Privacy Policy

Circly GesbR.

Cookie Settings
Status: March, 01. 2021

Privacy policy of the company CIRCLY

Types of data processed:
- inventory data (e.g., names, addresses).
- Contact data (e.g., e-mail, telephone numbers).
- Content data (e.g., text input, photographs, videos).
- Usage data (e.g., visited websites, 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.
- Reach Measurement/Marketing


I. General Information

Thank you for your interest in our company. Data protection has a particularly high priority for us, therefore the use of our website is basically possible without any indication of personal data. Circly GbR (hereinafter referred to as "Circly") is committed to protecting the privacy of visitors to its website. If it is necessary to process personal data and there is no legal basis for such processing, we generally obtain the consent of the person concerned.


II. in a nutshell

The following information provides a simple overview of what happens to your personal data when you visit our website. Personal data are all data with which you can be personally identified. Data subject is the person from whom personal data is collected. Collection is the collection, storage and processing of personal data.

What do we use your data for?
Part of the data is collected to ensure that the website is provided without errors. Other data can be used to analyze your user behavior.
What rights do you have regarding your data?
You have the right to receive information at any time, in particular about the origin, transfer and purpose of your stored personal data. You also have the right to demand the correction or deletion of this data.
Revocation of your consent to data processing
Many data processing operations are only possible with your express consent. You can revoke a previously given consent at any time. For this purpose, an informal notification by e-mail to us is sufficient. The legality of the data processing that took place up to the revocation remains unaffected by the revocation.
Right of complaint to the responsible supervisory authority
In the event of violations of data protection law, the data subject has a right of appeal to the competent supervisory authority. The competent supervisory authority in data protection matters is the data protection commissioner of the federal state in which the company has its headquarters, in our case Lower Austria.


III. data collection on our website

The processing of personal data, such as name, address or e-mail address, is always in accordance with the basic data protection regulation and in compliance with the country-specific data protection regulations applicable to CIRCLY. With this data protection declaration, we would like to inform you about the type, scope and purpose of the personal data we collect, use and process.

CIRCLY, as the data controller, has implemented sufficient technical and organizational measures to ensure that the personal data processed via this website is protected as completely as possible. However, Internet-based data transmissions can generally have security gaps, so that absolute protection cannot be guaranteed. For this reason, every person concerned is free to transmit personal data to us by alternative means, such as by telephone.

1. name and address of the person responsible for processing
The person responsible within the meaning of the Basic Data Protection Regulation, other data protection laws applicable in the member states of the European Union and other regulations of a data protection nature is

Circly GbR, BIZ, Heinrich Schneidmadl Str. 15, PO Box T022N, 3100 St. Pölten

represented by:
Eric Weisz
e-mail: contact@circly.at
Website: http://www.circly.at

2. cookies
We use so-called cookies on our website. Cookies are text files which are stored on a computer system via an internet browser. They enable the Internet pages and servers visited to distinguish the individual browser of the person concerned from other Internet browsers. A particular Internet browser can be recognized and identified by means of the unique cookie ID. By using cookies, CIRCLY can provide users of this website with more user-friendly services that would not be possible without the setting of cookies.

By means of a cookie, the information and offers on our website can be optimized in the interest of the user. As already mentioned, cookies enable us to recognize the users of our website. The purpose of this recognition is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to enter his or her access data again each time he or she visits the website, because this is done by the website and the cookie stored on the user's computer system.

The person concerned can prevent the setting of cookies by our website at any time by means of a corresponding setting in the Internet browser used and thus permanently object to the setting of cookies. Furthermore, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common internet browsers. If the person concerned deactivates the setting of cookies in the Internet browser used, it is possible that not all functions of our website can be used to their full extent.

What types of cookies are there?

The question which cookies we use in particular depends on the services used and is clarified in the following sections of the data protection declaration. At this point we would like to briefly discuss the different types of HTTP cookies.

You can distinguish 4 types of cookies:
Absolutely necessary cookies
These cookies are necessary to ensure basic functions of the website. For example, these cookies are needed when a user adds a product to the shopping cart, then continues surfing on other pages and only goes to checkout later. These cookies do not delete the shopping cart, even if the user closes his browser window.

