Privacy Policy

 

Thank you for your interest in our website. The protection of your personal data is a very important concern to us. Below you will find information about how we handle the data collected through your use of our website. Processing of your data is carried out in accordance with legal data protection regulations.

When you use this website, various personal data is collected. Personal data are data that can be used to personally identify you. This privacy policy explains what data we collect and how we use it, as well as the purpose of such use.

We would like to point out that data transmission over the Internet (e.g. communication by email) may have security vulnerabilities. A complete protection of your data from access by third parties is not possible.

 

1. Responsible entity in terms of data protection law

The responsible entity is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data (such as names, email addresses, etc.).

 

HeKu IT GmbH – IT Solutions & Services

Dieselstraße 10, 85748 Garching, Germany

 

Contact:

Phone: +49 89 36 03 81 90

Fax: +49 89 85 63 53 25

Email: privacy@readingtrainer.com

 

2. General notes and mandatory information

General notes
The following notes provide a simple overview of what happens to your personal data when you visit this website. Personal data refers to all data that can be used to personally identify you. Below you will find detailed information on data protection:

Data Collection on this Website
Who is responsible for the data collection on this website?
Data processing on this website is carried out by the website operator. You can find their contact details under section 1 “Responsible entity in terms of data protection law”.

How do we collect your data?
Your data is collected when you provide it to us. This may be, for example, data that you enter in a contact form. Other data is automatically collected or collected with your consent when you visit the website by our IT systems. These are mainly technical data (such as internet browser, operating system or time of page access). This data is collected automatically as soon as you enter this website.

Storage duration
Unless a more specific storage period has been mentioned in this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you make a legitimate deletion request or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (such as tax or commercial retention periods); in the latter case, deletion will take place after these reasons have ceased to exist.

 

3. How do we use your data and on what legal basis?

General information on the legal basis for data processing on this website
If you have given your consent to data processing, we will process your personal data on the basis of Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR if special categories of data pursuant to Art. 9 para. 1 GDPR are processed. In case of explicit consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49 para. 1 lit. a GDPR. If you have given your consent to the storage of cookies or access to information on your end device (e.g. via device fingerprinting), data processing will also be carried out on the basis of § 25 para. 1 TTDSG. The consent can be revoked at any time. If your data is required for the performance of a contract or for the implementation of pre-contractual measures, we will process your data on the basis of Art. 6 para. 1 lit. b GDPR. Furthermore, we will process your data if it is necessary to fulfill a legal obligation on the basis of Art. 6 para. 1 lit. c GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR. The relevant legal bases in each individual case are explained in the following paragraphs of this privacy policy.

Some of the data is collected to ensure error-free provision of the website. Other data may be used to analyze your user behavior.

We process your personal data for the following purposes and on the basis of the legal bases mentioned. In case the data processing is based on a balancing of interests, we will also explain our legitimate interest that we pursue with the processing:

No. Purpose of processing. Legal basis of processing and explanation of legitimate interest, where applicable.
1 Provision of this online service and fulfillment of contract according to our terms of use. Fulfillment of contract.
2 Personalization of the offer. Fulfillment of contract or consent.
3 Analysis of the offer to determine usage behavior, including market research and reach measurement. Balance of interests; we have a legitimate interest in analyzing usage behavior in our online offer in order to continuously improve it or adapt it to the interests of our users.
4 Self-promotion within legally permissible limits or based on consent. Consent or balance of interests; we have a legitimate interest in direct marketing as long as it is in compliance with data protection and competition law requirements.
5 Sending existing customer information about our own offers without registration. Balance of interests; we have a legitimate interest in direct marketing as long as marketing is carried out in compliance with data protection and competition law requirements.
6 Sending a newsletter with the recipient’s consent via email. Contract fulfillment, or consent.
7 Integration of social plugins and social share functions. Interests balancing; we have a legitimate interest in fulfilling the request of our users who have activated a social plugin to share their information with the corresponding social network.
8 Providing a login via social networks (Social Sign In). Contract fulfillment.
9 Detection of disruptions and ensuring system security including identification and tracking of unauthorized access and access attempts to our web servers. The fulfillment of our legal obligations in the area of data security as well as a balancing of interests; we have a legitimate interest in remedying disruptions, ensuring system security, and detecting and tracking unauthorized access attempts or accesses.
10 Protection and defense of our rights. Interests balancing; we have a legitimate interest in asserting and defending our rights.

