Privacy declaration

Responsible Authority

We are happy about you visiting our website. We would like to introduce you to the responsible authority in terms of data protection law as applicable:

Elementura GmbH
represented by the Manager David-Dayanand Pascal Steves
Wallstraße 16
Ratingen
Phone: +49 1757646334
E-mail: d.steves@elementura-amenities.com

General Information

Pursuant to our statutory obligations, we would like to inform you about the collection and use of your personal data.

When you use our website, personal data about you will be collected. This may happen by you entering the data yourself, for example your e-mail address. But our system also collects your data automatically, for example whenever you visit our website. This happens irrespective of the device or the software that you use to visit our website.

All data that you enter in our app is provided voluntarily; there are no disadvantages to you if you do not provide data. But without certain data, we are unable to provide services or to conclude contracts. Whenever such information is necessary, we will point it out to you.

On this website, the user’s personal data is only collected within the framework of the existing data-protection law, in particular the General Data Protection Regulation (GDPR). The legal terms used in the text are defined in Art. 4 of the GDPR.

The GDPR allows data processing in three cases in particular:

• in accordance with Art. 6 para. 1 (a) and 7 GDPR, when you have consented to us processing your data; in this Privacy Policy and in the cases of consent pursuant to Art. 4 no. 11 GDPR, we will inform you in detail and each time for what purposes and under what circumstances your data will be processed by us;
• in accordance with Art. 6 para. 1 (b) GDPR, when processing your personal data is necessary for negotiating, concluding or performing a contract;
• in accordance with Art. 6 para. 1 (f) GDPR, if the balancing of interests leads to the conclusion that the processing is necessary to protect our legitimate interests; this means in particular our interests to analyse, optimise and secure the offers on our website – meaning primarily the analysis of user behaviour, setting up profiles for advertisement purposes and storage of access data as well as the use of third-party providers.

Inventory Data

We collect inventory data as far as it is necessary to establish, negotiate or amend a contract (including one without remuneration) between us and the user. This can be: customer data (for example name, address), contact data (for example e-mail address, phone number), service data (for example services ordered, duration, payment). Upon establishing the user relationship, we will ask you for this data (for example name, address and e-mail address) and will also tell you which of the information is required to establish the user relationship.

Usage Data

We also collect usage data to allow users to use the services on our website. These may consist of: usage information (for example visited websites or parts, duration of visit, interest in services), content data (for example data, text, images, sounds, videos entered or uploaded by you), meta data (for example identity of your device, location, IP address).

We will only combine usage data if and insofar as it is necessary for billing purposes. Otherwise, we will only put together usage data pseudonymously and only insofar as you have not objected. You may send this objection to the address indicated in the “About Us” section or the responsible authority indicated in this Privacy Policy at any time.

The legal basis for this data processing are our legitimate interests pursuant to Art. 6 para. 1 (f) GDPR in analysing the website and your use, possibly also the statutory permission to store data as part of the negotiation of a contract pursuant to Art. 6 para. 1 (b) GDPR.

Furthermore, our provider stores information, the so-called server log files, each time the website is used; this is information which is automatically transferred by your browser. In detail, this data consists of:

• your IP address
• type and version of your browser
• host name
• time of visit
• the page from which you came to our page
• name of the page opened
• exact time of usage as well as
• the amount of data transferred

This data will only be used for statistical purposes and do not allow us to identify you as a user.

Advertisements

Before sending you advertisements, we will ask for your explicit consent pursuant to Art. 4 no. 11 GDPR, except in cases of advertisements for similar products to the one you already acquired. This will happen in particular when you grant us consent to mail our newsletter or when you fill out a contact form. You may withdraw your consent at any time in accordance with the subsequent section “Consent”.
INSOFAR AS WE USE YOUR PERSONAL DATA FOR DIRECT MARKETING, YOU MAY ALSO OBJECT TO THE USE OF YOUR DATA FOR THAT PURPOSE AT ANY TIME. THIS MAY BE DONE THROUGH ANY OF OUR MEANS OF CONTACT, PARTICULARLY BY E-MAIL TO THE E-MAIL ADDRESS LISTED IN THE “LEGAL NOTICE” SECTION WITHOUT ANY FORMAL REQUIREMENTS. WE WILL THEN NO LONGER USE YOUR DATA FOR DIRECT MARKETING.

