PRIVACY POLICY & DATA



This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online offer and the websites, functions and contents connected with it as well as external online presences, such as our Social Media Profile. (hereinafter jointly referred to as "online offer"). With regard to the terms used, e.g. "processing" or "responsible person", we refer to the definitions in Art. 4 of the Basic Data Protection Regulation (DSGVO).

 

Person responsible

Anett Bulano
Platz der Vereinten Nationen 6
10249 Berlin
Germany

Phone: +49 1 52 3389481
e-mail: mail@anettbulano.com

 

types of data processed:

 

- stock data (for example, names, addresses).
- Contact data (e.g., e-mail, telephone numbers).
- Content data (e.g., text input, photographs, videos).
- usage data (e.g., web pages visited, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).

 

Categories of data subjects

 

Visitors and users of the online offer (in the following we will refer to the persons concerned collectively as "users").

 

Purpose of processing

 

- Provision of the online offer, its functions and contents.
- Answering of contact requests and communication with users.
- security measures.
- Range measurement/Marketing

 

Used terms

 

"Personal data" shall mean any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person

"Processing" means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually all processing of data.

controller" shall mean the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data

 

Relevant legal bases

 

In accordance with Art. 13 DSGVO, we inform you of the legal basis of our data processing. If the legal basis is not stated in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 Para. 1 lit. a and Art. 7 DSGVO, the legal basis for processing for the purpose of fulfilling our services and implementing contractual measures and answering enquiries is Art. 6 Para. 1 lit. b DSGVO, the legal basis for processing for the purpose of fulfilling our legal obligations is Art. 6 Para. 1 lit. c DSGVO, and the legal basis for processing for the purpose of safeguarding our legitimate interests is Art. 6 Para. 1 lit. f DSGVO. In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6 paragraph 1 letter d DSGVO serves as the legal basis.

 

Cooperation with processors and third parties

 

If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transfer it to them or otherwise grant them access to the data, this is only done on the basis of a legal authorisation (e.g. if the data must be transferred to third parties, such as payment service providers, in accordance with Art. 6 Para. 1 letter b DSGVO for the fulfilment of the contract), if you have given your consent, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we commission third parties to process data on the basis of a so-called "contract processing agreement", this is done on the basis of Art. 28 DSGVO.

 

Transfers to third countries

 

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using the services of third parties or disclosure or transfer of data to third parties, this will only take place if it is done to fulfil our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we will only process or transfer the data in a third country if the special requirements of Art. 44 ff. DSGVO. This means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognised determination of a level of data protection corresponding to that of the EU (e.g. for the USA through the "Privacy Shield") or compliance with officially recognised special contractual obligations (so-called "standard contractual clauses").

 

Rights of data subjects

 

You have the right to obtain confirmation as to whether or not data in question is being processed and to obtain information about this data and to receive further information and a copy of the data in accordance with Art. 15 DSGVO.

You have accordingly. Art. 16 DPA, you have the right to request the completion of data concerning you or the correction of incorrect data concerning you.

In accordance with Art. 17 DSGVO, you have the right to demand that data concerning you be deleted immediately, or alternatively, in accordance with Art. 18 DSGVO, to demand that the processing of the data be restricted.

You have the right to demand that the data concerning you which you have made available to us be received in accordance with Art. 20 DSGVO and to demand that it be passed on to other responsible parties.

You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 DSGVO.

 

Right of withdrawal

 

You have the right to revoke consents granted in accordance with Art. 7 Para. 3 DSGVO with effect for the future

 

Right of objection

 

You can object to the future processing of data concerning you at any time in accordance with Art. 21 DSGVO. The objection may in particular be made against processing for the purposes of direct advertising.

 

Cookies and right of objection for direct advertising

 

"Cookies" are small files that are stored on the user's computer. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the contents of a shopping cart in an online shop or a login jam can be stored. Cookies are described as "permanent" or "persistent" if they remain stored even after the browser is closed. For example, the login status can be saved if users visit the site after several days. Likewise, the interests of the users can be stored in such a cookie, which are used for range measurement or marketing purposes. Third-party cookies" are cookies that are offered by providers other than the person responsible for the online offer (otherwise, if it is only their cookies, it is called "first-party cookies").

We may use temporary and permanent cookies and provide information about this in our privacy policy.

If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that in this case not all functions of this online offer can be used.

 

deletion of data

 

The data processed by us will be deleted or restricted in their processing in accordance with articles 17 and 18 DSGVO. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory storage obligations. If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

In accordance with legal requirements in Germany, data is stored in particular for 6 years in accordance with § 257 Paragraph 1 HGB (commercial books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting vouchers, etc.) and for 10 years in accordance with § 147 Paragraph 1 AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc.).