Functional Cookies
These cookies collect information about user behavior and whether the user receives any error messages. These cookies are also used to measure the loading time and the behavior of the website in different browsers.

Target-oriented cookies
These cookies ensure a better user experience. For example, entered locations, font sizes or form data are stored.

Advertising cookies
These cookies are also called targeting cookies. They are used to deliver customized advertising to the user. This can be very practical, but also very annoying.

Usually the first time you visit a website, you will be asked which of these types of cookies you want to allow. And of course this decision is also stored in a cookie.

How can I delete cookies?
How and whether you want to use cookies is up to you. Regardless of the service or website from which the cookies originate, you always have the option of deleting cookies, allowing them only partially or deactivating them. For example, you can block third-party cookies, but allow all other cookies.

If you want to find out which cookies are stored in your browser, if you want to change or delete cookie settings, you can find this in your browser settings:

Chrome: Delete, activate and manage cookies in Chrome
Safari: Manage cookies and website data with Safari
Firefox: delete cookies to remove data that websites have placed on your computer
Internet Explorer: Delete and manage cookies
Microsoft Edge: Delete and manage cookies

If you do not wish to receive cookies, you can set your browser to notify you whenever a cookie is set. In this way, you can decide for each individual cookie whether or not you wish to accept it. The procedure varies depending on the browser. The best thing to do is to look for the instructions in Google with the search term "Delete cookies Chrome" or "Deactivate cookies Chrome" in case of a Chrome browser or replace the word "Chrome" with the name of your browser, e.g. Edge, Firefox, Safari.

What about my privacy?
The so-called "cookie guidelines" have been in place since 2009. This states that the storage of cookies requires the consent of the website visitor (i.e. you). Within the EU countries, however, there are still very different reactions to these guidelines. In Austria, however, this directive has been implemented in § 96 para. 3 of the Telecommunications Act (TKG).

If you want to know more about cookies and are not afraid of technical documentation, we recommend https://tools.ietf.org/html/rfc6265, the Request for Comments of the Internet Engineering Task Force (IETF) called "HTTP State Management Mechanism".

3. server log files
Every time a person or automated system accesses the CIRCLY website, a series of general data and information is recorded in so-called server log files, which your browser automatically transmits to us. These are:

Browser type and version
Operating system used
URL
Hostname of the accessing computer
Time of the server request
IP address
similar data and information that serve to avert danger in the event of attacks on our information technology systemsThis data is not merged with other data sources.

When using this general data and information, CIRCLY does not draw conclusions about the person concerned. Rather, this information is required in order to (a) deliver the contents of our website correctly, (b) optimize the contents of our website and the advertising for it, (c) ensure the permanent operability of our information technology systems and the technology of our website and (d) provide law enforcement agencies with the information necessary for prosecution in the event of a cyber attack. This anonymously collected data and information is therefore evaluated by CIRCLY on the one hand statistically and also with the aim of increasing data protection and data security in our company, in order to ultimately ensure an optimum level of protection for the personal data processed by us. The anonymous data of the server log files are stored separately from all personal data provided by a person concerned.

4. registration on our website
You can register with us by providing various data. Which data is transmitted to us in the process is determined by the respective input mask used for registration. The personal data entered by the data subject is collected and stored exclusively for internal use by the data controller and for our own purposes. The internal controller may arrange for the personal data to be transferred to one or more processors who will also use the personal data exclusively for internal use attributable to the controller.

By registering on the Controller's website, the IP address assigned to the data subject by the Internet Service Provider (ISP), the date and time of registration are also stored. This data is stored with the aim of preventing the misuse of our services and, if necessary, to enable us to solve criminal offences. To this extent, the storage of this data is necessary to protect the person responsible for processing. As a matter of principle, this data will not be passed on to third parties unless there is a legal obligation to do so or the passing on of the data serves criminal prosecution.

5. contact possibility via the website
Due to legal regulations, our website contains information that enables quick electronic contact to our company as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If you contact us by e-mail or via a contact form, the data you enter will be stored automatically. Such personal data transmitted voluntarily by a data subject to the data controller will be stored for the purpose of processing or contacting the data subject. This personal data will not be passed on to third parties.