Upon request, you can obtain information from us regarding the balancing of interests we have carried out. To do so, simply use the contact information provided in the Contact section.

Please be aware of your right to object to the processing of your data for the purposes of direct marketing or for personal reasons (see the following section).

Processing of customer and contract data
We collect, process, and use personal customer and contract data to establish, design, and modify our contractual relationships. We only collect, process, and use personal data regarding the use of this website (usage data) to the extent necessary to enable or bill the user for using the service. The legal basis for this is Art. 6 (1) lit. b GDPR.

The collected customer data will be deleted after completion of the order or termination of the business relationship and expiration of any legal retention periods that may apply. Legal retention periods remain unaffected.

 

4. Registration and Contact

Inquiries by email, telephone, or fax
If you contact us by email, your inquiry, including all personal data resulting from it (name, inquiry), will be stored and processed by us for the purpose of processing your request. We do not pass on this data without your consent.

The processing of this data is based on Art. 6 (1) lit. b GDPR, provided that your request is related to the fulfillment of a contract or necessary to carry out pre-contractual measures. In all other cases, the processing is based on our legitimate interest in effectively processing the inquiries addressed to us (Art. 6 (1) lit. f GDPR) or on your consent (Art. 6 (1) lit. a GDPR), if requested; consent can be revoked at any time.

The data sent by you to us via contact inquiries will remain with us until you request us to delete it, revoke your consent to store it, or the purpose for data storage no longer applies (e.g., after completing the processing of your request). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

Contact form
If you send us inquiries via the contact form, your details from the inquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the inquiry and in the event of follow-up questions. We do not pass on this data without your consent.

The processing of this data is based on Art. 6 (1) lit. b GDPR, provided that your request is related to the fulfillment of a contract or necessary to carry out pre-contractual measures. In all other cases, the processing is based on our legitimate interest in effectively processing the inquiries addressed to us (Art. 6 (1) lit. f GDPR) or on your consent (Art. 6 (1) lit. a GDPR), if requested; consent can be revoked at any time.

The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent to store it, or the purpose for data storage no longer applies (e.g., after completing the processing of your request). Mandatory statutory provisions – in particular retention periods – remain unaffected.

Registration and Login via Email
You can register with your email address to use additional features of READING TRAINER. We will only use the data entered for the purpose of using the respective offer or service for which you have registered. The mandatory information requested during registration must be provided in full. Otherwise, we will reject the registration.

For important changes, such as the scope of services or technical changes, we will use the email address provided during registration to inform you in this way.

The processing of the data entered during registration is based on your consent (Art. 6 (1) (a) GDPR). You can revoke consent you have given at any time. An informal email to us is sufficient for this purpose. The legality of the data processing already carried out remains unaffected by the revocation.

The data collected during registration will be stored by us as long as you are registered on our website and will subsequently be deleted. Statutory retention periods remain unaffected.

Social Sign In (Registration and Login via Social Networks)

Amazon
We offer you the option to register or log in with your Amazon account. If you choose to do so, we will receive the data necessary for registration or login (e.g., email address, name) from Amazon.com, Inc., P.O. Box 81226, Seattle, WA 98108-1226, USA (“Amazon”).

We have no influence on the extent of data collected by Amazon through the Amazon Login. If you do not want Amazon to collect data about you in connection with your use of our online offerings and use it for its own purposes, you should not use the Amazon Login.

