tools and tools provided by third parties

We may receive information about you from other sources, including from other users and third parties, and combine that information with the other information we have about you. For example, if you interact with our social media account on another platform, we may receive certain information about you like your username on that platform.

There is a possibility that your browsing patterns will be statistically analysed when you visit our Website. Such analyses are performed primarily with what we refer to as analysis programs from third-party marketing, advertising and analytics providers.These providers may collect information about your activities on our Website through third-party cookies placed on the Website. To opt out of the use of third-party cookies that share data with these providers, visit our Cookie Settings via the button in the lower left corner of the screen. Where required by law, we will first obtain your consent before engaging in the marketing or advertising activities. For detailed information about these analysis programs please consult our Privacy below. 

ROOM serves only third-party cookies that are necessary for technical support and to deliver the Service. There are no interest-based advertising cookies on ROOM. For detailed information about these analysis programs in ROOM please consult our Privacy Policy below. 

Access via social network or app store: Should you sign into or access any of the Site via a social network or an app store (or app marketplace), or interact with us via a social network you may be granting the social network and/or app store permission to share your email address and any other personal information with us, including personal data, contact data, profile data. When you access and use the Site through or on a social network or app store, we may collect usage data, as well as other personal information from your social network and app store in accordance with the social network or app store's terms of use.

Who can see and share your personal data in ROOM?

By joining a meeting and using ROOM Beta, others, including third parties outside the meeting, may be able to see content and information that you share.

The Host and the other Participants in a meeting may be able to see your username, and profile picture (so far applicable), your voice and image, depending on what you choose to share and your settings. The Host and the Participants can also see and record or save meeting content, messages sent to everyone or to them directly, and files, whiteboards, or every other information shared during a meeting. The Host may also be able to see responses to Q&A and polls generated during the meeting. Live polls can also be accessed by all, depending on the option selected.

Third-Party Apps and Integrations: Registered Users (Account holders ) can add third-party apps to their ROOM profil/account, and can also control whether their users can add and use certain third-party apps, including in meetings and chats hosted on their account. Depending on their settings,the Hosts and their users and guests may share your personal information and content with third-party apps and integrations that they approve, which may include all of the personal information listed above that is available to the hosts and attendees, such as account information, profile and contact information, registration information, attendee list, settings, content, product usage and device information.

Other meeting participants may be able to see the third-party app you use in a meeting if the third-party app receives real-time features and information from the meeting.

Third-party developers may also integrate or embed ROOM Meetings into their Website or app experiences, or create versions of ROOM that allow access to ROOM through a third-party app.

Personal information shared by Users with third-party apps and integrations is collected and processed in accordance with the terms and privacy policies of these third-party apps and integrations. Third-party apps and integrations: see below

A portion of the information is generated to guarantee the error free provision of the Site and the Service. Other data may be used to analyse your user patterns. We collect information to provide better services to all our Users. We do not sell personal information to third parties but only use it to deliver the Site, to identify and troubleshoot problems and improve the Site and the service. 

We will use your information

  • to provide and maintain our site and our Service
    We need and use this information to deliver the Service (e.g. to register you in the Service, to respond to requests)
  • for product research and development
    We also need this information to ensure our Site and Service are working as intended, such as tracking outages or troubleshooting issues that you report to us. And we use this information to make improvements to our Site and Service and customise them for the Users.
  • for security and safety
    We use information to help improve the safety and reliability of our Site. This includes detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm us, the Users or third parties
  • for communication
    We use personal data (including contact information) to communicate with you about our products, features, and sites, including product updates, and changes to our Terms and Conditions and policies.We also use your information to respond to you when you contact us
  • for marketing and promotions
    To market, advertise, and promote ROOM Products, features, and sites.
  • for legal reasons
    In order to comply with applicable law or respond to valid legal process, including by law enforcement or regulatory authorities, to investigate or otherwise participate in civil investigations, legal action or other adversarial legal proceedings, and to enforce or investigate possible violations of our Terms and Conditions or Privacy Policy.

If you have consented to data processing, we process your personal data on the basis of Art. 6 para. 1 p. 1 lit. a or Art. 9 para. 2 lit.a GDPR, if special categories of data are processed according to Art. 9 para. 1 GDPR. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art.  49 para. 1 lit. a GDPR. If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TTDSG. The consent can be revoked at any time.  

If your data is required for the fulfilment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6 para. 1 p. 1 lit b GDPR. 

Furthermore, if your data is required for the fulfilment of a legal obligation, we process it on the basis of Art. 6 para. 1 p. 1 lit c GDPR. 

Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6 para. 1 p. 1 lit f GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

How long do we store your data? (storage duration)

The data processed by us are deleted or limited in their processing in accordance with articles 17 and 18 GDPR. Unless explicitly stated in this Privacy, your personal data stored by us will be deleted as soon as the purpose for which it was collected no longer applies and the deletion does not conflict with any statutory storage requirements. 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. If the data is not deleted because it is required for other and legitimate purposes, its processing will be restricted. That means the data is blocked and not processed for other purposes. 

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

The use and storage of your data may be objected to by email at any time. We will inform you about the specific duration of the respective data processing in this Privacy, provided we have additional related information.

How do we share your personal data?

In the course of our processing of personal data, we may transfer to or disclose to other bodies, companies, legally independent entities or persons, for example, service providers commissioned with IT tasks or providers of services and content that are integrated into the Site. In such cases, we observe the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

We may transfer personal data to other companies within our group of companies or grant them access to this data. Insofar as this transfer is for administrative purposes, the transfer of the data is based on our legitimate corporate and business interests or takes place insofar as it is necessary for the fulfilment of our contract-related obligations or if the consent of the data subjects or a legal permission exists.

Otherwise, your personal data will not be transferred to third parties for purposes other than those listed below: 

  • insofar as you have given your express consent in accordance with art. 6 para. 1 p. 1 lit. a GDPR;
  • if the disclosure is necessary for the purposes of the legitimate interests pursuant to art. 6 para. 1 p. 1 lit. f GDPR and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data;
  • in the event that there is a legal obligation to disclose your data pursuant to art. 6 para. 1 p. 1 lit. c GDPR, or
  • where this is legally permissible and necessary according to art. 6 para. 1 p. 1 lit. b GDPR for the execution of contractual relationships with you. This includes, in particular, the transmission of data to authorities or third parties involved in the project, such as customers and their representatives or implementing companies, as well as external service providers for the purpose of correspondence and contract processing and/or fulfilment. 

The data passed on may be used by the third party exclusively for the purposes stated. 

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, analyse, and permanently archive your personal data for surveillance purposes. We have no control over these processing activities.

Security measures

We take appropriate technical and organisational measures in accordance with the law, taking into account the state of the technic, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the level of threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

Shortening of the IP address: If IP addresses are processed by us or by the service providers and technologies used and the processing of a complete IP address is not necessary, the IP address is shortened (also referred to as "IP masking"). In this process, the last two digits or the last part of the IP address after a full stop are removed or replaced by wildcards. The shortening of the IP address is intended to prevent or make it considerably more difficult to identify a person by their IP address.

SSL encryption (https): For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us, we use 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.