First Contact through Electronic Request

If you contact us in electronic form (for example by mail, fax, phone, messenger, etc.), we store and process the data which you have given us (for example name, contact information, content of the request). This is based on our legitimate interest in an effective communication with customers in accordance with Article 6 para. 1 (a) GDPR and, as far as it concerns a request to enter into or to perform a contract, also with Article 6 para. 1 (b) GDPR.
We will only pass on this data to third parties as far as required for the performance of the contract (in accordance with Article 6 para. 1 (b) GDPR), by the overwhelming interest in effective services (in accordance with Article 6 para. 1 (f) GDPR) or based on your consent (in accordance with Article 6 para. 1 (a) GDPR) or if there is another legal permission or obligation.
You may ask us at any time and without any cost to provide information about the purpose of the processing, the origin and the recipient, if any, of your data. You may also request that we correct, delete or limit the processing of your personal data. You may object against the (further) processing of your data at any time and you have a right for the data to be made transferable as well as the right to file a complaint with the competent supervisory agency.
In general, your data will only remain stored as long as required by the purpose of the respective data processing. A longer storage is an option, in particular when required in order to pursue our rights, for other legitimate interests of ours or when there is a statutory duty to keep the data longer (for example record-keeping under tax law, statute of limitations).

Consent

Whenever we ask you for your consent for the processing of your data, we will inform you in clear language and in an easily accessible way about the cases for which you will be granting your consent. Any consent that we ask you for is voluntary. Any advantage that you wish to gain by granting consent is also available without consent; simply ask us.

Regarding any consent, you have the right to revoke any consent given to us for the processing of your personal data at any time. You just need to contact us without any particular formal requirement, for example through our contact form, an e-mail to the e-mail address indicated in the “About Us” section or a link to unsubscribe (if offered by us). Your withdrawal has no effect on the legality of the data processing carried out up to that point.

Storage Period

Generally, your data will only remain stored as long as required by the purpose of the respective data processing. Storage beyond that is possible in particular if it is still required for pursuing our rights or for other legitimate interests of ours.
For your inventory data which were necessary to perform a contract (including one without remuneration), this means that we store this data until the complete performance or termination of the contractual relationship plus the limitation period (which is generally 2 or 3 years) plus an adequate extra time for potential interruptions of the limitation period.
For your usage data which was collected in the course of your use of the website, this means that we will store it only for the time still required for the proper functionality of our website and as long as we still have a legitimate interest. Statistical information will be primarily stored by us in pseudonymous form.
Beyond that, we still store your data for as long as we are required to do so by law. This concerns in particular the tax-law requirements to keep records, usually for 6 or even 10 years.

Cookies

More then essential Cookies

Upon opening the website, we have asked you to consent to the storing of certain cookies which will be placed while you visit our website. Based on your consent pursuant to Art 6 para. 1 (a) GDPR, our website thus uses cookies, so that our offer can be used in a better, more effective and more secure way.
A cookie is a record of information that is stored on your terminal device (computer, tablet, smartphone, etc.). These can be “session cookies”, which are automatically deleted when you leave our website. Other cookies are stored on your computer permanently until you delete them. That allows us to recognize your browser when you visit our website again and to provide you with features or offers according to your previous usage.

Your browser allows you to prevent the use of cookies in general or in specific cases. Please check the instructions for your browser to find out more about this. You can also delete cookies following these instructions which we have listed for you:

for Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en
for Safari: https://support.apple.com/en-gb/guide/safari/sfri11471/mac
for Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox
for Edge: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
for Internet Explorer: https://support.microsoft.com/en-gb/help/278835/how-to-delete-cookie-files-in-internet-explorer

Blocking cookies may limit the functionality of our website and of other websites visited by you.
More information on this topic, in particular how you can administer, limit or completely disable third-party cookies and technologies with a similar purpose, can be found at:
https://www.aboutads.info/choices
https://www.youronlinechoices.eu
https://www.networkadvertising.org/choices

Borlabs

In order to obtain your consent to store certain cookies on your device and to document this in line with data protection law, and in line with our legal obligations under Art. 6 para. 1 sentence 1 (c) GDPR and our legitimate interest in accordance with Art. 6 para. 1 (f) GDPR, we use the Cookie Consent Manager “Borlabs Cookie“ provided by Borlabs - Benjamin A. Bornschein, Georg-Wilhelm-Str. 17, 21107 Hamburg, Germany.
Borlabs Cookie only places cookies that are technologically necessary. When you open our website, the following data will be sent to Borlabs Cookie: your consent or the withdrawal of your consent for placing cookies, a cookie placed on your browser by Borlabs Cookie, the duration and version of the cookie, domain and path of the WordPress website and the UID. The UID is a randomly generated ID and no personal information.
Borlabs Cookie processes no personal data. If you want to withdraw the consent to place certain cookies, simply delete the cookie in your browser. When you re-enter/reload the website, you will be asked for your consent to place cookies again.
You can find detailed information about the privacy policy of Borlabs Cookies at: https://de.borlabs.io/datenschutz/

Borlabs Cookie

For the Cookie Opt In we use the WordPress plugin from Borlabs (https://borlabs.io/borlabs-cookie/) and you can adapt here your settings.
Borlabs Cookie Settings

Users‘ Rights

You may request us anytime to provide information about the personal data stored about you free of charge. To avoid misuse, this will require personal identification.