For more information on the purpose and scope of data collection as well as further processing and use of your data by Amazon, as well as your rights and options for protecting your data, please refer to Amazon’s privacy policy.

https://www.amazon.de/gp/help/customer/display.html/ref=hp_bc_nav?ie=UTF8&nodeId=201908990

Apple
We offer you the option to register or log in with your Apple account. If you choose to do so, we will receive the data necessary for registration or login (e.g., email address, name) from Apple Inc., One Apple Park Way, Cupertino, California, USA, 95014 (“Apple”).

We have no influence on the scope of data collected by Apple through Apple Login. If you do not want Apple to collect data about you in connection with your use of our online offerings and use it for their own purposes, you should not use Apple Login.

For more information on the purpose and scope of data collection as well as further processing and use of your data by Apple, as well as your rights and options for protecting your data, please refer to Apple’s privacy policy:

https://www.apple.com/privacy/

Facebook
Instead of direct registration on our website, you can register with Facebook Connect. This service is provided by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland.

If you choose to register with Facebook Connect and click on the “Login with Facebook” / “Connect with Facebook” button, you will be automatically redirected to the Facebook platform. There you can log in with your user data. This links your Facebook profile with our website or services. Through this link, we gain access to the data stored on Facebook. These are mainly:

● Facebook name
● Facebook profile and cover picture
● Facebook cover picture
● Email address stored on Facebook
● Facebook ID
● Facebook friend lists
● Facebook likes
● Birthday
● Gender
● Country
● Language
This data is used for setting up, providing, and personalizing your account.

For more information, please refer to Facebook’s terms of use and privacy policy, which can be found at https://www.facebook.com/about/privacy/ and https://www.facebook.com/legal/terms/.

Google
We also offer you the possibility to register or log in using your Google+ account. If you choose to use this service, we will receive the data necessary for registration or log in from Google, such as your email address and name.

We have no control over the scope of data collected by Google through Google OAuth. If you do not want Google to collect data about you in connection with your use of our online services for its own purposes, you should not use this login method.

For more information about the purpose and scope of data collection, as well as the further processing and use of your data by Google, and your rights and options for protecting your privacy, please see Google’s privacy policy at https://policies.google.com/privacy.

We allow users to log in to our website using their Google account. For this, we use Google OAuth 2.0, which allows for API authorization by the user without us receiving the user’s access data. By logging in through the Google OAuth 2.0 process and subsequently confirming access in the OAuth consent screen, personal data may be sent from Google to us and from us to Google. This refers to information such as IP address, browser used, etc., and not private data such as full name or address.

Information about what data Google collects and how it processes that data can be found in Google’s privacy policy (https://policies.google.com/technologies/partner-sites?hl=en).

By using the Google OAuth 2.0 function on one of our websites, the user explicitly agrees to its use. API requests are therefore only authorized if the user actively decides to share this data with us via the Google OAuth 2.0 process, has been informed about the necessary information for processing, and has confirmed receipt of this information. The legal basis in this case is consent pursuant to Art. 6 para. 1 sentence 1 lit. a GDPR.

 

5. Your rights

What rights do you have regarding your data?
You have the right to receive free information about the origin, recipient, and purpose of your stored personal data at any time. You also have the right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. In addition, under certain circumstances, you have the right to demand the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority (https://www.lda.bayern.de/de/index.html)

For this purpose, as well as for any other questions concerning data protection, you can contact us at any time at privacy@readingtrainer.com.

How can you assert your rights?
Please use the contact information provided in the Contact section to assert your rights. Please ensure that we are able to clearly identify you as a person.

Alternatively, you can use the settings in your user account to correct the data provided during registration or to object to advertising.

Please note that your data will initially only be blocked if retention periods prevent deletion.