6. routine deletion and blocking of personal data
We process and store personal data only for the period of time necessary to achieve the purpose of storage or if this has been provided for by the European Directive and Regulation Giver or another legislator in laws or regulations to which the person responsible for the processing is subject. If the purpose of storage ceases to apply or if a storage period prescribed by the European Directive and Regulation Giver or any other competent legislator expires, the personal data will be blocked or deleted as a matter of routine and in accordance with the statutory provisions.


IV. Infrastructure, Analysis tools, social networks and advertising

1. User information
User-specific data is passed on to the respective using company for verification. This company is entitled to notify the user and/or to contact him/her due to further situation-related circumstances. We have concluded an order data processing contract with the company using the service and fully implement the data protection requirements when using the service. Processing by the company itself is not permitted without good reason.

2. Website building kit system Webflow
We use Webflow, a website construction system, for our website. The service provider is the American company Webflow, Inc. 398 11th, St., Floor 2, San Francisco, CA 94103, USA.

Webflow also processes data from you in the USA, among other places. We would like to point out that according to the opinion of the European Court ofJustice, there is currently no adequate level of protection for the transfer of data to the USA. This may be associated with various risks to the legality and security of data processing. As a basis for data processing with recipients located in third countries (outside the European Union, Iceland, Liechtenstein, Norway, i.e. especially in the USA) or a data transfer there, Webflow uses so-called standard contractual clauses (= Art. 46. para. 2 and 3 DSGVO). Standard Contractual Clauses (SCC) are templates provided by the EU Commissionand are intended to ensure that your data comply with European data protectionstandards even if they are transferred to third countries (such as the USA) andstored there. Through these clauses, Webflow undertakes to comply with theEuropean level of data protection when processing your relevant data, even ifthe data is stored, processed and managed in the USA. These clauses are basedon an implementing decision of the EU Commission. You can find the decision and the corresponding Standard Contractual Clauses here, among other places: https://eurlex.europa.eu/eli/dec_impl/2021/914/oj?locale=de

For more information on the standard contractual clauses and on the data processed through the use of Webflow, please refer to the Privacy Policy at https://webflow.com/legal/privacy.

3. CRM system Pipedrive
We use Pipedrive, a CRM platform for sales, on our website. The service provider is the American company Pipedrive Inc, 460 Park Ave South, New York,NY, 10016, USA.

Pipedrive also processes data from you in the USA, among other places. We would like to point out that according to the opinion of the European Courtof Justice, there is currently no adequate level of protection for the transfer of data to the USA.

This may be associated with various risks for the legality and securityof data processing. As a basis for data processing with recipients located in third countries (outside the European Union, Iceland, Liechtenstein, Norway, i.e. especially in the USA) or a data transfer there, Pipedrive uses so-called standard contractual clauses (= Art. 46. para. 2 and 3 DSGVO).  Standard Contractual Clauses (SCC) are templates provided by the EU Commission and are intended to ensure that your data complies with European data protection standards even if it is transferred to and stored in third countries (such as the USA). Through these clauses, Pipedrive undertakes to comply with the European level of data protection when processing your relevant data, even if the data is stored, processed and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses here, among other places: https://eurlex.europa.eu/eli/dec_impl/2021/914/oj?locale=de

The Pipedrive Data Processing Condition (Data Protection Addendum), which corresponds to the standard contractual clauses, can be found at https://www-cms.pipedriveassets.com/documents/2021-02-16-Pipedrive-DPA-Signed.pdf.

You can learn more about the data processed through the use of Pipedrive in the Privacy Policy at https://www.pipedrive.com/en/privacy.


4. Google-Tools

4.1. Google Analytics
This website uses functions of the web analysis service Google Analytics. The provider is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics also uses cookies (see above), which are used to analyze user behavior and thus to optimize the advertising and the offer. We have activated the IP anonymization function on this website. As a result, your IP address is shortened by Google within EU member states or in other signatory states to the Agreement on the European Economic Area before it is transmitted to the USA. You can prevent the storage of cookies by adjusting your browser software accordingly. However, we would like to point out that in this case you may not be able to use all functions of this website to their full extent. You can also prevent the collection of data generated by the cookie and related to your use of the website to Google and the processing of this data by Google by downloading and installing the browser plugin available under the following link: here. We have concluded a contract with Google for commissioned data processing and fully implement the data protection regulations when using Google Analytics.