Deletion, Correction, Limitation

You may at any time demand from us that we correct (or complete) incorrect data as well as a limitation of the processing of data or deletion of your data. This applies in particular if the reason for processing the data is no longer valid, if a required consent has been revoked and there is no other legal basis or if our data processing is unlawful. We will then correct, block or even delete your personal data without delay as far as permitted by law.

Objection

The right to object to advertisement is governed by our text regarding consent:
Regarding any consent, you have the right to revoke any consent given to us for the processing of your personal data at any time. You just need to contact us without any particular formal requirement, for example through our contact form, an e-mail to the e-mail address indicated in the “About Us” section or a link to unsubscribe (if offered by us). Your withdrawal has no effect on the legality of the data processing carried out up to that point.

Data Transfer

You may request us to transfer the data stored about you in machine-readable form.

Complaint

If you feel that our data processing has violated any of your rights, you may file a complaint with the competent regulatory agency (here you find a list of the agencies).

Changes to the Privacy Policy

If and when factual or legal reasons will compel us to amend the Privacy Policy, we will update this page accordingly. This will not change the consent provided by the user.

Data Entry

Encryption of Data Entry

When you enter data on our website, whether in a contact form, during the registration process, when you log in or for payment purposes, the website, where you enter the data, is encrypted. Thus, third parties can not read what you enter. You will recognise the encryption by the lock symbol in your browser and by the URL beginning with “https“ instead of “http“.

Contact Forms

General contact form

When you fill out a contact form or when you send us an e-mail or another electronic message, your information will be stored for the processing of the request, for possible follow-up questions or for other related questions and will only be used to follow up with the request.

Your data will be transferred in an encrypted manner, preventing third parties from reading your data while it is being entered.

Basis for this storage is the safeguarding of our legitimate interests in regard to communication with interested users pursuant to Art. 6 para. 1 (f) GDPR and in the case of inquiries prior to entering into a contract also the performance of a contract pursuant to Art. 6 para (b) GDPR.

Your data remains stored for as long as the processing of the request requires, in particular as long as the storage is still necessary to perform the contract, to pursue our rights or for our other legitimate interests or we are compelled by law to keep your data stored (for example based on tax-law requirements to maintain files).

Offer

On our website, you find a contact form, through which you may request a specific offer for our goods and services. We will ask for for the necessary data as in the form, so we can prepare the offer.
Your data will be entered in an encrypted manner, so that third parties cannot read your data while being entered.
The legal basis for this storage is our legitimate interest in communication with interested users in accordance with Art. 6 para. 1 (f) GDPR and in case of contractual requests also the storage of contractual data in accordance with Art. 6 para. 1 (b) GDPR.
These data remain saved until you will terminate your access by sending an e-mail to the e-mail address listed in the "About Us" section. After that, they will remain stored in connection with the necessary performance of the contract (see the section on user/contract data).

Return Call

On our service page, you can ask for a call from one of our customer service agents.
We will ask for
– your first name, because we like to address your personally,
– your phone number, so we can call you, and
– your e-mail address, because we will e-mail you to confirm your request.

Your data will be entered in an encrypted manner, so that third parties cannot read your data while being entered.

The legal basis for this storage is our legitimate interest in communication with interested users in accordance with Art. 6 para. 1 (f) GDPR and in case of contractual requests also the storage of contractual data in accordance with Art. 6 para. 1 (b) GDPR.

We will only use this data for your specific request and will save it for 6 months after the request has been completed, so we can refer to the results already achieved in the case of subsequent service requests.

Social Media

Social Media Links

General Information

We refer with links to our social media presences. When you follow any such link to the social media site, your data will be broadcasted to that site. The social media site will normally store a cookie in your browser and to your account information there, especially, if you are logged into your social media account on the site. The social media site can analyse your use of the platform and your browsing habits and will use these for targeting advertisements based on your interests. That can lead to ads being shown to you when browsing in- and outside of the social media site. Please inform yourself about the use of your data on these sites and use them only, when you agree to that use of your data, that happens on that social media site, in particular, when you are not using that social media site for the first time. We have added links to all the privacy policies of the social media site for your information.