Your rights

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.

As far as your information is concerned, you have the following rights:

A wide range of data processing transactions are possible only subject to your express consent. You can revoke at any time any consent you have given (art. 7 para 3 GDPR). This shall affect all future data processing but be without prejudice to the lawfulness of any data collection that occurred prior to your revocation. 

Right of objection (Art. 21 GDPR)

If your personal data is processed on the basis of public interest (art. 6 para. 1 p. 1 lit. e GDPR) and/or legitimate interests (art. 6 para. 1 p. 1 lit. f GDPR), you have the right to object to the processing of your personal data in accordance with art. 21 GDPR, provided there are reasons for this arising from your particular situation.

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 para. 1 GDPR). 

if your personal data is being processed in order to engage in direct advertising, you have the right to at any time object to the processing of your affected personal data for the purposes of such advertising. 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 para. 2 GDPR).

Right to complain to the competent supervisory authority (Art. 77 GDPR)

You also have the right, in accordance with the law, to lodge a complaint to a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data concerning you infringes the GDPR.The right to lodge a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

Right to information (Art.15 GDPR), rectification (Art. 16 GDPR) and eradication of data (Art. 17 GDPR)

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 without having to pay a fee for such disclosures.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 data portability (Art. 20 GDPR)

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.

Right to demand processing restrictions (Art. 18 GDPR)

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.

TO EXERCISE YOUR RIGHTS OR IF YOU HAVE ANY PRIVACY-RELATED QUESTIONS OR COMMENTS RELATED TO THIS STATEMENT, PLEASE CONTACT US AT ANY TIME AT dataprotection@room3d.com.

ROOM account

You have the option to register for ROOM on this Website. You need to have a registered account to host a meeting in ROOM. By signing up, you can create meetings in rooms/venues, while users without ROOM accounts can only join meetings to which they've been invited. 

When you sign up for ROOM on the Website and create a ROOM account, you provide us with personal information, including your name and a password and other information, depending on whether it is a free sign-up or a subscription. Even if you aren’t signed in to an account, you might choose to provide us with information — like an email address to receive updates about our services.

Free ROOM Account

For a free ROOM account Users have to provide information such as:

  • First name, last name
  • Email
  • Username and password
  • Age confirmation (for age verification purposes only)

For a  paid ROOM account (subscription) we collect from the account holder data Information such as: 

  • User Data (listed above)
  • Billing name
  • Billing phone
  • Billing address
  • Billing information, including the last four digits of the credit card number associated with the transaction
  • Payment method  (if applicable)
  • Company Name (if applicable)
  • Employee count (if applicable)

We shall use the data you enter only for the purpose of using the respective offer or service you have registered for. To notify you of any important changes to the scope of our offer or in the event of technical modifications, we shall use the e-mail address provided during the registration process. 

We do not retain or use this information for any other purpose.The entry remains valid until you revoke it. The data shall be stored by us as long as you are registered. Subsequently, such data shall be deleted.  Otherwise, after suspension or termination of your access to or use of ROOM for any reason, all your entry data will be deleted, unless we have other legally permissible reasons for storing it. This shall be without prejudice to mandatory statutory retention obligations.

Legal basis of processing: We shall process the data entered during the registration process on the basis of your consent (art. 6 para. 1 p. 1 lit. a GDPR) otherwise for Contract performance and pre-contractual enquiries ( art. 6 para. 1 p. 1 lit. b GDPR), Legitimate interests (art. 6 para. 1 p. 1 lit. f GDPR), Protection of vital interests (art. 6 para. 1 p. 1 lit. c GDPR) and legal compliance (art. 6 ( para. 1 p. 1 lit. d GDPR). If consent has been requested, processing is carried out exclusively on the basis of art. 6 para. 1 p. 1 lit. a GDPR; consent can be revoked at any time.

Support and feedback data

We process support and feedback data that you send us or that we have received directly from the Users. This may be support data that has been provided by the Users or is otherwise processed in connection with support activities such as support chats or calls. Furthermore we may process data such as survey data (Feedback from In-Service surveys) or feedback in relation to the use of ROOM.

The purpose of this processing is to respond to requests for support, and to conduct anonymized, aggregated analytics to improve performance. 

Legal basis of processing: Contract performance and pre-contractual enquiries ( art. 6 para. 1 p. 1 lit. b GDPR), Legitimate interests (art. 6 para. 1 p. 1 lit. f GDPR).

Approximate location 

Approximate Location (e.g. next city) is collected automatically by logging in ROOM. The purpose of the processing is e.g. to connect you to the nearest data center; to comply with privacy and other laws, for example, to monitor performance of our data centers and networks; to route support requests.

Legal basis of processing: Contract performance and pre-contractual enquiries ( art. 6 para. 1 p. 1 lit. b GDPR), Legitimate interests (art. 6 para. 1 p. 1 lit. f GDPR), legal compliance (art. 6 para. 1 p. 1 lit. c GDPR) and protection of vital interests (art. 6 para. 1 p. 1 lit. d).

Persistent identifiers

We use persistent identifiers on ROOM Beta service pages. These are third-party cookies that are necessary for technical support and to deliver the Service, and are automatically collected when you use the Service from your web browser to provide the Service and technical support. 

Legal basis of processing: Contract performance and pre-contractual enquiries ( art. 6 para. 1 p. 1 lit. b GDPR), Legitimate interests (art. 6 para. 1 p. 1 lit. f GDPR).

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.

The processing of these data is based on art. 6 para. 1 p. 1 lit. 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 para. 1 p. 1 lit. f GDPR) or on your agreement (art. 6 para. 1 p. 1 lit. 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 email/phone

If you contact us by email/phone 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 para. 1 p. 1 lit. b GDPR if your inquiry is related to the fulfilment 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 para. 1 p. 1 lit. f GDPR) or on the basis of your consent (art. 6 para. 1 p. 1 lit. 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.

Newsletter

Newsletter Data

If you would like to subscribe to the newsletter offered on this Website, we will need from you an email address as well as information that allows 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.

For the handling of the newsletter, we use newsletter service providers, which are described below.

Mailchimp with deactivated success measurement

This Website uses the services of MailChimp to send out its newsletters. The provider is the Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.

Among other things, MailChimp is a service that can be deployed to organise the sending of newsletters.

Whenever you enter data for the purpose of subscribing to a newsletter (e.g. your email address), the information is stored on MailChimp servers in the United States. 

With the assistance of the MailChimp tool, we can analyse the performance of our newsletter campaigns. If you open an email that has been sent through the MailChimp tool, a file that has been integrated into the email (a so-called web-beacon) connects to MailChimp’s servers in the United States. As a result, it can be determined whether a newsletter message has been opened and which links the recipient possibly clicked on. Technical information is also recorded at that time (e.g. the time of access, the IP address, type of browser and operating system). This information cannot be allocated to the respective newsletter recipient. Their sole purpose is the performance of statistical analyses of newsletter campaigns. The results of such analyses can be used to tailor future newsletters to the interests of their recipients more effectively.

If you do not want MailChimp to receive your data, you must unsubscribe from the newsletter. We provide a link for you to do this in every newsletter message.