According to legal requirements in Austria, the storage is carried out in particular for 7 J according to § 132 para. 1 BAO (accounting documents, records/invoices, accounts, vouchers, business documents, statement of income and expenditure, etc.), for 22 years in connection with real estate and for 10 years in the case of documents in connection with electronically provided services, telecommunications, radio and television services provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.

 

Business-related processing

 

Additionally we process
- Contract data (e.g., subject matter of the contract, duration, customer category).
- Payment data (e.g., bank details, payment history)
from our customers, interested parties and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

 

Hosting

 

The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, security services as well as technical maintenance services that we use for the purpose of operating this online offer.

In doing so, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer in accordance with Art. 6 para. 1 lit. f DSGVO in conjunction with Art. 28 DSGVO (conclusion of contract processing agreement).

 

Collection of access data and log files

 

We, or our hosting provider, on the basis of our legitimate interests as defined in Art. 6 Par. 1 lit. f. DSGVO data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the accessed website, file, date and time of access, transferred data volume, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited site), IP address and the requesting provider.

For security reasons (e.g. to clarify misuse or fraud), log file information is stored for a maximum of 7 days and then deleted. Data whose further storage is required for evidence purposes is excluded from deletion until the respective incident has been finally clarified.

 

Provision of contractual services

 

We process inventory data (e.g., names and addresses as well as contact data of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services in accordance with Art. 6 Par. 1 lit. b. DSGVO. The entries marked as obligatory in online forms are required for the conclusion of the contract.

When using our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user's protection against misuse and other unauthorized use. This data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 Para. 1 lit. c DSGVO.

We process usage data (e.g., the visited websites of our online offer, interest in our products) and content data (e.g., entries in the contact form or user profile) for advertising purposes in a user profile in order to show the user e.g., product information based on the services they have used so far.

The deletion of the data is carried out after the expiry of legal warranty and comparable obligations, the necessity of keeping the data is reviewed every three years; in the case of legal archiving obligations, the deletion is carried out after their expiry. Data in any customer account will remain until it is deleted.

 

Contact

 

When contacting us (e.g. by contact form, e-mail, telephone or via social media), the user's details are processed for the purpose of handling the contact request and its processing in accordance with Art. 6 Para. 1 lit. b) DSGVO. The user's details may be stored in a customer relationship management system ("CRM system") or comparable enquiry organisation.

We delete the enquiries if they are no longer required. We review the necessity every two years; furthermore, the statutory archiving obligations apply.

 

Akismet anti-spam check

 

Our online offering uses the "Akismet" service, which is provided by Automattic, Inc. 132 Hawthorne Street San Francisco, CA 94107, USA. The use is made on the basis of our legitimate interests in the sense of Art. 6 para. 1 lit. f) DSGVO. With the help of this service, comments from real people are distinguished from spam comments. For this purpose, all comment data is sent to a server in the USA, where it is analysed and stored for four days for comparison purposes. If a comment has been classified as spam, the data is stored beyond this period. This information includes the name entered, the email address, the IP address, the comment content, the referrer, information on the browser used and the computer system and the time of entry.

Automattic is certified under the Privacy Shield Agreement, which guarantees that it complies with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000CbqcAAC&status=Active).

For more information about Akismet's collection and use of data, please refer to Automattic's Privacy Policy: https://automattic.com/privacy/.

Users are welcome to use pseudonyms, or refrain from entering their name or email address. You can completely prevent the transmission of data by not using our comment system. This would be a pity, but unfortunately we do not see any other alternatives that work as effectively.

 

Jetpack (WordPress Stats)

 

On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) the plugin Jetpack (here the sub-function "Wordpress Stats"), which integrates a tool for the statistical evaluation of visitor access and is provided by Automattic, Inc. 132 Hawthorne Street San Francisco, CA 94107, USA. Jetpack uses so-called "cookies", text files which are stored on your computer and which enable an analysis of your use of the website.

Automattic is certified under the Privacy Shield Agreement, which guarantees that it complies with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000CbqcAAC&status=Active).

The information generated by the cookie about your use of this website is stored on a server in the USA. User profiles can be created from the processed data, whereby these are only used for analysis and not for advertising purposes. For more information, please refer to Automattic's privacy policy: https://automattic.com/privacy/ and notes on Jetpack cookies: https://jetpack.com/support/cookies/.