Facebook

Our website uses links to our presence in the social network of Facebook by Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland. It is just a normal link. Thus, when you open our site, Facebook will not learn of your visit to our website. But once you click on the link, you will be led to Facebook, allowing Facebook to learn that you have visited out site.
Your data will be forwarded by Facebook Ireland on the base of the standard contractual clauses to Facebook USA. Furthermore this provider is certified according to the EU-US Data Privacy Framework. This means that the transfer of data to the USA is possible in a legally secure manner on the basis of the adequacy decision concluded on 10.07.2023.

The collection and use of your data which is possibly carried out by Facebook after clicking on the link is beyond our knowledge or control. You may find further information in Facebook’s privacy policy at https://en-gb.facebook.com/policy.php.

Instagram

Our website uses links to our presence in the social network of Instagram by Instagram LLC, now Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland.

It is just a normal link. Thus, when you open our site, Instagram will not learn of your visit to our website. But once you click on the link, you will be led to Instagram, allowing Instagram / Facebook to learn that you have visited out site.
Your data will be forwarded by Meta Platforms Ireland on the base of the standard contractual clauses to Meta Platforms USA. Furthermore this provider is certified according to the EU-US Data Privacy Framework. This means that the transfer of data to the USA is possible in a legally secure manner on the basis of the adequacy decision concluded on 10.07.2023.

The collection and use of your data which is possibly carried out by Instagram/Facebook after clicking on the link is beyond our knowledge or control. You may find further information in Instagram’s privacy policy at
https://privacycenter.instagram.com/policy.

Google

Google Tag Manager

With the Google Tag Manager, marketers can use an interface to administer website tags. The Tag Manager itself, which places the tags, works without cookies and collects no personal data. The Tag Manager only activates other tags, which may in turn collect data. About these third-party providers, you will find the respective declarations in this Privacy Policy. The Google Tag Manager does not use this data. If you have deactivated cookies, it will be respected for all tracking tags that were placed with the Google Tag Manager, so the tool does not change your cookie preferences.

Google may ask you for permission to pass on some product data (e.g. your contact information) to other google products in order to activate certain features, e.g. adding new conversion-tracking tags to simplify AdWords. Google's developers will also check the information about the usage of the product from time to time, in order to further improve the product. But Google will never pass on such data to other Google products without your consent.

When using this provider, it may happen that your data is transferred to the USA. However, we have ensured that your data is only transferred to the USA on the basis of a contract in accordance with the standard contractual clauses. Furthermore this provider is certified according to the EU-US Data Privacy Framework. This means that the transfer of data to the USA is possible in a legally secure manner on the basis of the adequacy decision concluded on 10.07.2023.

We have concluded an data processing agreement with this provider, according to which this provider will only process your data on our behalf within the scope of the GDPR and according to our instructions see the Google Ads Data Processing Terms for further information. The Google Ads Data Processing Terms are available here: https://business.safety.google/adsprocessorterms/.

Further information can be found in the user guidelines of Google and the privacy policy of Google for this product.

Google Ads

Based on our legitimate interest in a technologically perfect online offering and its design and optimisation in an economically efficient manner pursuant to Art. 6 para. 1 (f) GDPR, we use Google Ads, an online advertisement network provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

With this system we can advertise in the Google ads network, which will be displayed on other websites, search results or other places on the internet. With Google Ads our ads will be primarily shown to users, who are most likely interested in them. This allows us, to market more specific. Google uses a Cookie to display the ads based on the interests of the user. The Cookie will be read by “web beacons” on the Website of the Google ads network.
The Cookies contain data about technical specifications of your system, the websites visited, the interests shown and which ads were clicked.
At the same time we have a „Conversion Cookie“. With it Google shows us anonymize statstics without personal data. It is just about how often our ads were clicked.
Also Google will use all data out of these Cookies just in a pseudonymized way, without being able, to follow your actions individually. The data is just analysed concerning the cookie itself, otherwise only, if you have given Google your specific consent to use the data with respect to you individually.

The data collected by Google may be transferred by Google to countries outside of the EU, in particular to the USA. We have concluded a data processing agreement with Google, according to which Google only processes your data according to our instructions. This agreement ensures, that your data will be transferred to the US solely on the base of the standard contractual clauses, see the Google Ads Data Processing Terms for further information. The Google Ads Data Processing Terms are available here: https://business.safety.google/adsprocessorterms/.