The data processing is based on your consent (art. 6 para. 1 p. 1 lit. 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.

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.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:

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 para. 1 p. 1 lit. 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 Privacy Policies of MailChimp at: https://mailchimp.com/legal/terms/.

Data processing: We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our Website visitors only based on our instructions and in compliance with the GDPR.

Hosting With Amazon Web Services (AWS)

We are hosting our Site and Service (Website, Room Platform, database and web content) with AWS. The provider is Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, 1855 Luxembourg (hereinafter referred to as “AWS”).

When you visit our Site, your personal data will be processed on AWS servers.These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site. The data is stored exclusively in a German data center (Frankfurt/Main), which is certified according to ISO 27001, 27017 and 2018 as well as PCI DSS Level 1. Of course, there are strictly limited access rights on our part and the data is automatically encrypted. 

For more information about AWS and data protection, please visit https://aws.amazon.com/de/compliance/eu-data-protection/ and https://aws.amazon.com/de/privacy/.

This may also result in the transfer of personal data to the parent company of AWS in the United States. The transfer of data to the US is based on the EU’s standard contractual clauses. For details please consult: https://aws.amazon.com/de/blogs/security/aws-gdpr-data-processing-addendum/.

AWS is used for the purpose of fulfilling the contract with our Users, potential and existing customers (art. 6 para. 1 p. 1 lit. b GDPR) and in the interest of secure, fast, and efficient provision of our online services by a professional provider (art. 6 para. 1 p. 1 lit. f GDPR). If your respective consent was obtained, processing will occur exclusively based on (art. 6 para. 1 p. 1 lit. a GDPR) and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG.This consent may be revoked at any time. 

AWS will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data. In order to guarantee processing in compliance with data protection regulations, we have concluded a data processing agreement (DPA), which is based on the EU standard contractual clauses with AWS.This is a contract mandated by data privacy laws that guarantees that they process personal data of our users only based on our instructions and in compliance with the GDPR.

Cookies

Our Website uses “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 (third party 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 para. 1 p. 1 lit. f GDPR, unless a different legal basis is mentioned in this Policy. We have a legitimate interest in the storage of cookies to ensure the technically error free and optimised provision of the Site. 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 para. 1 p. 1 lit. a GDPR); If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TTDSG.  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 our 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 Privacy and, if applicable, ask for your consent.

Our cookies consent tool  (Cookies settings) contains a detailed description of the optional cookies we use. You may at any time object to the setting of optional cookies by using the respective objection option in the cookie settings (open via the cookie button in the bottom left corner).

Our Website uses the ConsentManager consent technology to obtain your consent to the storage of certain cookies on your device or for the use of certain technologies and data protection legislation compliant documentation of the former. The provider offering this technology is consentmanager AB, Håltegelvägen 1b, 72348 Västerås, Sweden, website: https://www.consentmanager.net (hereinafter referred to as “ConsentManager”).

Whenever you visit our Website, a connection to ConsentManager’s servers will be established to obtain your consent and other declarations regarding the use of cookies. Moreover, ConsentManager shall store a cookie in your browser to be able to allocate your declaration(s) of consent or any revocations of the former. 

The data that are recorded in this manner shall be stored until you ask us to eradicate them, delete the ConsentManager cookie or until the purpose for archiving the data no longer exists. This shall be without prejudice to any mandatory legal retention periods.

The legal basis for the described data processing is art. 6 para. 1 p. 1 lit. c GDPR. As the responsible party, we are subject to the legal obligation to make the use of technically unnecessary cookies dependent on the respective User consent. Furthermore, this data processing is carried out in accordance with art. 6 para. 1 p. 1 lit. f GDPR on the basis of our legitimate interest in a legally compliant, user-specific and user-friendly consent management for cookies and thus in a legally compliant design of our Website.

Data processing agreement

We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our Website visitors only based on our instructions and in compliance with the GDPR.

Server log files

The provider of this Website 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 para. 1 p. 1 lit. f GDPR. We have a legitimate interest in the technically error free depiction and the optimization of the Website. In order to achieve this, server log files must be recorded.

Certain links within the Site may lead to other independent companies. We will never share your personal information with these third party companies.

Links to third party websites provided are provided as a service to you. We have no control over these sites or over their privacy practices, which may differ from ours. We do not endorse and are not responsible for any content on third party sites that may be accessed through our Site. We encourage you to review each company's privacy policy before submitting your personal information. 

The information you voluntarily provide to independent third parties is subject to their privacy policies. Some third party companies may choose to share their personal information with us; such sharing is subject to that third party company's privacy policy. We cannot be responsible for the personal information these third parties collect, store and use through the use of the Site. You are responsible for always carefully reading the privacy policy on any website you visit.

Sharing your data with third parties

We may employ professional services from companies and individuals to help us operate our websites.

All professional service providers are required to take appropriate security measures to protect your data in line with our policies. We do not allow them to use your data for their own purposes. We permit them to process your data only for specified purposes and in accordance with our instructions.

Analysis tools and advertising

Here we inform you about which plugins or tools we use for statistical or advertising purposes on the Website.

Google Tag Manager

We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States.

Where the relevant consent has been requested, the processing is carried out exclusively on the basis of art. 6 para. 1 p. 1 lit. a GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time. Otherwise the Google Tag Manager is used on the basis of art. 6 para. 1 p. 1 lit. f GDPR. We have a legitimate interest in the quick and uncomplicated integration and administration of various tools on our Website.

Google Analytics (Universal Analytics and Analytics 4)

This Website uses functions of the web analysis service Google Analytics (Google Universal Analytics and Google Analytics 4). The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyse the behaviour patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilised operating system and the user’s origin. This data is summarised in a user-ID and assigned to the respective end device of the website visitor.

Furthermore, Google Analytics allows us to record your mouse and scroll movements and clicks, among other things. Google Analytics uses various modelling approaches to augment the collected data sets and uses machine learning technologies in data analysis.

Google Analytics uses technologies that make the recognition of the user for the purpose of analysing the user behaviour patterns (e.g., cookies or device fingerprinting). The Website use information recorded by Google and is, as a rule, transferred to a Google server in the United States, where it is stored. 

All processing described above, in particular the setting of Google Analytics cookies for the storage and reading of information on the end device used by you for the use of the Website, only takes place if you have given us your express consent for this in accordance with art. 6 para. 1 p.1 lit. a GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. Without your consent, Google Analytics will not be used during your use of the Website. You can revoke your consent at any time with effect for the future. To exercise your revocation, please deactivate this service via the cookie consent tool provided on the website (Cookies Settings). 

In connection with this Website, the "UserIDs" function is also used as an extension of Google Analytics 4. By assigning individual UserIDs, we can have Google create cross-device reports (so-called "cross-device tracking"). This means that your usage behaviour can also be analysed across devices if you have given your corresponding consent to the use of Google Analytics 4 in accordance with art. 6 para. 1 lit. a GDPR, if you have set up a personal account by registering on this Website and are logged into your personal account on different end devices with your relevant login data. The data collected in this way shows, among other things, on which end device you clicked on an ad for the first time and on which end device the relevant conversion took place.