Google Maps Privacy Policy
We use Google Maps of the company Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA) on our website.
By using the functions of this map, data is transferred to Google. You can read here which data is collected by Google and what this data is used for.

Google Analytics Privacy Policy
We use Google Analytics from Google LLC (1600 Amphitheatre Parkway Mountain View, CA 94043, USA) on this website to statistically evaluate visitor data. Google Analytics uses target-oriented cookies for this purpose.
You can find more information on terms of use and data protection here or here.

Pseudonymization
Our concern in terms of the DSGVO is the improvement of our offer and our web presence. Since the privacy of our users is important to us, the user data is pseudonymized. The data processing is based on the legal provisions of § 96 Abs 3 TKG as well as Art 6 EU-DSGVO Abs 1 lit a (consent) and/or f (legitimate interest) of the DSGVO.

Deactivation of data collection by Google Analytics
Using the browser add-on to disable Google Analytics JavaScript (ga.js, analytics.js, dc.js), website visitors can prevent Google Analytics from using their data.
You can prevent the collection of data generated by the cookie and related to your use of the website to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: here.

Google Analytics add-on for data processing
We have entered into a direct customer agreement with Google for the use of Google Analytics by accepting the "Data Processing Addendum" in Google Analytics. You can find more about the data processing addendum for Google Analytics here.

4.2 Google Tag Manager
We use the Google Tag Manager service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94.043 USA on our site. With Google Tag Manager, marketers can manage website tags via an interface. A tag is one of marking or labeling a piece of data. However, the Tag Manager itself, which sets the tags, works without cookies and does not collect any personal data. The tags set up via the Google Tag Manager merely ensure the collection of data that is passed on to the target system.

Because the data is only passed through, the system does not collect or store the data itself. The Tag Manager thus merely triggers other tags, which in turn may collect data. For these respective third-party providers, corresponding explanations can be found in this privacy policy. However, the Google Tag Manager does not use this data. If you have set or otherwise made a deactivation of cookies, this will be observed for all tracking tags that were used with the Google Tag Manager, so the tool does not change your cookie settings.

Google may ask you for permission to share some product data (for example, your account information) with other Google products to enable certain features, such as making it easier to add new conversion tracking tags for AdWords. In addition, Google's developers review product usage information from time to time in order to further optimize the product. However, Google will not share this type of data with other Google products without your consent.

For more information, please see Google's Usage Policy and Google's Privacy Notice for this product.

4.3. Google reCAPTCHA
We use "Google reCAPTCHA" (hereinafter "reCAPTCHA") on our websites. The provider is Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google").

The purpose of reCAPTCHA is to verify whether data entry on our websites (e.g. in a contact form) is made by a human or by an automated program. Forthis purpose, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis starts automatically as soon as thewebsite visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g. IP address, time spent by the website visitor on the website or mouse movements made by the user). The data collected during the analysis is forwarded to Google.

The reCAPTCHA analyses run entirely in the background. Website visitorsare not made aware that an analysis is taking place.

The data processing is based on Art. 6 para. 1 lit. f DSGVO. The website operator has a legitimate interest in protecting its web offers from abusive automated spying and from SPAM.

For more information on Google reCAPTCHA and Google's privacy policy, please see the following links: https://www.google.com/intl/de/policies/privacy/and https://www.google.com/recaptcha/intro/android.html.

5. youTube
We use plugins from the YouTube site operated by Google. The operator is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. When you visit one of our sites equipped with a YouTube plugin, a connection to the YouTube servers is established. This tells the YouTube server which of our pages you have visited. YouTube is used in the interest of an attractive presentation of our online offers.