Below you will find a detailed list of your rights as a data subject:

Withdrawal of your consent to data processing:

Many data processing operations are only possible with your express consent. You can revoke consent that has already been given at any time. The legality of data processing carried out prior to the revocation will not be affected by the withdrawal.

Right to object to data collection in special cases and to direct advertising (Art. 21 GDPR):

If data processing is based on Art. 6 para. 1 lit. e or f GDPR, you have the right to object at any time, for reasons that arise from your particular situation, to the processing of your personal data, including profiling based on these provisions. The respective legal basis on which a processing is based can be found in this privacy policy. If you object, we will no longer process your personal data, unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or the processing serves the assertion, exercise or defense of legal claims (objection according to Art. 21 para. 1 GDPR).

If your personal data is processed for direct advertising purposes, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising, including profiling to the extent that it is related to such direct advertising. If you object, your personal data will no longer be used for direct advertising purposes (objection according to Art. 21 para. 2 GDPR).

Right to lodge a complaint with the supervisory authority:
In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or the place of the alleged infringement. The right to lodge a complaint is without prejudice to other administrative or judicial remedies. The supervisory authority responsible for us is the Bavarian State Office for Data Protection Supervision (https://www.lda.bayern.de/en/complaint.html).

Right to data portability:
You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done to the extent that it is technically feasible.

Information, deletion, and correction
You have the right, in accordance with applicable legal provisions, to obtain free information about your stored personal data, their origin and recipients, and the purpose of data processing. You also have the right to correct or delete this data if necessary. For this purpose, as well as for any further questions regarding personal data, you can contact us at any time.

Right to restriction of processing
You have the right to request the restriction of processing of your personal data. To do so, you can contact us at any time. The right to restriction of processing exists in the following cases:
● If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. During the time of verification, you have the right to request the restriction of processing of your personal data.
● If the processing of your personal data was/is unlawful, you can request the restriction of data processing instead of deletion.
● If we no longer need your personal data, but you need it for the exercise, defense or assertion of legal claims, you have the right to request the restriction of processing of your personal data instead of deletion.
● If you have objected to processing pursuant to Art. 21 para. 1 GDPR, a balancing of your interests and ours must be carried out. As long as it is not yet clear whose interests prevail, you have the right to request the restriction of processing of your personal data.
If you have restricted the processing of your personal data, these data – apart from their storage – may only be processed with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.

 

6. Hosting

We host the content of our services with the following provider:

Amazon Web Services (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 website, your personal data is processed on AWS servers. This may also involve the transfer of personal data to the parent company of AWS in the USA. The transfer of data to the USA is based on the EU standard contractual clauses. Details can be found here: https://aws.amazon.com/de/blogs/security/aws-gdpr-data-processing-addendum/

Further information can be found in the AWS privacy policy: https://aws.amazon.com/privacy/?nc1=f_pr

The use of AWS is based on Art. 6 para. 1 lit. f GDPR. We have a legitimate interest in the most reliable presentation of our website. If the corresponding consent has been requested, processing will only take place on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information on the user’s device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.

Contract data processing
We have concluded a contract for order data processing (ODP) for the use of the above-mentioned service. This is a legally required contract that ensures that this service provider processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

 

7. Note on data transfer to the USA and other third countries

We use tools from companies based in the USA or other countries outside the EU that do not offer the same level of data protection as in the EU. When these tools are active, your personal data may be transferred to and processed in these third countries. We would like to point out that there is no guarantee that these countries will provide a level of data protection comparable to that of the EU. For example, US companies are required to disclose personal data to security authorities without the possibility of the data subject being able to take legal action against this. It cannot be ruled out that US authorities (e.g. intelligence agencies) will process, evaluate and permanently store your data located on US servers for monitoring purposes. We have no control over these processing activities.

 

8. Encrypted payment transactions on this website

If, after concluding a paid contract, you are obliged to transmit your payment data to us, we will need this data for payment processing. Payment transactions via the common payment methods (Visa/MasterCard) are exclusively processed via an encrypted SSL/TLS connection. You can recognize 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.