 

Google Analytics

 

On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) we use Google Analytics, a web analysis service of Google LLC ("Google"). Google uses cookies. The information generated by the cookie about the use of the website by the user is usually transferred to a Google server in the USA and stored there.

Google is certified under the Privacy-Shield-Agreement and thus offers a guarantee to comply with the European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google will use this information on our behalf to evaluate the use of our website by users, to compile reports on the activities within this website and to provide us with further services associated with the use of this website and the Internet. In doing so, pseudonymous user profiles of the users can be created from the processed data.

We only use Google Analytics with activated IP anonymisation. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transferred to a Google server in the USA and shortened there.

The IP address transmitted by the user's browser is not merged with other Google data. Users can prevent the storage of cookies by adjusting their browser software accordingly; users can also prevent the collection of data generated by the cookie and relating to their use of the online offer to Google and the processing of this data by Google by downloading and installing the browser plugin available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

You can find further information on data use by Google, setting and objection options on the websites of Google: https://www.google.com/intl/de/policies/privacy/partners ("Data use by Google when you use websites or apps of our partners"), http://www.google.com/policies/technologies/ads ("Data use for advertising purposes"), http://www.google.de/settings/ads ("Manage information that Google uses to show you advertising").

 
Online presence in social media

 

We maintain online presences within social networks and platforms in order to be able to communicate with the customers, interested parties and users active there and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.

Unless otherwise stated in our data protection declaration, we process the data of users if they communicate with us within the social networks and platforms, e.g. write articles on our online presences or send us messages.

 

Integration of third party services and content

 

Within our online offer, we set within our online offer on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer in the sense of Art. 6 Par. 1 lit. f. DSGVO), we use content or service offers from third parties in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as "content").

This always presupposes that the third-party providers of these contents are aware of the IP address of the users, as without the IP address they would not be able to send the contents to their browsers. The IP address is therefore necessary for the display of this content. We make every effort to use only such content whose respective providers use the IP address only to deliver the content. Third party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain technical information about the browser and operating system, referring websites, visiting time and other details about the use of our online offer, as well as being linked to such information from other sources.

 

Google Fonts

 

We integrate the fonts ("Google Fonts") of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

 

Use of Facebook Social Plugins

 

On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO) Social Plugins ("Plugins") of the social network facebook.com, which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"). The Plugins can display interaction elements or content (e.g. videos, graphics or text contributions) and can be recognized by one of the Facebook logos (white "f" on blue tile, the words "Like", "Like" or a "thumbs up" sign) or are marked with the addition "Facebook Social Plugin". The list and appearance of the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/.

Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

When a user calls up a function of this online offer that contains such a plugin, his or her device establishes a direct connection with the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user's device and integrated into the online offer by the user. User profiles can be created from the processed data. We therefore have no influence on the scope of the data that Facebook collects with the help of this plugin and therefore inform the users according to our state of knowledge.

By integrating the plugins, Facebook receives the information that a user has called up the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to his or her Facebook account. If users interact with the plugins, for example, by pressing the Like button or making a comment, the corresponding information is transmitted directly from your device to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to find out his or her IP address and store it. According to Facebook, only an anonymized IP address is stored in Germany.

The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the relevant rights and setting options to protect the privacy of users, can be found in the Facebook privacy policy: https://www.facebook.com/about/privacy/.

If a user is a Facebook member and does not want Facebook to collect data about him or her via this online offer and link it to his or her membership data stored on Facebook, he or she must log out of Facebook and delete his or her cookies before using our online offer. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US-American page http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.

 

Instagram

 

Within our online offer, functions and contents of the service Instagram can be integrated, offered by Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA. This may include, for example, content such as images, videos, or text and buttons that allow users to express their favorites regarding the content, the authors of the content, or to subscribe to our posts. If users are members of the Instagram platform, Instagram may associate the invocation of the above content and features with their profiles. Instagram Privacy Policy: http://instagram.com/about/legal/privacy/.

Created with Datenschutz-Generator.de by RA Dr. Thomas Schwenke

 
SSL encryption

 

This site uses SSL encryption for security reasons and to protect the transmission of confidential content, such as the requests you send to us as site operator. You can recognise an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.

If SSL encryption is activated, the data you send to us cannot be read by third parties.

 

Right to information, deletion, blocking

 

You have the right to receive information free of charge at any time about your stored personal data, its origin and recipients and the purpose of data processing, as well as the right to correct, block or delete this data. For this purpose, as well as for further questions regarding personal data, you can contact us at any time at the address given in the imprint.

Source: eRecht24