6. facebook
We have integrated components of the company Facebook on our website. As a social network, Facebook is an Internet-based social meeting place, an online community that allows users to communicate with each other and interact in virtual space. A social network can serve as a platform for the exchange of opinions and experiences or enables the Internet community to provide personal or company-related information. Facebook enables users of the social network to create private profiles, upload photos and network via friend requests, among other things. The operating company of Facebook is Facebook, Inc. 1 Hacker Way, Menlo Park, CA 94025, USA. The person responsible for processing personal data, if a data subject lives outside the USA or Canada, is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. Each time a user accesses one of the individual pages of this website, which is operated by the data controller and on which a Facebook component (Facebook plug-in) has been integrated, the Internet browser on the information technology system of the data subject is automatically prompted by the respective Facebook component to download a display of the corresponding Facebook component from Facebook. A complete overview of all Facebook plug-ins can be found here. As part of this technical process, Facebook is informed which specific subpage of our website is visited by the person concerned. If the person concerned is logged in to Facebook at the same time, Facebook recognizes which specific subpage of our website the person concerned is visiting each time the person concerned calls up our website and for the entire duration of their stay on our website. This information is collected by the Facebook component and assigned by Facebook to the respective Facebook account of the person concerned. If the data subject clicks one of the Facebook buttons integrated on our website, for example the "Like" button, or if the data subject makes a comment, Facebook assigns this information to the personal Facebook user account of the data subject and stores this personal data. Facebook receives information via the Facebook component that the data subject has visited our website whenever the data subject is logged in to Facebook at the same time when he or she accesses our website; this occurs regardless of whether the data subject clicks on the Facebook component or not. If the data subject does not want this information to be transmitted to Facebook in this way, he or she can prevent the transmission by logging out of his or her Facebook account before accessing our website. The data policy published by Facebook, which can be accessed here, provides information about the collection, processing and use of personal data by Facebook. It also explains which setting options Facebook offers to protect the privacy of the person concerned. In addition, various applications are available that make it possible to suppress data transmission to Facebook. Such applications can be used by the data subject to suppress data transfer to Facebook.

7. Instagram
The controller has integrated components of the service Instagram on this website. Instagram is a service that qualifies as an audiovisual platform and allows users to share photos and videos and also to disseminate such data in other social networks. The operating company of the Instagram services is Instagram LLC, 1 Hacker Way, Building 14 First Floor, Menlo Park, CA, USA. Each time one of the individual pages of this website operated by the controller is called up and on which an Instagram component (Insta button) has been integrated, the internet browser on the information technology system of the data subject is automatically prompted by the respective Instagram component to download a representation of the corresponding component from Instagram. As part of this technical process, Instagram receives knowledge of which specific subpage of our website is visited by the data subject. If the data subject is logged in to Instagram at the same time, Instagram recognizes which specific sub-page the data subject is visiting each time the data subject calls up our website and for the entire duration of the respective stay on our website. This information is collected by the Instagram component and assigned by Instagram to the respective Instagram account of the data subject. If the data subject activates one of the Instagram buttons integrated on our website, the data and information thus transmitted will be assigned to the personal Instagram user account of the data subject and stored and processed by Instagram. Instagram always receives information via the Instagram component that the data subject has visited our website if the data subject is simultaneously logged into Instagram at the time of calling up our website; this takes place regardless of whether the data subject clicks on the Instagram component or not. If the data subject does not want this information to be transmitted to Instagram, he or she can prevent the transmission by logging out of his or her Instagram account before calling up our website. Further information and the applicable data protection provisions of Instagram can be found here.

8. linkedIn Privacy Policy
We use features of the social media network LinkedIn from LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA on our website.

By calling up pages that use such functions, data (IP address, browser data, date and time, cookies) are transmitted to LinkedIn, stored and evaluated.
If you have a LinkedIn account and are logged in, this data is associated with your personal account and the data stored in it.The privacy policy, what information LinkedIn collects and how they use it can be found here.

9. XING Privacy Policy
On our website we use functions of the social media network XING of the company XING SE, Dammtorstraße 30, 20354 Hamburg, Germany.By calling up pages that use such functions, data (IP address, browser data, date and time, cookies) are transmitted to XING, stored and evaluated. If you have a XING account and are logged in, this data is assigned to your personal account and the data stored in it. The privacy policy, what information XING collects and how it uses it can be found here.

10. Twitter
We use the technical platform and services of Twitter Inc., 1355 MarketStreet, Suite 900, San Francisco, CA 94103 U.S.A. for the short message service offered. The data controller for individuals living outside the United States is Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2D02 AX07, Ireland.  