With encrypted communication, your payment data that you transmit to us cannot be read by third parties.

 

9. SSL/TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize 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 or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

 

10. Cookies, analysis tools, and other third-party tools

When you visit this website, your surfing behavior may be statistically evaluated. This is done primarily with so-called analysis programs.

Detailed information on these analysis programs can be found in the following privacy policy.

Cookies

Our website uses so-called “cookies”. Cookies are small data packets that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your device. Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your device until you delete them yourself or automatic deletion by your web browser occurs.

Third-party cookies may also be stored on your device when you enter our site. These enable us or you to use certain services of the third-party provider (e.g. cookies for payment processing).

Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies are used to analyze user behavior or display advertising.

Cookies that are necessary for electronic communication, the provision of certain functions requested by you (e.g. for the shopping cart function), or the optimization of the website (e.g. cookies for measuring web audiences) are stored on the basis of Art. 6 para. 1 lit. f DSGVO, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of his services. If consent to the storage of cookies and similar recognition technologies has been requested, processing will be carried out exclusively on the basis of this consent (Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG); consent can be revoked at any time.

You can adjust your browser settings to be notified about the setting of cookies and to allow cookies only on a case-by-case basis, to refuse cookies for specific cases or in general, or to enable the automatic deletion of cookies when closing your browser. However, disabling cookies may limit the functionality of this website.

Where cookies are used by third-party providers or for analytical purposes, we will inform you separately in this privacy policy and, if necessary, request your consent.

Consent with Cookiebot

Our website uses the Cookiebot consent technology to obtain your consent to the storage of certain cookies on your device or to the use of certain technologies and to document this in compliance with data protection regulations. The provider of this technology is Cybot A/S, Havnegade 39, 1058 Copenhagen, Denmark (hereinafter “Cookiebot”).

When you enter our website, a connection is made to the Cookiebot servers to obtain your consents and other declarations regarding the use of cookies. Cookiebot then stores a cookie in your browser to associate the consents granted or their revocation. The data collected in this way is stored until you request us to delete it, delete the Cookiebot cookie yourself, or the purpose of the data storage no longer applies. Mandatory legal retention periods remain unaffected.

The use of Cookiebot is for the purpose of obtaining the legally required consents for the use of cookies. The legal basis for this is Art. 6 para. 1 lit. c DSGVO.

Server log files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

● Browser type and browser version
● Operating system used
● Referrer URL
● Host name of the accessing computer
● Time of the server request
● IP address

Combining this data with other data sources is not done.

The collection of this data is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of its website – for this purpose, the server log files must be recorded.

Google Analytics

This website uses Google Analytics, a web analysis service of Google Inc. (“Google”). Google Analytics uses so-called “cookies”, text files which are stored on your computer and which enable an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. However, if IP anonymisation is activated on this website, your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area beforehand. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. IP anonymisation is active on this website.

On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link:
http://tools.google.com/dlpage/gaoptout?hl=en

Google reCAPTCHA

We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

reCAPTCHA is used to check whether the data entered on this website (e.g. in a contact form) is being entered by a human or by an automated program. To do this, reCAPTCHA analyses the behaviour of the website visitor using various characteristics. This analysis starts automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, length of time the website visitor stays on the website or mouse movements made by the user). The data collected during the analysis is forwarded to Google.

reCAPTCHA analyses run completely in the background. Website visitors are not informed that an analysis is taking place.

The storage and analysis of data is based on Art. 6 para. 1 lit. f DSGVO. The website operator has a legitimate interest in protecting its web offers against abusive automated spying and spam. If appropriate consent has been requested, processing will be based exclusively on Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information on the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.

For more information on Google reCAPTCHA, please refer to Google’s privacy policy and terms of use at the following links: https://policies.google.com/privacy?hl=en and https://policies.google.com/terms?hl=en.