Otherwise Google Analytics may be used on the basis of art. 6 para. 1 p. 1 lit. f GDPR. As operator of this Website we have a legitimate interest in the analysis of user patterns to optimise both, the services offered online and the operator’s advertising activities.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.

IP anonymization

On this Website, we have activated the IP anonymization function. That means that your IP address is shortened beforehand by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google LLC.server in the USA and shortened there. On behalf of the operator of this Website, Google shall use this information to analyse your use of this Website to generate reports on Website activities and to render other services to the operator of this Website that are related to the use of the Website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.

Browser plug-in and Opt Out

You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.

Google Signals

We use Google Signals. Whenever you visit our Website, Google Analytics records, among other things, your location, the progression of your search and YouTube progression as well as demographic data (site visitor data). This data may be used for customised advertising with the assistance of Google Signal. If you have a Google account, your site visitor information will be linked to your Google account by Google Signal and used to send you customised promotional messages. The data is also used to compile anonymized statistics of our users’ online patterns.

Demographic parameters 

Google Analytics also enables the creation of statistics with statements about the age, gender and interests of site visitors on the basis of an evaluation of interest-based advertising and with the inclusion of third-party information via a special function, the so-called "demographic characteristics". This allows the definition and differentiation of user groups of the Website for the purpose of targeting marketing measures. However, data records collected via the "demographic characteristics" cannot be assigned to a specific person.

You have the option to deactivate this function at any time by making pertinent settings changes for advertising in your Google account or you can generally prohibit the recording of your data by Google Analytics as explained in section “Objection to the recording of data”.

Retention period

The retention period of the data depends on the properties used. When using the Google Analytics 4 properties, the retention period of your user data is fixed at 14 months. For other so-called event data, we have the option to choose a retention period of 2 months or 14 months.

For Universal Analytics properties, the default retention period for your user data is 26 months. Your user data will then be deleted. However, we have the option to choose the retention period of user data ourselves (14 months/26 months/38 months/50 months/Do not automatically expire).

In addition, there is also the option for data to be deleted only when you no longer visit our Website within the period we have chosen. In this case, the retention period will be reset each time you visit our Website again within the specified period.

Once the specified period has expired, the data is deleted once a month. This retention period applies to your data associated with cookies, user recognition and advertising IDs (e.g. DoubleClick domain cookies). Reporting results are based on aggregated data and are stored separately from user data. Aggregated data is a merging of individual data into a larger unit.

For details, please click the following link: https://support.google.com/analytics/answer/7667196?hl=en

Data processing

We have executed a contract data processing agreement with Google and are implementing the stringent provisions of the German data protection authorities to the fullest when using Google Analytics.

Google Analytics E-Commerce-Tracking

This Website uses the “E-Commerce Tracking” function of Google Analytics. With the assistance of E-Commerce Tracking, the website operator is in a position to analyse the purchasing patterns of website visitors with the aim of improving the operator’s online marketing campaigns. In this context, information, such as the orders placed, the average order values, shipping costs and the time from viewing the product to making the purchasing decision are tracked. These data may be consolidated by Google under a transaction ID, which is allocated to the respective user or the user’s device.

Google Data Studio

Where you have given your consent, we use Google Data Studio, an analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043-1351, USA ("Google"). 

We use the Google Data Studio software to visualise data relating to user behaviour on our Website in the form of graphical reports. In doing so, we use data from the web analytics service Google Analytics as well as other data sources (such as Google AdWords, Google Analytics). Further information on the use of Google Data Studio can be found at https://support.google.com/datastudio/answer/6283323?hl=de&ref_topic=6267740

As a rule, data is also transmitted to a Google server in the USA as part of the processing. There is an agreement with Google in accordance with the EU standard contractual clauses, which ensures the adequacy of data protection even in the case of processing in the USA and other third countries (art. 46 GDPR).

The processing is carried out in accordance with art. 6 para. 1 p. 1 lit. a GDPR on the basis of your consent. If you give your consent to the use of the cookies in question, you also expressly consent to the transfer of data to the USA as described above (art. 49 para. 1 lit. a GDPR). 

If you deactivate the use of Google Analytics for the future at https://tools.google.com/dlpage/gaoptout?hl=de, your data will also not be used in Google Data Studio. By clicking on the link, we set a cookie (opt-out cookie) in your browser, which signals to us to prevent the use of Google Analytics for your end device. Please note that you will have to carry out this process again if you remove the cookies in your browser.

We use 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 analyse these data quantitatively, for instance by analysing 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 para. 1 p. 1 lit. 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. Data processing terms and conditions and standard contractual clauses between data controllers for third country transfers of data: https://business.safety.google/adscontrollerterms.  

Types of processing and data processed: https://privacy.google.com/businesses/adsservices;

 Google data protection policy: https://policies.google.com/privacy;

Google AdSense 

This website uses Google AdSense, a service for the integration of ads. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. With the assistance of Google Adsense, we are in a position to place targeted ads by third parties on our site.

The contents of the ads are based on your interests, which Google determines based on your past user patterns. Moreover, when choosing compatible ads, context information, such as your location, the content of the visited website or Google search terms you have entered, will be taken into account.

Google AdSense uses Cookies, Web Beacons (invisible graphics) and comparable recognition technologies. As a result, it is possible to analyse information, such as visitor traffic data, on these sites. The usage information for this website (including your IP address) recorded by Google Adsense and delivery of advertising formats are transferred to a Google server in the United States, where the information is stored. Google may share this information with one of its contracting partners. However, Google will not link your IP address with any other of your stored information.

Our use of AdSense is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the marketing of the operator’s website that is as effective as possible. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent 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: https://privacy.google.com/businesses/controllerterms/mccs/.

Google Remarketing

This Website uses the functions of Google Analytics Remarketing. The provider of these solutions is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Remarketing analyses your user patterns on our Website (e.g., clicks on specific products), to allocate a certain advertising target groups to you and to subsequently display matching online offers to you when you visit other online offers (remarketing or retargeting).

Moreover, it is possible to link the advertising target groups generated with Google Remarketing to device encompassing functions of Google. This makes it possible to display interest-based customised advertising messages, depending on your prior usage and browsing patterns on a device (e.g., cell phone) in a manner tailored to you as well as on any of your devices (e.g., tablet or PC).

For the formation of target groups, we may use, among other things, the Google Remarketing customer reconciliation feature. To achieve this, we may transfer certain customer data (e.g., email addresses) from our customer lists to Google. If the respective customers are Google users and are logged into their Google accounts, matching advertising messages within the Google network (e.g., YouTube, Gmail or in a search engine) are displayed for them to view.

If you have a Google account, you have the option to object to personalised advertising under the following Link: https://www.google.com/settings/ads/onweb/.

The use of Google Remarketing is based on art. 6 para. 1 p. 1 lit. f GDPR. The website operator has a legitimate interest in the marketing of the operator’s products that is as effective as possible. If a respective declaration of consent was requested, processing shall occur exclusively on the basis of art. 6 para. 1 p. 1 lit. a GDPR; the given consent may be revoked at any time.