As we have already explained about cookies in general in our Privacy Policy, you can prevent the saving of cookies through the relevant preferences in your browser, but this may limit the functionality of our website.

Alternatively, you can use your browser to deactivate only interest-targeted ads on Google as well as interest-targeted Google ads on the web. To do this, you have to go to http://www.google.de/settings/ads and activate the “Off” button or use the deactivation at https://myaccount.google.com/privacycheckup?. Further information about your preference options regarding this issue and the data protection of Google can be found at https://www.google.de/intl/en/policies/privacy/?fg=1.

For the general approach to cookies and their deactivation as well as regarding the passing of data to third parties, particularly to the USA, we refer you to our general information in this Privacy Policy. This provider is certified according to the EU-US Data Privacy Framework. This means that the transfer of data to the USA is possible in a legally secure manner on the basis of the adequacy decision concluded on 10.07.2023.



You will find more information about Google’s precautions regarding data protection at the following link: https://www.google.de/intl/en/policies/privacy/.

Google Ads Conversion Tracking

Based on our legitimate interest in a technologically perfect online offering and its design and optimisation in an economically efficient manner pursuant to Art. 6 para. 1 (f) GDPR, we additionally to Google Ads we use the Google Ads Conversion Tracking, to track the result of our ads and to allow us to display ads based on the interest of the user.

If you perform certain actions on our Website – as ordering something, send a contact form or order out Newsletter – will this Conversion send to Google. Google can therewith measure the numbers of conversions. Additionally Google will be able to identify the cookie saved by Google on your Computer by Google before and can see, on which ads you have clicked before.

If you do not wish to be tracked, you can use the Google Ad Manager https://www.google.com/settings/u/0/ads/authenticated to modify your settings or even deactivate your Google Ads entirely. Additionally we refer for further settings and deactivation-measures to our general information in this Privacy Policy and especially for Google Ads.

Google remarketing and similar target groups

Based on our legitimate interest in a technologically perfect online offering and its design and optimisation in an economically efficient manner pursuant to Art. 6 para. 1 (f) GDPR, we use remarketing and other target-group services provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland, on our website.

This technology applied through cookies allows Google to present you targeted ads based on previously visited websites. Thus, we can better approach users of our website with ads. When you visit our page, a cookie will be placed in your browser, unless you have objected to the use of cookies when you opened our page.

The cookie is a small file with a number code, with which your visit of the website and anonymised data about your use of the website are collected. When it is transmitted to Google, your IP address will be shortened and thus anonymised. Your personal data will neither be stored, nor connected with other data by Google.

The anonymized data may be forwarded to the USA and stored by Google. However, we have ensured that your data is only transferred to the USA on the basis of a contract in accordance with the standard contractual clauses. According to the GDPR and the EuGH, this is a legal basis for the transfer of data to the USA. Furthermore this provider is certified according to the EU-US Data Privacy Framework. This means that the transfer of data to the USA is possible in a legally secure manner on the basis of the adequacy decision concluded on 10.07.2023.


We have concluded an data processing agreement with this provider, according to which this provider will only process your data on our behalf within the scope of the GDPR and according to our instructions. 

If you visit other websites after ours and these other websites are also part of the Google Display network, you will probably be shown interest-targeted ads on the basis of the websites previously visited by you.

You can perpetually prevent the saving of cookies by Google in your browser by downloading and installing the plugin linked to hereinafter.
https://www.google.com/settings/ads/plugin?hl=de

You can also prevent the use of cookies by third-party providers by declaring your opt-out on the deactivation page of the Network Advertising Initiative, following the instructions there: http://www.networkadvertising.org/choices/

Further information about Google's remarketing service and Google's privacy policy can be found at http://www.google.com/privacy/ads/.

For the general approach to cookies and their deactivation as well as regarding the passing of data to third parties, particularly to the USA, we refer you to our general information in this Privacy Policy.

Google Workspace

In the context of our legitimate interest in a technically flawless online offer and its economically efficient design and optimization in accordance with. Article 6 (1) (f) GDPR we use Google Cloud Services(Google Workspace) from Google Cloud EMEA Ltd., 70 Sir John Rogerson's Quay, D02 R296, Dublin 2, Irland
(„Google“).
Google Cloud and associated software services in the GDPR-compliant GSuite relate to the storage and management of data in the cloud, calendar functions, e-mail software, document creation, spreadsheets and presentations, the exchange of documents with specific recipients, the publication of forms or other content and information, as well as chats and participation in video and audio conferences.