Google Tag Manager

This website uses Google Tag Manager. Google Tag Manager is a solution that allows marketers to manage website tags through an interface. The tool itself that implements the tags is a cookieless domain for the user and does not collect any personal data. The tool triggers other tags, which may collect data. Google Tag Manager does not access this data. If deactivation has been carried out at the domain or cookie level, this remains for all tracking tags implemented with Google Tag Manager.

AppsFlyer

On the basis of Art. 6 para. 1 letter f of the General Data Protection Regulation, we use the AppsFlyer analysis service of AppsFlyer Ltd, 85 Medinat Hayehudim St. Herzliya, Israel. We have a legitimate interest in information about the success of marketing measures. With the AppsFlyer service, we measure the success of our campaigns. We receive information from AppsFlyer in aggregated form. In order to track the use of a mobile application, we transmit information about downloads and installations to AppsFlyer, as well as information about “in-app events” such as in-app purchases. You can object to the collection and storage of data by AppsFlyer with effect for the future at any time by following the instructions at https://www.appsflyer.com/optout.

AppsFlyer receives information from the data transmitted by the SDKs (Software Development Kit) in a mobile end user application to the servers. The data collected by the SDKs includes information such as IP addresses (anonymized), browser, platform, SDK version, anonymized user ID, time key, developer key, application version, and device identifiers (such as Identifier For Advertisers), Google advertising ID, device model, device manufacturer, operating system version, in-app events, and network status (WLAN/3G). The end-user data collected by the AppsFlyer platform is representative for us to analyze our applications.

OTRS

We use the email ticket system of OTRS AG, Zimmersmühlenweg 11, 61440 Oberursel (“OTRS”) to process customer inquiries. If users of our website submit contact inquiries via email, these are stored and organized in the ticket system to enable chronological processing and improve the service experience. Users can always view the current status of their request via the individually assigned ticket number.

Personal data, such as name, first name, and email address, are collected, transmitted to OTRS, and stored and read there solely for the organization and processing of inquiries, to the extent provided in the request. The legal basis for the processing of this data is our legitimate interest in the efficient design of our customer service, the fastest possible response to your request, and the optimization of our service offerings in accordance with Art. 6 para. 1 lit. f DSGVO.

We have concluded a contract for order processing with OTRS, obliging OTRS to protect our customers’ data and not to disclose it to third parties.

Your data will be deleted after the final processing of your request. This is the case if the circumstances indicate that the matter in question has been conclusively clarified and if there are no statutory retention obligations to the contrary.

Further information on data protection at OTRS can be found at https://otrs.com/de/dsgvo/

 

11. Newsletter

Newsletter Data

If you wish to receive the newsletter offered on the website, we require an email address from you as well as information that allows us to verify that you are the owner of the specified email address and that you agree to receive the newsletter. No further data is collected unless on a voluntary basis. We use this data exclusively for sending the requested information and do not pass it on to third parties.

The processing of the data entered in the newsletter registration form is based exclusively on your consent (Art. 6 para. 1 lit. a GDPR). You can revoke your consent to the storage of the data, the email address and their use for sending the newsletter at any time, for example via the “unsubscribe” link in the newsletter. The legality of the data processing operations already carried out remains unaffected by the revocation.

The data you provide us for the purpose of subscribing to the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter or until the purpose for data storage no longer applies. We reserve the right to delete or block email addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR.

This means: Data that has been stored with us for other purposes remains unaffected by this.

Newsletter delivery with Mailjet

This website uses Mailjet to send newsletters. The provider is Mailjet SAS, 13-13 bis, Rue de l’Aubrac – 75012 Paris, France. Mailjet is a service that can be used to organize and analyze newsletter delivery. The data you enter for the purpose of receiving newsletters (e.g., email address) is stored on Mailjet’s servers in the EU.