For further information and the pertinent data protection regulations, please consult the Data Privacy Policies of Google at: https://policies.google.com/technologies/ads?hl=en.

Google Conversion-Tracking

This Website uses Google Conversion Tracking. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

With the assistance of Google Conversion Tracking, we are in a position to recognize whether the user has completed certain actions. For instance, we can analyse how frequently which buttons on our Website have been clicked and which products are reviewed or purchased with particular frequency. The purpose of this information is to compile conversion statistics. We learn how many users have clicked on our ads and which actions they have completed. We do not receive any information that would allow us to personally identify the users. Google as such uses cookies or comparable recognition technologies for identification purposes.

We use Google Conversion Tracking on the basis of art. 6 para. 1 p. 1 lit. f GDPR. The operator of the website has a legitimate interest in the analysis of the user patterns with the aim of optimising both, the operator’s web presentation and advertising. If a respective declaration of consent was requested (e.g., concerning the storage of cookies), processing shall occur exclusively on the basis of art. 6 para. 1 p. 1 lit. a GDPR; the given consent may be revoked at any time.

For more information about Google Conversion Tracking, please review Google’s data protection policy at: https://policies.google.com/privacy?hl=en

Google DoubleClick

This Website uses features of Google DoubleClick. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland, (hereinafter “DoubleClick”).

DoubleClick is used to show you interest-based ads across the Google Network. Advertisements can be tailored to the interests of the viewer using DoubleClick. For example, our ads may appear in Google search results or in banners associated with DoubleClick.

To be able to display interest adequate promotional content to users, DoubleClick must recognize the respective visitor so that it can allocate the websites visited, the clicks and other user pattern information to the user. To do this, DoubleClick deploys cookies or comparable recognition technologies (e.g., device fingerprinting). The recorded information is consolidated into a pseudonym user profile so that the respective users can be shown interest adequate advertising.

The use of Google DoubleClick takes place in the interest of targeted advertising measures. This constitutes a legitimate interest within the meaning of art. 6 para. 1 p. 1 lit. f GDPR. If a corresponding consent has been requested (e.g., a consent to the storage of cookies), the processing takes place exclusively on the basis of art. 6 para. 1 p. 1 lit. a GDPR; the consent can be revoked at any time.

For further information on how to object to the advertisements displayed by Google, please see the following links: https://policies.google.com/technologies/ads and

https://adssettings.google.com/authenticated.

Facebook Pixel

To measure conversion rates, this Website uses the visitor activity pixel of Facebook. The provider of this service is Meta Platforms 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 analyse the effectiveness of Facebook ads for statistical and market research purposes and to optimise 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 para. 1 p. 1 lit. f GDPR. The operator of the website has a legitimate interest in effective advertising campaigns, which also include social media. If a corresponding consent has been requested (e.g., a consent to the storage of cookies), the processing takes place exclusively on the basis of art. 6 para. 1 p. 1 lit. a GDPR; the consent can be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. 

Insofar as personal data is collected on our Website with the help of the tool described here and forwarded to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (art. 26 GDPR). The purposes for which the collection and transfer of the personal data constituting the joint processing is carried out are as set out and referenced in the terms of use https://www.facebook.com/legal/terms/businesstools, the Facebook European Data Transfer Addendum https://www.facebook.com/legal/EU_data_transfer_addendum/update and  the Data Processing Terms https://www.facebook.com/legal/terms/dataprocessing/amendment

For more information on how Meta Platforms Ireland Limited processes personal data, including the legal basis on which Meta Platforms Ireland relies and how data subjects can exercise their rights against Meta Platforms Ireland Limited, please see  Meta Platforms Ireland's Data Policy at https://www.facebook.com/about/privacy.

We have entered this Controller Addendum with Meta Platforms Ireland to set out the respective responsibilities for fulfilling the obligations under the GDPR in respect of joint processing as described. We are responsible for providing data subjects with at least this information on joint responsibility with Facebook. It is agreed with Meta Platforms Ireland that  Meta Platforms Ireland is responsible for fulfilling the rights of data subjects under Articles 15-20 of the GDPR in respect of personal data held by  Meta Platforms Ireland following joint processing.

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/.

LinkedIn Insight Tag

This Website uses the Insight tag from LinkedIn. This service is provided by LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

We use the LinkedIn Insight tag to obtain information about visitors to our Website. Once a website visitor is registered with LinkedIn, we can analyse the key occupational data (e.g., career level, company size, country, location, industry, job title) of our Website visitors to help us better target our site to the relevant audience. We can also use LinkedIn Insight tags to measure whether visitors to our Website make a purchase or perform other actions (conversion measurement). Conversion measurement can also be carried out across devices (e.g. from PC to tablet). LinkedIn Insight Tag also features a retargeting function that allows us to display targeted advertising to visitors to our Website outside of the Website. According to LinkedIn, no identification of the advertising addressee takes place. 

LinkedIn itself also collects log files (URL, referrer URL, IP address, device and browser characteristics and time of access). The IP addresses are shortened or (if they are used to reach LinkedIn members across devices) hashed (pseudonymized). The direct identifiers of LinkedIn members are deleted by LinkedIn after seven days. The remaining pseudonymized data will then be deleted within 180 days.

The data collected by LinkedIn cannot be assigned by us as a website operator to specific individuals.

LinkedIn will store the personal data collected from website visitors on its servers in the USA and use it for its own promotional activities. For details, please see LinkedIn’s privacy policy at

https://www.linkedin.com/legal/privacy-policy#choices-oblig.

Legal basis: The use of LinkedIn Insight is based on art. 6 para. 1 p. 1 lit. f GDPR. The website operator has a legitimate interest in effective advertising measures, including social media. If a corresponding consent has been requested (e.g. consent to the storage of cookies), the processing is carried out exclusively on the basis of art. 6 para. 1 p. 1 lit. a GDPR; the consent 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: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs.

Objection to the use of LinkedIn Insight Tag: You can object to LinkedIn’s analysis of user behaviour and targeted advertising at the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

In addition, LinkedIn members can control the use of their personal information for promotional purposes in the account settings. To prevent LinkedIn from linking information collected on our site to your LinkedIn account, you must log out of your LinkedIn account before you visit our site.

Data processing agreement: We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our Users only based on our instructions and in compliance with the GDPR.

Twitter Advertising/Twitter Pixel (Retargeting, Conversion Tracking)

We use "Twitter Pixel", a service of Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2 D02 AX07, Ireland on our Website. Mother company is Twitter Inc: Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.

With the help of the Twitter pixel, we can in particular track users' actions after they have seen or clicked on a Twitter advertisement. This procedure is used to evaluate the effectiveness of the Twitter ads for statistical and market research purposes and can help to optimise future advertising measures. Statistical, pseudonymous data is transmitted to Twitter in order to provide us with corresponding statistics on this basis and to be able to show you interest-specific offers. This data is stored in a cookie.

We use "Twitter Pixel'' on the basis of our legitimate interests. If consent has been requested, processing is carried out exclusively on the basis of art. 6 para. 1 p. 1 lit. a GDPR; your consent can be revoked at any time.