We would like to point out that you use the Twitter short message service offered here and its functions under your own responsibility. This applies to the use of the interactive functions (for example, sharing or rating). Information about which data is processed by Twitter and for which purposes can be found in Twitter's privacy policy: https://twitter.com/de/privacy.

The information collected by the cookies of this provider is usually sent to a server in the USA and stored there. If the data is transferred to the USA, the data transfer is based on the existence of standard contractual clauses.

Further information on these points is available on the following Twitter support pages:
https://support.twitter.com/articles/105576#
https://help.twitter.com/de/forms/fragments/privacy-helpful-articles

You can find out about the possibility of viewing your own data on Twitter here:
https://support.twitter.com/articles/20172711#.

Information on the available personalization and data protection setting options can be found here (with further references): https://twitter.com/personalization.

Furthermore, you have the option to request information via the Twitter privacy form or the archive requests:
https://support.twitter.com/forms/privacy
https://support.twitter.com/articles/20170320#


11. external payment service providers
We use external payment service providers through whose platforms the users and we can carry out payment transactions (e.g., each with a link to the privacy policy):
Paypal,
Klarna,
Skrill,
Giropay,
Visa,
Mastercard,
American Express.

Within the framework of the performance of contracts, we use payment service providers on the basis of Art. 6, Par. 1, letter b. DSGVO. Otherwise, we use external payment service providers on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. DSGVO in order to offer our users effective and secure payment options.

The data processed by the payment service providers includes inventory data, such as name and address, bank data, such as account or credit card numbers, passwords, TANs and checksums, as well as contract, sum and recipient related data. These details are required to complete the transactions. However, the data entered is only processed by the payment service providers and stored by them. This means that we do not receive any account or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the payment service providers may transfer the data to credit agencies. The purpose of this transmission is to check identity and creditworthiness. In this regard, we refer to the general terms and conditions and data protection notices of the payment service providers.

For payment transactions, the terms and conditions and the data protection information of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to them for further information and the assertion of rights of revocation, information and other rights of affected persons.

12. subscription to our newsletter
Which personal data is transmitted to us when ordering the newsletter is determined by the input mask used for this purpose. CIRCLY informs its customers and business partners about company offers at regular intervals by means of a newsletter. The newsletter of our company can only be received by the person concerned if (a) the person concerned has a valid e-mail address and (b) the person concerned registers for the newsletter. For legal reasons, a confirmation e-mail will be sent to the e-mail address registered for the first time by a person concerned for the purpose of receiving the newsletter using the double opt-in procedure. This confirmation mail is used to check whether the owner of the e-mail address has authorized the receipt of the newsletter as the person concerned.

When registering for the newsletter, we also store the IP address assigned by the Internet service provider (ISP) of the computer system used by the person concerned at the time of registration as well as the date and time of registration. The collection of this data is necessary in order to be able to trace the (possible) misuse of a data subject's e-mail address at a later date and therefore serves to provide legal protection for the data controller. The personal data collected during registration for the newsletter is used exclusively for sending our newsletter. In addition, subscribers to the newsletter could be informed by e-mail if this is necessary for the operation of the newsletter service or for registration, as might be the case if there are changes to the newsletter offer or if technical conditions change. The personal data collected within the scope of the newsletter service will not be passed on to third parties. The subscription to our newsletter can be cancelled by the person concerned at any time. The consent to the storage of personal data, which the person concerned has given us for the newsletter service, can be revoked at any time.

Newsletter Privacy Policy
If you register for our newsletter, you provide the above mentioned personal data and give us the right to contact you by e-mail. We use the data stored during the registration for the newsletter exclusively for our newsletter and do not pass them on.If you unsubscribe from our newsletter - you will find the link for this at the bottom of every newsletter - we will delete all data that was saved when you subscribed to the newsletter.

MailChimp Privacy Policy
We send newsletters with MailChimp and use on this website functions of the newsletter service MailChimp of The Rocket Science Group, LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA to collect newsletter subscriptions.