All data you enter in the Google cloud solutions will be entered or displayed (in particular inventory data such as name and email, usage data such as the browser used, websites visited, length of stay, previously visited website and your IP address, content data such as documents, files, contracts, audio and video communication and / or recording, chat history, shared screen content) to Google and saved by Google. We ourselves use settings that are as privacy-friendly as possible, you can also take such precautions. When communicating, you can use aliases or unique email addresses to log in or deactivate your audio and video transmission (in part).

Your data may be transferred to the USA here. However, we have ensured that your data is only transferred to the USA on the basis of a contract in accordance with the standard contractual clauses. According to the GDPR and the EuGH, this is a legal basis for the transfer of data to the USA. Furthermore this provider is certified according to the EU-US Data Privacy Framework. This means that the transfer of data to the USA is possible in a legally secure manner on the basis of the adequacy decision concluded on 10.07.2023.


We have concluded an data processing agreement with this provider, according to which this provider will only process your data on our behalf within the scope of the GDPR and according to our instructions. 

Your data will remain stored insofar as it is still necessary for the purposes of your consent, for contract fulfillment / processing, for legal prosecution by us or for our other legitimate interests or if we are legally required to keep your data.
For more information on the use of your data by Google, please refer to Google's privacy policy
[https://policies.google.com/privacy?hl=de&gl=de] as well as the further security information on Google's cloud services [https://cloud.google.com/security/privacy/].

CRM and Marketing

HubSpot

Based on our legitimate interest in a flawlessly functioning online offer and its economic and efficient design and optimization according to Article 6 para. 1 (f) GDPR, as well as – insofar as it concerns the storage of your contractual data – based on the permission to process contractual data in accordance with Art. 6 para. 1 (b) GDPR, we use the integrated hosting and marketing solution of HubSpot Ireland Limited, 2nd Floor 30, North Wall Quay, Dublin 1, Ireland. HubSpot Ireland Limited is a subsidiary of a company registered in the USA. But the Irish company is the data processor in the EU.
More information about the data processing carried out by HubSpot can be found in the privacy policy of HubSpot: https://legal.hubspot.com/de/privacy-policy
A transparent list of the cookies potentially placed by HubSpot can be found here and here
We have also concluded a data processing contract with HubSpot, according to which HubSpot will only process your data on our behalf: https://legal.hubspot.com/de/dpa
HubSpot offers the following features:

• Hosting
• CMS (Content Management System)
• Contact Forms
• Newsletter Software
• Tracking and Analysis
• CRM (Customer Relation Management)
• Chat Software

Of these, we use the following features:

HubSpot Hosting / CMS / CRM

Based on our legitimate interest in a technologically perfect online offering and its design and optimization in an economically efficient manner, we use HubSpot for hosting our website. As any other hosting service, HubSpot collects usage data. These are identified and non-identifiable data on the occasion of you accessing our website. These will either be made available to HubSpot or automatically collected when you use HubSpot services (“non-personal data”).

Non-personal data does not allow HubSpot to find out the origin of the data. Non-personal data are technical information and usage information, for example the browsing and click stream behavior of visitors and users of services, session heat maps and scrolls as well as non-identifiable data about the user's or visitor's used device, operating system, browser, screen resolution, language and keyboard settings, internet provider, referral and exit pages, date/time stamp, etc.

As a hosting service, HubSpot also collects data that can identify a person with manageable effort (“personal data”). This personal data generally consists of all data that you enter when using the website. These can be contact data (for example e-mail address or phone number), invoice data (name, billing address, payment method and bank connection), data regarding a browser or user session (IP address, geographic location and/or unique identification of the user's device), data regarding connected accounts of third parties (for example e-mail address or user name for a connected PayPal, Google or Facebook account), scanned identity papers sent to us (for example ID card, driving license, passport or company registration documents), and any other personal data.

HubSpot also undertakes physical, electronic and procedural security measures to protect your personal data. HubSpot has more information about this here: https://legal.hubspot.com/data-privacy?__hstc=230861184.05b1c26761c5da0b5d0ce9ba8c0bc3af.1496406325284.1496406325284.1496406325284.1&__hssc=230861184.1.1496406325285&__hsfp=80863953

Based on contractual data, we use HubSpot for our Customer Relation Management System. Here, we store all data, which you have conveyed to us when entering into a contract, in particular your name, your contact information, payment information and products purchased, if applicable. We will keep this data stored as long as required for the performance of the contract (in particular the warranty period) or as long as we are required by law to keep your data stored (for example the data required for taxation).