The data collected is anonymous for us, so that we cannot draw any conclusions about the identity of the users. However, the data is stored and processed by Twitter so that a connection to the respective user profile is possible and Twitter can use the data for its own advertising purposes in accordance with the Twitter privacy policy: https://twitter.com/privacy.

We have no influence on the scope and further use of data collected by Twitter through the use of Twitter Pixel. You can object to the aforementioned collection by Twitter Pixel and the use of your data to display Twitter ads. You can make settings regarding which types of advertisements are displayed to you within Twitter on the following Twitter website (Opt-Out): https://twitter.com/personalization.

You can change your data protection settings and consents on Twitter in the account settings at: https://twitter.com/account/settings.

Plug-ins and tools

Hubspot CRM

We use Hubspot CRM on this Website. The provider is Hubspot Inc. HubSpot, a software company based in the USA 25 Street, Cambridge, MA 02141 USA with an office in Ireland. Contact: HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, Phone: +353 1 5187500.  

Hubspot CRM enables us, among other things, to manage existing and potential customers and customer contacts, to communicate with you and to plan and execute marketing activities in line with your interests. Hubspot CRM enables us to capture, sort and analyse customer interactions via email, social media, or phone across multiple channels. The personal data collected in this way can be evaluated and used for communication with the potential customer or marketing measures (e.g., newsletter mailings). Hubspot CRM also enables us to collect and analyse the user behaviour of our contacts on our Website.

The use of Hubspot CRM is based on art. 6 para. 1 p. 1 lit. f GDPR. The website operator has a legitimate interest in the most efficient customer management and customer communication. If consent has been requested, the processing is carried out exclusively on the basis of art. 6 para. 1 p. 1 lit. a GDPR; consent may be revoked at any time. 

For details, please refer to Hubspot’s privacy policy: https://legal.hubspot.com/de/privacy-policy.

Data transmission to the US is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.hubspot.de/data-privacy/privacy-shield.

Data processing: We have concluded an order processing contract with Hubspot CRM. This is a contract that is required by data protection law and ensures that Hubspot CRM processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

Zendesk

We deploy the CRM system Zendesk to process User inquiries. The provider is Zendesk, Inc., 1019 Market Street in San Francisco, CA 94103 USA.

When contacting us (e.g. via contact form, email, telephone or via social media), the information provided by the person making the enquiry is processed to the extent necessary to respond to the contact enquiries and any measures requested. The response to the contact requests in the context of contractual or pre-contractual relationships is carried out to fulfil our contractual obligations or to respond to (pre)contractual requests and otherwise on the basis of the legitimate interests in responding to the requests.

We use Zendesk to be able to respond to your inquiries promptly and efficiently. The messages addressed to us remain with us until you request deletion, or the data storage purpose no longer applies (e.g. after completed processing of your request). Mandatory statutory provisions, in particular retention periods, remain unaffected.

Types of data processed: personal data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

Purposes of processing: contact requests and communication, managing and responding to requests.

Legal basis: Contract performance and pre-contractual enquiries (art. 6 para. 1 p. 1 lit. b GDPR), Legitimate interests (art. 6 para. 1 p. 1 lit. f GDPR), Protection of public interests (art. 6 para. 1 p. 1 lit. e GDPR). If consent has been requested, processing is carried out exclusively on the basis of art. 6 para. 1 p. 1 lit. a GDPR; consent can be revoked at any time. 

Zendesk has Binding Corporate Rules (BCR) which have been approved by the Irish Data Protection Authority. These are binding corporate rules that legitimise the transfer of data within the company to third countries outside the EU and EEA. Details can be found here: https://www.zendesk.de/blog/update-privacy-shield-invalidation-european-court-justice/.

If you should not want to agree to the processing of your inquiries by us via Zendesk, you have the alternative option to communicate with us via email. For more information, please consult Zendesk’s Data Privacy Declaration at: https://www.zendesk.com/company/customers-partners/privacy-policy/.

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

YouTube with expanded data protection integration

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 para. 1 p. 1 lit. 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 para. 1 p. 1 lit. 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.

We use YouTube in the expanded data protection mode. According to YouTube, this mode ensures that YouTube does not store any information about visitors to this Website before they watch the video.

Nevertheless, this does not necessarily mean that the sharing of data with YouTube partners can be ruled out as a result of the expanded data protection mode. For instance, regardless of whether you are watching a video, YouTube will always establish a connection with the Google DoubleClick network. As soon as you start to play a YouTube video on this Website, a connection to YouTube’s servers will be established. As a result, the YouTube server will be notified, which of our pages you have visited. 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 yourYouTube account.

Furthermore, after you have started to play a video, 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.

Chatbots

We may 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 analyse 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 metadata. 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 para. 1 p. 1 lit. b  GDPR, if the chatbot is used to negotiate a contract or in conjunction with the fulfilment of a contract. If pertinent consent has been requested, the processing shall occur exclusively on the basis of art. 6 para. 1 p. 1 lit. 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 para. 1 p. 1 lit. f GDPR).

We currently use the following chatbots: -

Social Media monitoring and management tools

Brandwatch

 We use the services of Brandwatch GmbH (Gutenbergstr. 77A, 70197 Stuttgart). This is a social media monitoring tool that helps us to recognize and monitor content on third-party sites (e.g. posts, tweets, blogs, news, contributions from forums and social media platforms). This gives us a detailed insight into customer opinions and any topics on the internet where our company name(s) are mentioned or our brand(s) are talked about. In the process, so-called "crawlers" search online sources to filter out the relevant hits. Brandwatch searches publicly available data from the internet as well as closed networks of third party providers with whom contracts are directly concluded for access to their data. The data Brandwatch collects varies depending on the source of the data. The following personal data may also be collected: your name, username, nickname or other identifier; the content of the data you have posted about that name, username, nickname or other identifier, including comments, expressions, opinions, posts, etc.; and your profile picture; your job title or industry; your interests;your location; your gender; and any other data you publish on an internet website or on a third party platform that provides Brandwatch with data.

The use of Brandwatch is  on the basis of our legitimate interests pursuant to art. 6 para. 1 p. 1 lit. f GDPR and a contract on data processing pursuant to GDPR and serves the purpose of market and opinion research and/or  marketing and PR purposes. If consent has been requested, processing is carried out exclusively on the basis of art. 6 para. 1 p. 1 lit. a GDPR; consent can be revoked at any time. 

The data processing takes place externally and separately from our company Website and social media sites, so that we are not responsible for the data processing by Brandwatch. If you wish to object to the use of your data by Brandwatch, request information about the stored data or assert any other right to which you are entitled, please contact Brandwatch at the e-mail address privacy@brandwatch.com. Further information on data protection at Brandwatch can be found at https://www.brandwatch.com/legal/author-privacy-policy/

Falcon.io

We use the social media management tool Falcon.io of the provider Falcon.io ApS, H.C. Andersens boulevard 27, 1st floor, 1553 Copenhagen V, Denmark, with the functions Publish, Engage, Listen, Audience and Measure on the basis of our legitimate interests pursuant to art. 6 para. 1 p. 1 lit. f GDPR and a contract on data processing pursuant to GDPR. This allows us to publish network- or platform- and channel-specific content, edit user reactions, search the social networks and platforms for mentions, and to analyse any interactions with us and our actions. Every time you interact with our online presences within social networks and platforms, the data that is stored in the profiles you use is saved. These are, for example, name, gender, profile picture, profile URL, handle/username. In addition, the times of your interactions with our online presences are recorded. Furthermore, the tool also enables us to create our own campaign pages and to display personalised and interest-based advertising as well as to measure the results. If consent has been requested, processing is carried out exclusively on the basis of art. 6 para. 1 p. 1 lit. a GDPR; consent can be revoked at any time. 