General information about MailChimp
The Rocket Science Group LLC (MailChimp) maintains online platforms that allow our users to stay in touch with their subscribers, primarily via email. They allow users to upload e-mail addresses and other subscriber profile information, such as name, physical address and other demographic information, to the MailChimp database. This information is used to send email and to enable the use of certain other MailChimp features by these users. In accordance with the published privacy policy, MailChimp shares some information with third parties to provide and support the services that MailChimp offers to users. MailChimp also shares some information with third-party advertising partners to better understand users' needs and interests so that more relevant content and targeted advertising can be delivered to these users and other users.

Newsletter Subscription
If you register for our newsletter on our website, the entered data will be stored at MailChimp.

Deletion of your data
You can withdraw your consent to receive our newsletter at any time within the received e-mail by clicking on the link in the lower area. If you have unsubscribed by clicking on the unsubscribe link, your data will be deleted by MailChimp.

Newsletter evaluation
When you receive a newsletter via MailChimp, information such as IP address, browser type and e-mail program is stored to give us information about the performance of our newsletter. MailChimp can use the images called web beacons (details can be found here) integrated in the HTML e-mails to determine if the e-mail has arrived, if it has been opened and if links have been clicked. All this information is stored on MailChimp's servers, not on this website.

MailChimp is an active participant in the EU-U.S. Privacy Shield Framework which regulates the correct and secure transfer of personal data. You can find more information here. You can read more about the use of cookies at MailChimp here, information about data protection at MailChimp (Privacy) can be found here.

13. Sentry
We use the Sentry service of Functional Software Inc, 132 Hawthorne Street, San Francisco, California 94107, to improve the technical stability of our service by monitoring system stability and identifying code errors.

Sentry serves these purposes alone and does not evaluate data for advertising purposes. User data, such as device details or time of error, are collected anonymously and are not used in a personalized manner and are subsequently deleted. For more information, please see Sentry's privacy policy: https://sentry.io/privacy/.

This transfer is permittedunder Article 45 of the GDPR, as Functional Software Inc. is Privacy Shield certified and thus an adequate level of data protection exists under Commission Implementing Decision (EU) 2016/1250 (https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=CELEX:32016D1250).

The certification can beviewed at https://www.privacyshield.gov/participant?id=a2zt0000000TNDzAAO&status=Active. The legal basis for the use of Sentry is a legitimate interest according to Art. 6 para. 1 p. 1 f DSGVO. Our legitimate interest is the user-friendly design of our offers.

14. Hotjar
Our website uses Hotjar an analytics software provided by Hotjar Ltd. 3 Lyons Range- 20 Bisazza Street- Sliema SLM 1640, Malta (http://www.hotjar.com), which allows us to analyze how you use the website.

Hotjar uses cookies as well as a tracking code through which the collected data is transmitted to the Hotjar server. This data is essentially device-related information, such as the IP address, the screen size of your device, the device type and browser information, such as type and version, your geographical location and your language setting. In addition, your email address is transmitted with your first and last name, if you have provided us with this information. Periodically, user interaction, such as mouse movement, web pages visited, and the date and time of use are also transmitted to Hotjar.

Your IP address is automatically anonymized by Hotjar and stored only in this form. In addition, users of the website are assigned a "unique user identifier (UUID), through which Hotjar can record returning users of our website - without linking them to your personal data.

You can use the link https://www.hotjar.com/opt-out to prevent the collection and use of your data by Hotjar.

15. Podigee Podcast-Hosting
We use the podcast hosting service Podigee of the provider Podigee GmbH, Schlesische Straße 20, 10997 Berlin, Germany. The podcasts are thereby loaded by Podigee or transmitted via Podigee.

The use is based on our legitimate interests, i.e. interest in a safe and efficient provision, analysis as well as optimization of our podcast offer according to Art. 6 para. 1 lit. f. DSGVO.  

Podigee processes IP addresses and device information to enable podcast downloads/playbacks and to determine statistical data, such as call-up figures. This data is anonymized or pseudonymized before being stored in Podigee's database unless it is necessary for the provision of the podcasts.

Further information and objection options can be found in Podigee'sprivacy policy: https://www.podigee.com/de/about/privacy/.


V. Legal basis of the processing

In accordance with Art. 13 DSGVO we inform you about 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 inquiries 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, Art. 6 para. 1 lit. d DSGVO serves as the legal basis.

Contact
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the user's details are processed for the purpose of processing the contact request and its handling 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 inquiry organization.

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