Our Social Media Fan Page(s) - General Information

Beside our website, we also use fan page(s) on social media platforms. Above, we have already informed you about the data processing on our website and we have in particular made sure that the fact alone that you access our website is not yet forwarded to the social media platform. Following the ECJ ruling dated 5 June 2018 about social media presences, we want to inform you about the data processing during your visit to our social media fan page(s):

On the basis of our legitimate interest in a timely customer communication pursuant to Art. 6 para. 1 (f) GDPR as well as for advertising and public relations purposes, we present ourselves and our offers on social media fan page(s).

Our social media fan page(s) usually can be accessed online independently of you having a user account with the relevant platform or not. But in either case, your data will be processed by the social media platform.

Each time the social media platform is accessed, your IP address will be collected and stored. Usually, a cookie will also be placed on your page, which will save your visit and further data about your visit to the social media platform.

If you are logged in with the social media platform, your visit will also be spotted by a cookie or through other technological means and will be attributed to your user account. Thus, the social media platform is usually able to analyse your user behaviour. In this process, a user profile with your interests is generated, which the social media platform will use to provide you with a user experience tailored to your interests, in particular advertisement tailored to your interests within and outside of the social media platform – even across different devices, if applicable. Your data may also be used for market research. For the details, we refer you to the following privacy policies of the social media platform(s) used by us.

We can usually also use the data of the social media platform in order to allow you to use our fan page in accordance with your interests or to approach you with advertising.

When you interact with our fan page and if you are logged in with the relevant social media platform, according to the social media page's terms of use, we can usually also recognise your user profile and see your content.
If you do not want this, we point you to our explanations about cookies above, with general information about cookies and their deactivation. There, we have laid out in general terms how you can prevent or limit cookies being stored on your devices. Further information about the respective social media platform can be found hereinafter.

According to the aforementioned ECJ ruling dated 5 June 2018, we are always jointly responsible for our social media fan page(s) together with the relevant social media platform. This means that you may also exercise your general rights, which we have listed in detail above under the heading “Users' Rights”, against us. To that purpose, we refer you to our contact details at the beginning of this Privacy Policy. Please keep in mind, though, that we have no conclusive knowledge of the exact scope of the processing of your data by the social media platform and have even less influence on it. Therefore, we kindly ask you to contact the relevant social media platform in the first place regarding your rights.

We generally leave your data on the social media platform and do not import it onto our server. But if that should occur, our general information regarding the storage period will apply.

Further information about the processing of your data and the storage period on the social media platform can be found in the respective privacy policy of the social media platform, which we have listed hereinafter.

Facebook

We present ourselves on the social media platform Facebook.

Joint Responsibility
Meta Platforms Ireland Ltd.
4 Grand Canal Square
Grand Canal Harbour
Dublin 2 Ireland
Contact
Contact Data Protection Officer

If you open our fan page on Facebook, your data will be forwarded to the USA.

Facebook has concluded an agreement with us https://www.facebook.com/legal/controller_addendum about our shared responsibility for processing the data, in which it recognises its primary responsibility and guarantees in particular that you can exercise your right to information, as described in the general part.

You may obtain more information from Facebook's privacy policy at: https://www.facebook.com/about/privacy. Your data will be forwarded by Facebook Ireland on the base of the standard contractual clauses to Facebook USA.
Furthermore this provider is certified according to the EU-US Data Privacy Framework. This means that the transfer of data to the USA is possible in a legally secure manner on the basis of the adequacy decision concluded on 10.07.2023.

Facebook also provides us with statistics as part of "Facebook Insights" for the purpose of targeted advertising. These are created without our participation and then provided to us. The data include information like interaction with our page, such as likes, page activities, video views, reach of our posts, comments, sharing of content, clicks on offers or further information on our fan page as well as statistical data about those interacting, such as gender, origin by country, city and language. The same applies to groups which we may manage.

When you are logged in, you can influence the processing of your data by Facebook considerably and in different ways.

Here you can make changes to your timeline, i.e. what can be seen about you and your page (while being logged in to facebook).

And you can change your advertisement preferences here.

ManyChat

For our communication, we use a chatbot provided by Manychat Inc., One International Place, 535 Mission St, San Francisco, CA 94105, USA. This chatbot can be found and operated through Facebook Messenger.

The legal basis for our use of the chatbot is different, depending on the respective use of the chatbot. Requests regarding our offers will be processed on the basis of contractual data in accordance with Article 6 para. 1 (b). If we have contacted you via chatbot and asked you to consent to communication with our chatbot and with us, we will process your data based on this consent in accordance with Article 6 para. 1 (a) GDPR. We also use the chatbot based on our legitimate interest in accordance with Article 6 para. 1 (a) GDPRin a fast, technological and always available communication with users and customers.