The use of Falcon.io serves the aforementioned purposes. The data processing takes place externally and separately from our company Website and social media page, so that we are not responsible for the data processing by Falcon.io.

If you wish to object to the use of your data by Falcon.io, request information about the data stored or exercise any other right to which you are entitled, please contact Falcon.io at the email address privacy@falcon.io. Further information on data protection at Falcon.io can be found here: https://www.falcon.io/privacy-policy/.

Notes on service application

We process the data of the Users of our application insofar as this is necessary to provide the application and its functionalities to the Users, to monitor its security and to further develop it. We may also contact Users in compliance with legal requirements if the communication is necessary for the purposes of administration or use of the application. In all other respects, we refer to the data protection information in this Privacy with regard to the processing of users' data.

The processing of data required for the provision of the functionalities of the application serves the fulfilment of contractual obligations. This also applies if the provision of the functions requires user authorisation (e.g. release of device functions). If the processing of data is not necessary for the provision of the functionalities of the application, but serves the security and development of the application or our business interests (e.g. collection of data for purposes of optimising the application or security purposes), it is carried out on the basis of our legitimate interests. The required information is identified as such in the context of the conclusion of the use, order, purchase order or comparable contract and may include the information required for the provision of services as well as contact information in order to be able to hold any consultations. If Users are explicitly asked for their consent to the processing of their data, the processing of the data covered by the consent is based on the consent.

Legal basis of processing: Contract performance and pre-contractual enquiries ( art. 6 para. 1 p. 1 lit. b GDPR), Legitimate interests (art. 6 para. 1 p. 1 lit. f GDPR). If consent has been requested, processing is carried out exclusively on the basis of art. 6 para. 1 p. 1 lit. a GDPR; consent can be revoked at any time. 

Storage of a pseudonymous identifier: In order for us to provide the application and ensure its functionality, we use a pseudonymous identifier. The identifier is a mathematical value (i.e. no clear data, such as names, is used) that is assigned to a device and/or the installation of the application installed on it. This identifier is generated when this application is installed, remains stored between the launch of the application and its updates, and is deleted when users remove the application from the device.

Device authorisations for access to functions and data: The use of our application or its functionalities may require User authorisations for access to certain functions of the devices used or to the data stored on the devices or accessible with the help of the devices. By default, these permissions must be granted by the Users and can be revoked at any time in the settings of the respective devices. The exact procedure for controlling app permissions may depend on the Users' device and software. Please note that denial or revocation of the respective permissions may affect the functionality of our app.

Access to the camera: In the course of using our application, image and/or video recordings (which also includes audio recordings) of the Users (and of other persons captured by the recordings) are processed by accessing the camera functions or stored recordings. Access to the camera functions or stored recordings requires an authorisation by the Users that can be revoked at any time. The processing of the image and/or video recordings serves in each case only to provide the respective functionality of our application, in accordance with its description to the Users, or its typical and expected functionality.

Use of microphone functions: Within the scope of the use of our application, the microphone functions and audio recordings captured with its help are processed. The use of the microphone functions requires the authorisation of the Users, which can be revoked at any time. The use of the microphone functions and audio data serves in each case only to provide the respective functionality of our application, in accordance with its description to Users, or its typical and expected functionality.

Processing of location data: In the context of the use of our application, the location data collected from the device used or otherwise entered by the Users are processed. The use of the location data requires the User's authorisation, which can be revoked at any time. The use of the location data only serves to provide the respective functionality of our application, according to its description to the Users, or its typical and expected functionality.

No location history and no movement profiles: The location data are only used selectively and are not processed to create a location history or a movement profile of the devices used or their users.

Storage period of image and sound recordings: The image and sound recordings transmitted within the scope of our applications are only processed for the purpose of transmitting them to the Users and are deleted immediately afterwards. A recording or evaluation of the image and sound data does not take place.

Data Analysis: When you access our application, your behaviour may be statistically analysed via log files (our own software) to improve our offerings or for promotional or market research purposes. Legal Basis: Art. 6 para. 1 p. 1 lit. f GDPR, we have a legitimate interest to optimise our application and improve our offerings. If consent has been requested, processing is carried out exclusively on the basis of art. 6 para. 1 p. 1 lit. a GDPR; consent can be revoked at any time. 

Application availability via app stores: so far our application is obtained via special online platforms operated by other service providers ("app stores"), the data protection notices of the respective app stores apply in addition to our data protection notices. This applies in particular with regard to the procedures used on the platforms for reach measurement and interest-based marketing as well as any obligation to pay costs.

Our social media appearances

Data Processing Through Social Networks

We maintain publicly available profiles in social networks. The individual social networks we use can be found below. 

On the Website we link to the online presence of the different social media. Our icon in this regard acts as an external link, so that no information is transmitted to the social media (e.g. Facebook) without clicking on the icon. When the user clicks on the icon, the User is redirected to the website of the respective provider. The URL of the current page is transferred as a parameter. We have no influence on whether or how the different social media (e.g.  Facebook) use this date for evaluation. If you do not want the  different social media  to collect information about the use of our Website, please do not click on the social media icons. 

Unless otherwise stated in our Privacy Policy, we process the data of users insofar as they communicate with us within the social networks and platforms, e.g. write posts on our online presences or send us messages. The data you enter yourself on our social media sites, e.g. comments, videos, pictures, likes, public messages, etc., are published by the social media platform and are only used or processed by us to inform users and communicate with users. We also reserve the right to delete content if this should be necessary. Where applicable, we share your content on our site if this is a function of the social media platform and communicate with you via the social media platform. The processing of users' personal data is based on our legitimate interests in effectively informing users and communicating with users.

Social networks such as Facebook, Instagram, Twitter etc. can generally analyse your user behaviour comprehensively if you visit their website or a website with integrated social media content (e.g. like buttons or banner ads). When you visit our social media pages, numerous data protection-relevant processing operations are triggered.

In detail: If you are logged in to your social media account and visit our social media page, the operator of the social media portal can assign this visit to your user account. Under certain circumstances, your personal data may also be recorded if you are not logged in or do not have an account with the respective social media portal. In this case, this data is collected, for example, via cookies stored on your device or by recording your IP address.Using the data collected in this way, the operators of the social media portals can create user profiles in which their preferences and interests are stored. This way you can see interest-based advertising inside and outside of your social media presence. If you have an account with the social network, interest-based advertising can be displayed on any device you are logged in to or have logged in to.

Please also note that we cannot retrace all processing operations on the social media portals. Depending on the provider, additional processing operations may therefore be carried out by the operators of the social media portals. Details can be found in the terms of use and privacy policy of the respective social media portals.

