Data Protection

The translation of this data protection declaration is based on the German text created by https://datenschutz-generator.de/

Data protection declaration

This Privacy Policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as “Data”) within our online offer and the related websites, features and content, as well as external online presence, e.g. our social media profiles. (collectively referred to as “online offer”). With regard to the terminology used, e.g. “Processing” or “Responsible Person”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Responsible Person

Hadass Gilboa
Prenzlauer Promenade 9
13086 Berlin
hadass.gilboa@gmail.com
Mobile: +49 (0) 177 264 36 03

Link to Imprint

Types of processed data:

– Inventory data (e.g., names, addresses).
– contact information (e.g., e-mail, phone numbers).
– content data (e.g., text input, photographs, videos).
– data of usage (e.g., websites visited, interest in content, access times).
– Meta / communication data (e.g., device information, IP addresses).

Categories of affected persons

Visitors and users of the online offer (hereinafter we refer to the affected persons as “users”).

Purpose of processing

– Provision of the online offer, its functions and contents.
– Answering contact requests and communicating with users.
– Safety measures.
– Reach Measurement / Marketing

Used terms

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter the “affected person”); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (e.g. cookie) or to one or more special features, that express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.

“Processing” means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term is general and includes virtually every handling of data.

“Responsible person” means the natural or legal person, public authority, or body that decides, alone or in concert with others, on the purposes and means of processing personal data.

Relevant legal bases

In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 GDPR, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 (1) lit. b GDPR, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c GDPR, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f GDPR. In the event that vital interests of the affected person or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR, serves as legal basis.

Safety measures

We take appropriate technical measures in accordance with Art. 32 GDPR, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons and organizational measures to ensure a level of protection appropriate to the risk.

Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. In addition, we have established procedures that ensure that users can make use of their user rights, data erasure and procedures that allow us to react to data vulnerability. Furthermore, we consider the protection of personal data in the development, or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings (Article 25 GDPR).

Collaboration with processors and third parties

If, in the context of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit them to them or otherwise grant access to the data, this will only be done on the basis of a legal permission you have consented to (e.g. if a transmission of the data to third parties, as required by payment service providers, pursuant to Art. 6 (1) (b) GDPR to fulfill the contract), a legal obligation requires it, or based on our legitimate interests (e.g. the use of agents, webhosters, etc.).

If we commission third parties to process data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 GDPR.

Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done if it is to fulfill our (pre) contractual obligations, or on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of Art. 44 et seq. GDPR. That the processing is e.g. on the basis of specific guarantees, such as the officially recognized level of data protection (e.g. for the US through the Privacy Shield) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).

Rights of affected persons

You have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.

According to Art. 16 GDPR you have the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you.

In accordance with Art. 17 GDPR, you have the right to demand that the relevant data be deleted immediately or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 GDPR.

You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 GDPR and request their transmission to other persons responsible.

You have gem. Art. 77 GDPR the right to file a complaint with the competent supervisory authority.

Right to Withdrawal

You have the right to withdraw previously given consent in accordance with. Art. 7 para. 3 GDPR with effect for the future.

Right to Object

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

Cookies and right to object in direct mail

“Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, e.g. the contents of a shopping cart are stored in an online store or a login jam. The term “permanent” or “persistent” refers to cookies that remain stored even after the browser has been closed. Thus, e.g. the login status can be saved if users revisit it after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for range measurement or marketing purposes. As a “third-party cookie”, cookies will be offered by providers other than the person responsible for the online offer (otherwise, cookies are called “first-party cookies”).

We may use temporary and permanent cookies and declare this in the context of our privacy policy.

If users do not want cookies stored on their computer, they are asked to disable the option in their browser’s system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
A general objection to the use of cookies used for online marketing purposes can be declared for a variety of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/

Furthermore, the storage of cookies can be stopped by adjusting the settings of the browser. Please note that you may then not be able to use all features of this online offer.

Deletion of data

The data processed by us are deleted or limited in their processing in accordance with Articles 17 and 18 GDPR. Unless explicitly stated in this privacy policy, the data stored by us are deleted as soon as they are no longer required for their purpose and the deletion does not conflict with any statutory storage requirements. Unless the data is deleted because it is required for other and legitimate purposes, its processing will be restricted. That the data is blocked and not processed for other purposes. This applies, for example for data that must be kept for commercial or tax reasons.

According to legal requirements in Germany, the storage takes place in particular for 6 years pursuant to § 257 paragraph 1 HGB (trading books, inventories, opening balance sheets, annual accounts, trade letters, accounting documents, etc.) and for 10 years in accordance with § 147 Abs. 1 AO (books, records , Management reports, accounting documents, trade and business letters, documents relevant to taxation, etc.).

According to legal regulations in Austria the storage takes place in particular for 7 years according to § 132 paragraph 1 BAO (accounting documents, receipts / invoices, accounts, receipts, business papers, statement of income and expenses, etc.), for 22 years in connection with real estate and for 10 years with respect to documents related to electronically supplied services, telecommunications, broadcasting and television services provided to non-EU companies in EU Member States for which the Mini-One-Stop-Shop (MOSS) is used.

Hosting

The hosting services we use are for the purpose of providing the following services: infrastructure and platform services, computing capacity, storage and database services, security and technical maintenance services we use to operate this online service.

Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer acc. Art. 6 para. 1 lit. f GDPR i.V.m. Art. 28 GDPR (conclusion of order processing contract).

Collection of access data and log files

We, or our hosting provider, collect data on every access to the server on which this service is located (so-called server log files) on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR. The access data include name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Logfile information is stored for security purposes (for example, to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data whose further storage is required for evidential purposes shall be exempted from the cancellation until final clarification of the incident.

Contact

When contacting us (for example, by contact form, e-mail, telephone or via social media) the information of the user is processed to answer a contact request and its processing is done in accordance with Art. 6 para. 1 lit. b) GDPR. User information can be stored in a Customer Relationship Management System (“CRM System”) or comparable system.

We delete the requests, if they are no longer required. We check the necessity every two years; Furthermore, the legal requirements for archiving apply.

Comments and posts

If users leave comments or other contributions, their IP addresses are stored for 7 days, based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR. This is for our own safety, if someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.

Google Analytics

Based on our legitimate interests (i.e., interest in the analysis, optimization, and economic operation of our online offer within the meaning of Art. 6 (1) lit. GDPR), we use Google Analytics, a web analytics service provided by Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the users are usually transmitted to a Google server in the USA and stored there.

Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous usage profiles of the users can be created from the processed data.

We only use Google Analytics with activated IP anonymization. This means that the IP address of the users 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. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.

The IP address submitted by the user’s browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users may also prevent the collection of the data generated by the cookie and related to its use of the online offer and the processing of such data by Google by downloading and installing the browser plug-in available at the following link: http://tools .google.com/dlpage/gaoptout?hl=en.

For more information about Google’s data usage, setting and opt-out options, please visit Google’s websites: https://www.google.com/intl/en/policies/privacy/partners (“Google’s use of your data when you use websites or apps of our partners “), http://www.google.com/policies/technologies/ads (”Use of data for promotional purposes“), http://www.google.com/settings/ads (“Managing information that Google uses, to show advertisements”).

Online presence in social media

We maintain online presence within social networks and platforms in order to communicate with customers, interested persons and users and to inform them about our services. When visiting the respective networks and platforms, the terms and conditions and the data processing guidelines of the respective operators apply.

Unless otherwise stated in our Privacy Policy, users’ data will be processed as long as they communicate with us within social networks and platforms, e.g. Write posts on our online presence or send us messages.

Integration of services and contents of third parties

Based on our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. GDPR), we make use of content or services offered by third-party providers in order to use their content and services, such as videos or fonts (collectively referred to as “content”).

This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring web sites, visit time, and other information regarding the use of our online offer.

Vimeo

We embed the videos of the Vimeo platform of Vimeo Inc., Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA. Privacy Policy: https://vimeo.com/privacy.

Youtube

We embed the videos of the YouTube platform of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated.

Google fonts

We incorporate the fonts (“Google Fonts”) provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, opt-out: https://adssettings.google.com/authenticated.

Use of Facebook social plugins

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

Facebook is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

When a user invokes a feature of this online offering that includes such a plugin, their device establishes a direct connection to the Facebook servers. The content of the plugin is transmitted directly to the device of the user by Facebook and incorporated into the online offer. In the process, user profiles can be created from the processed data. We therefore have no influence on the amount of data that Facebook collects with the help of this plugin and therefore inform the users according to our knowledge.

By integrating the plugins, Facebook receives the information that a user has accessed the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to the respective Facebook account. If users interact with the plugins, for example, press the Like button or leave a comment, the information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook will identify and save their IP address. According to Facebook, only anonymous IP addresses are stored in Germany.

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

If a user is a Facebook member and does not want Facebook to collect data about him via this online offer and link him to his member data stored on Facebook, he must log out of Facebook before using our online offer and delete his cookies.

Other settings and objections regarding the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US-American site http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/. The settings are platform independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.

Instagram

Within our online offering we may include functions and content of the service Instagram, offered by the Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA. This means content such as images, videos, or text and buttons that users use to promote their content, subscribe to the content creators, or subscribe to our posts. If the users are members of the platform Instagram, Instagram can call connect and assign content and functions to the profiles of the users there. Instagram privacy policy: http://instagram.com/about/legal/privacy/.

Features and content of the Pinterest service offered by Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA, may be incorporated into our online offering. For this, e.g. content such as images, videos, or text and buttons that users use to promote their content, subscribe to the content creators, or subscribe to our posts. If the users are members of the platform Pinterest, Pinterest can connect and assign content and functions to the profiles of the users there. Pinterest Privacy Policy: https://about.pinterest.com/privacy-policy.

Within our online offer functions and contents of the service LinkedIn can be integrated, offered by the LinkedIn AG, Dammtorstraße 29-32, 20354 Hamburg, Germany. For example content such as images, videos, or text and buttons that users use to promote their content, subscribe to content creators, or subscribe to our posts. If the users are members of the platform LinkedIn, LinkedIn can connect and assign content and functions to the profiles of the users there. LinkedIn privacy statement: https://www.linkedin.com/legal/privacy-policy. LinkedIn is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation (https: //www.privacyshield. gov / participant? id = a2zt0000000L0UZAA0 & status = Active). Privacy Policy: https://linkedin.com/legal/privacy-policy, opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

The translation of this data protection declaration is based on the German text created by Datenschutz-Generator.de by RA Dr. Thomas Schwenke