Our newsletters sent via Mailjet allow us to analyze the behavior of newsletter recipients. This can include, among other things, analyzing how many recipients opened the newsletter message and how often a link in the newsletter was clicked. The so-called conversion tracking also enables us to analyze whether a predefined action (e.g., purchase of a product on our website) has occurred after clicking the link in the newsletter. More information about data analysis through Mailjet newsletters can be found at: https://mailjet.de/funktion/tracking-tools

Mailjet also allows us to divide newsletter recipients into different categories (“segmentation”). Newsletter recipients can be divided according to the data provided during registration. This allows newsletters to be better tailored to the respective target groups.
Detailed information on the features of Mailjet can be found at the following link: https://mailjet.de/funktion

The data processing is based on your consent (Art. 6 para. 1 lit. a DSGVO). You can revoke this consent at any time by unsubscribing from the newsletter. The legality of the data processing that has already taken place is not affected by the revocation.

If you do not want analysis by Mailjet, you must unsubscribe from the newsletter. We provide a corresponding link for this purpose in every newsletter message.

The data you provide for the purpose of receiving newsletters will be deleted from Mailjet’s servers after you unsubscribe from the newsletter. We do not store any data ourselves.

For more information on “Security and Privacy” by Mailjet, please visit: https://mailjet.de/sicherheit-datenschutz and the Mailjet Privacy Policy at: https://mailjet.de/privacy-policy

 

12. Processing of data by credit institutions and payment service providers; debt collection

We integrate payment services from third-party companies on our website. When you make a purchase from us, your payment data (e.g. name, payment amount, account information, credit card number) will be processed by the payment service provider for the purpose of payment processing. The respective provider’s contractual and data protection provisions apply to these transactions. The use of payment service providers is based on Art. 6 para. 1 lit. b GDPR (performance of a contract) as well as in the interest of a smooth, convenient, and secure payment transaction (Art. 6 para. 1 lit. f GDPR). If your consent is required for certain actions, the legal basis for data processing is Art. 6 para. 1 lit. a GDPR; consents can be revoked at any time for the future.

We use the following payment services/payment service providers as part of this website:

Stripe

For customers within the EU, the provider is Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland (hereinafter “Stripe”).

Data transfer to the USA is based on the standard contractual clauses of the European Commission. Details can be found here: https://stripe.com/de/privacy and https://stripe.com/de/guides/general-data-protection-regulation

You can find details on this in Stripe’s privacy policy at the following link: https://stripe.com/de/privacy

Debt collection

We reserve the right to have third-party service providers collect debts on our behalf as so-called processors.

In addition, we have a legitimate interest in selling claims to third parties and in this context transmitting to the respective buyer of the claim the data required for debt collection. In the collection of debts, buyers of claims act in their own name and process the transmitted data under their own responsibility. The data protection provisions of the respective claim buyer apply in this respect.

Transmission of data upon conclusion of contracts for services and digital content

We only transmit personal data to third parties if this is necessary within the scope of contract processing, for example to the credit institution commissioned with payment processing.

Further transmission of the data does not take place, unless you have expressly consented to the transmission. Your data will not be disclosed to third parties for advertising purposes without your express consent.

The basis for data processing is Art. 6 (1) lit. b GDPR, which permits the processing of data for the performance of a contract or pre-contractual measures.

 

13. Appendix: Technical notes

Technical notes on deleting cookies:

● Internet Explorer:
Instructions at http://windows.microsoft.com/de-de/internet-explorer/delete-manage-cookies#ie=ie-11-win-7
● Mozilla Firefox:
Instructions at https://support.mozilla.org/de/kb/cookies-erlauben-und-ablehnen
● Google Chrome:
Instructions at https://support.google.com/chrome/answer/95647
● Safari:
Instructions at http://help.apple.com/safari/mac/8.0/#/sfri11471

 

HeKu 26. January 2023

Note: Data protection declaration for legally compliant websites based on the sample texts from e-Recht24.de and supplemented with individual information.