Legal basis: Our social media appearances should ensure the widest possible presence on the Internet. This is a legitimate interest within the meaning of art. 6 para. 1 p. 1 lit. f GDPR. The analysis processes initiated by the social networks may be based on divergent legal bases to be specified by the operators of the social networks (e.g. consent within the meaning of art. 6 para. 1 p. 1 lit. a GDPR).

Responsibility and assertion of rights: If you visit one of our social media sites (e.g., Facebook), we, together with the operator of the social media platform, are responsible for the data processing operations triggered during this visit. You can in principle protect your rights (information, correction, deletion, limitation of processing, data portability and complaint) vis-à-vis us as well as vis-à-vis the operator of the respective social media portal (e.g. Facebook).

Please note that despite the shared responsibility with the social media portal operators, we do not have full influence on the data processing operations of the social media portals. Our options are determined by the company policy of the respective provider.

Storage time: The data collected directly from us via the social media presence will be deleted from our systems as soon as the purpose for their storage lapses, you ask us to delete it, you revoke your consent to the storage. Stored cookies remain on your device until you delete them. Mandatory statutory provisions - in particular, retention periods - remain unaffected.

We have no control over the storage duration of your data that are stored by the social network operators for their own purposes. For details, please contact the social network operators directly (e.g. in their privacy policy, see below).

Individual Social Networks

Facebook

We have a profile on Facebook. The provider of this service is Meta Platforms Ireland, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. According to Facebook’s statement the collected data will also be transferred to the USA and to other third-party countries.

We have signed an agreement with Facebook on shared responsibility for the processing of data (Controller Addendum). This agreement determines which data processing operations we or Facebook are responsible for when you visit our Facebook Fanpage. This agreement can be viewed at the following link: https://www.facebook.com/legal/terms/page_controller_addendum.

Setting options (objection options/opt-out): You can customise your advertising settings independently in your user account. Click on the following link and log in: https://www.facebook.com/settings?tab=ads.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum and https://de-de.facebook.com/help/566994660333381 and in the Facebook privacy policy: https://www.facebook.com/about/privacy/.

Twitter

We use the short message service Twitter. The provider is Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland.

Setting options (objection options/opt-out): You can customise your Twitter privacy settings in your user account. Click on the following link and log in: https://twitter.com/personalization.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://gdpr.twitter.com/en/controller-to-controller-transfers.html.

For details, see the Twitter Privacy Policy: https://twitter.com/privacy.

Instagram

We have a profile on Instagram.The collection and further processing of personal user data on Instagram websites is basically the responsibility of Meta Platforms Ireland, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:

For details on how they handle your personal information, see the Instagram Privacy Policy: https://help.instagram.com/519522125107875.

LinkedIn

We have a LinkedIn profile. The provider is the LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. LinkedIn uses advertising cookies.

Setting options (objection options/opt-out): If you want to disable LinkedIn advertising cookies, please use the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission.

YouTube

We have a profile on YouTube. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Details on how they handle your personal data can be found in the YouTube privacy policy: https://policies.google.com/privacy?hl=en.

Reddit

We have a profile on Reddit. The provider is reddit, Inc., c/o Wired, 520 Third St., San Francisco, CA 94107. Details on how reddit handles your personal data can be found in the reddit privacy policy: http://www.reddit.com/help/privacypolicy.

Discord 

Discord Inc., 444 De Haro Street #200, San Francisco, CA 94107. Details on how Discord handles your personal data can be found in the Discord privacy Policy: https://discordapp.com/privacy.

E-Commerce 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 organisation or change of the legal relationship (data inventory). These actions are taken on the basis of art. 6 para. 1 p. 1 lit. 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 utilise 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 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 para. 1 p. 1 lit. b  GDPR, which permits the processing of data for the fulfilment of a contract or for pre-contractual actions.

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 para. 1 p. 1 lit. b  GDPR (contract processing) and in the interest of a smooth, convenient, and secure payment transaction (art. 6 para. 1 p. 1 lit. f  GDPR). Insofar as your consent is requested for certain actions, art. 6 para. 1 p. 1 lit. 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:

Paddle

We use an integration of Paddle to manage the purchasing process through our Website. Paddle is an online payment service provided by Paddle.com Market Limited or by Paddle Payments Limited, depending on the location from which this Website is accessed. Paddle is also the contracting party to the payment (Merchant of Record). 

Paddle stores information from you when you make a purchase and uses cookies (even without buying). This service can be used to analyse users' interactions and track their purchases made through this Website. 

If you do not want to share your information with Paddle, do not use the payment option on the Website. Cookies can be blocked and deleted by your browser setting. The cookies are used to improve the paddle service. 

The collected data (if you pay via the Website) are used for order processing and for order and product support. Data such as email address, country (e.g. for VAT) and other billing and payment information is collected for the reasons mentioned. The data subject has the option to revoke the consent to the processing of personal data at any time vis-à-vis Paddle. A revocation does not affect personal data that must be processed, used or transmitted for (contractual) payment processing. Read Paddle's Terms of Use and Privacy Policy here:

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.

American Express

The provider of this payment service is the American Express Europe S.A., Theodor-Heuss-Allee 112, 60486 Frankfurt am Main, Germany (hereinafter “American Express”).

American Express may transfer data to its parent company in the US. The data transfer to the US is based on the Binding Corporate Rules. Details can be found here: https://www.americanexpress.com/en-pl/company/legal/privacy-centre/european-implementing-principles/.

For more information, please see the American Express privacy policy: https://www.americanexpress.com/de/legal/online-datenschutzerklarung.html.

Mastercard

The provider of this payment service is the Mastercard Europe SA, Chaussée de Tervuren 198A, B-1410 Waterloo, Belgium (hereinafter “Mastercard”).

Mastercard may transfer data to its parent company in the US. The data transfer to the US is based on Mastercard's Binding Corporate Rules. Details can be found here:

VISA

The provider of this payment service is the Visa Europe Services Inc, London Branch, 1 Sheldon Square, London W2 6TT, United Kingdom (hereinafter “VISA”).

Great Britain is considered a secure non-EU country as far as data protection legislation is concerned. This means that the data protection level in Great Britain is equivalent to the data protection level of the European Union. VISA may transfer data to its parent company in the US. The data transfer to the US is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.visa.de/nutzungsbedingungen/visa-globale-datenschutzmitteilung/mitteilung-zu-zustandigkeitsfragen-fur-den-ewr.html.

For more information, please refer to VISA’s privacy policy: https://www.visa.de/nutzungsbedingungen/visa-privacy-center.html.

Modification and update of the privacy policy

We ask you to regularly inform yourself about the content of our Privacy Policy. We adapt the Privacy Policy as soon as the changes in the data processing carried out by us make this necessary and we reserve the right to adapt this Privacy Policy to technical and legal requirements at any time. We will inform you as soon as the changes require your consent or other individual notification otherwise your continued use of or access to our Site following the posting of any changes to this Privacy constitutes acceptance of those changes.You can view the most current version of the Privacy at any time on this page. 

Last updated: April 21, 2022