If you send messages to our chatbot, Facebook will send us personal data about you. In particular, this will concern your Facebook identity. That allows us to see your public information on Facebook. But we will only use this data for your communication with the chatbot. We also store your communication with us in accordance with the general information in this privacy policy. This data will always be anonymised by us.

If you have requested recurring messages in the chatbot, you can always turn off the communication with certain messages in the future. The chatbot will show you the messages to be sent each time. This will remove your Facebook ID from the list of recipients. Also, your records up to that time will be anonymised.

By using the chatbot of ManyChat, the data mentioned will also be sent to ManyChat. Thus, your data will be sent to the USA.

For the handling of your data with ManyChat, we refer you to the privacy policy of ManyChat. ManyChat will only use your data for sending messages and for analyzing the messenger on our behalf. Additionally, ManyChat will only use your data to improve their own services. But ManyChat will not use the data to contact you directly or to pass on your data to third parties.

You can only use Facebook Messenger if you are a user of the social media platform Facebook. For the consequences thereof, we refer you to the section “Fan Pages”, “Facebook” in this privacy policy.

Instagram

We have a presence on the social media platform Instagram. Instagram is now owned by Facebook.

Jointly Responsible
Meta Platforms Ireland Ltd.
4 Grand Canal Square
Grand Canal Harbour
Dublin 2 Ireland.
Contact Data Protection Officer
Your data will be forwarded by Facebook Ireland on the base of the standard contractual clauses to Facebook USA. Furthermore this provider is certified according to the EU-US Data Privacy Framework. This means that the transfer of data to the USA is possible in a legally secure manner on the basis of the adequacy decision concluded on 10.07.2023.

We have neither knowledge of, nor any influence on the possible collection and processing of your data by Facebook and Instagram. Further information can be found in Instagram's privacy policy at https://privacycenter.instagram.com/policy.
Instagram and Facebook also provide us with statistics as part of "Facebook Insights" for the purpose of targeted advertising. These are created without our participation and then provided to us. The data include information like interaction with our page, such as likes, page activities, video views, reach of our posts, comments, sharing of content, clicks on offers or further information on our fan page as well as statistical data about those interacting, such as gender, origin by country, city and language. The same applies to groups which we may manage.
When you are logged in, you can influence the processing of your data by Instagram considerably and in different ways.
Your content, i.e. what is visible of you and your profile, can be changed here: https://www.instagram.com/accounts/login/?next=/accounts/privacy_and_security/.

LinkedIn

We have a presence on the social media platform LinkedIn.

Jointly Responsible
LinkedIn Ireland Limited Company,
Wilton Place,
Dublin 2,
Ireland

Contact

If you open our profile on LinkedIn, your data may be forwarded to the USA.

However, we have ensured that your data is only transferred to the USA on the basis of a contract in accordance with the standard contractual clauses. According to the GDPR and the EuGH, this is a legal basis for the transfer of data to the USA. This applies in particular since the US Presidential Decree of 07.10.2022.

We have concluded an data processing agreement with this provider, according to which this provider will only process your data on our behalf within the scope of the GDPR and according to our instructions.
Further information can be found in LinkedIn's privacy policy at
https://www.LinkedIn.com/legal/privacy-policy.

LinkedIn also provides us with statistics. These are created without our participation and then provided to us. The data will include interactions, for example, as well as statistical data.

When you are logged in, you can influence the processing of your data by LinkedIn considerably and in different ways.

For your privacy settings with LinkedIn, LinkedIn refers you to several options that you can read about in their privacy policy.

The LinkedIn advertising cookie can be turned off here (opt-out):
https://www.LinkedIn.com/psettings/guest-controls/retargeting-opt-out

Xing

We have a presence on the social media platform Xing.

Jointly Responsible

NEW WORK SE,
Am Strandkai 1,
20457 Hamburg,
Germany
Phone: +49 40 419 131-0,
Fax: +49 40 419 131-11,
E-mail: info@xing.com.

Data Protection Officer:
Felix Lasse,
Am Strandkai 1,
20457 Hamburg,
Germany,
E-mail: Data Protection Officer@xing.com

We have neither knowledge of, nor any influence on the possible collection and processing of your data by Xing. Further information can be found in Xing's privacy policy at
https://privacy.xing.com/de/datenschutzerklaerung.

Xing also provides us with statistics. These are created without our participation and then provided to us. The data will include interactions, for example, as well as statistical data.

For your privacy settings with Xing, Xing refers you to several options that you can read about in their privacy policy.

This is our current valid privacy policy from 03.12.2023