25th May 2018

Privacy Policy

1)   Preamble

Welcome to our website! We attach great importance to the protection of your data and the preservation of your privacy. Below we would like to describe the type of data we process, when we process it, for what purpose and the legal basis for processing. This includes explaining to you how our services work and how we ensure the protection of your personal data in the process.

According to Art. 4 no. 1 GDPR, personal data are all information relating to an identified or identifiable natural person. A natural person is identifiable when it is possible to identify him or her, directly or indirectly. Further information can be found in Art. 4 no. 1 GDPR.

This privacy policy can be accessed, saved and printed at any time at https://www.proimageeditors.eu/privacy-policy/.

If we cite our legitimate interest or the legitimate interest of a third party (Art. 6(1) point f) GDPR) as the legal basis for processing personal data, you have the right to object according to Art. 21 GDPR:

According to Art. 21 GDPR you have the right

to object to the processing of personal data at any time. We will then no longer process the personal data for purposes of direct marketing or related profiling.

We will also no longer process your personal data for other purposes after an objection, unless we can prove legitimate reasons for processing it that outweigh your interests, rights and freedoms, or such processing is required for the assertion, exercise or defense of legal claims (see Art. 21(1) GDPR, “restricted right to object”). In this case, you must state the reasons for your objection that result from your particular situation.

You may also object to the processing of your personal data (reasons arising from your particular situation) for scientific or historical research purposes or for statistical purposes in accordance with Art. 89(1) GDPR, unless such processing is necessary for the performance of a task in the public interest (see Art. 21(6) GDPR).

We will also point out your right of objection separately in the individual sections (e.g. with the following note: “You have a right to object”), if this right exists. You will also find further information there on how to exercise your right of objection.

In order to ensure the following privacy policy is clear and friendly, we will occasionally use links to refer to data protection and other information located on external websites (see also the section “Social networks & external links” in this privacy policy). Although we make every effort to keep the links listed in this privacy policy up to date, due to the need to regularly update the website, we cannot exclude the possibility of links not functioning properly. Should you notice such a link, we would appreciate your informing us so that we can insert the current link. 

2)   Data controller

The data controller responsible within the meaning of Art. 4(7) GDPR for the processing of personal data:

ProImageExperts LLC (ProImageEditors)
Represented by the CEO Hezikiah de Souza

30405 Solon Road, Suite 9
Solon OH 44139, U.S.A.

Telefon: +49 800 183 0884 (GER)
or +1 440 319 3979 (US)
or +44 203 318 7710 (UK)
or +34 900 838 321 (ES)

E-Mail: [email protected]

The contact details of our representative in the European Union (Art. 27 GDPR) are as follows:

Stellar Attractions GmbH & Co. KG
Gottfried-Hagen Straße 30
51105 Cologne, Germany

Telefon: +49 221 222 37 22
E-Mail: [email protected]

3)  Data protection contact

If you have any questions about the processing of your personal data or your data protection rights, please contact:

Purva Kini, ProImageExperts LLC,
30405 Solon Road Suite 9,
Solon, OH, 44139, U.S.A
Telefon: +1 440-319-3979
E-Mail: [email protected]

4) Log files

Each time you visit our website, we automatically collect data and information from your device’s system and store it in server log files. Such data are information relating to an identified or identifiable natural person (in this case: website visitors). The data are transferred automatically by your browser when you visit our website. This includes the following information:

  • date and time of your visit to our website (request to the host provider’s server),
  • URL of the website from which you accessed our website,
  • IP address of your computer.

The purpose of such processing is to make our website accessible from your device and ensure our website is displayed correctly on your device or in your browser. We also use the data to optimize our website and to ensure the security of our systems. Such data are not evaluated for marketing purposes.

The legal basis for processing is Art. 6(1) point f) GDPR. We have a legitimate interest in providing you with a website optimized for your browser and enabling communication between our server and your device. The latter above all requires processing of your IP address.

The information processed is only stored for as long as is necessary for the intended purpose or required by law.

The data recipient is our server host, centron GmbH, Heganger 29, D-96103 Hallstadt, Germany, who works for us under a commissioned data processing agreement.

Right to object

You have a right to object. You can send or inform us of your objection at any time (e.g. by e-mail to [email protected]).

The provision of personal data is not required by law nor by contract, nor for conclusion of a contract. You are also not obliged to provide the personal data. Failure to do so may, however, result in your not being able to use our website or not being able to use it to its full extent.

5) Cookies

Our website uses cookies. Cookies are text files that are stored on your device in order, for example, to make the website more user-friendly or to recognize the user’s device and save settings, etc. Entries and settings on a website can be saved in cookies so that you do not have to enter them each time you visit that website. Cookies contain a cookie ID that makes it possible to identify the device on which the cookie was stored. We use the following cookies to do so:

  • Cookies that contain a randomly generated, concrete identification number that allows your device to be identified during your visit to our website. This serves the purpose of recognizing related requests from a user and thus assigning them to a specific usage session. These cookies are automatically deleted at the end of the browser session.
  • A cookie to indicate that you have approved the use of cookies.
  • A cookie that contains information about whether tracking has been disabled.

The following cookies, in particular, are used by us and by services we make use of:

Cookie

Provider / service

Term

Description

cookie_notice
_accepted

Cookie Notice

13 months

Storage of the user input on the cookie banner.

PHPSESSID

At the end of the browser session

This serves the purpose of recognizing related requests from a user and thus assigning them to a specific usage session.

COOKIE_CONSENT_STATUS

12 months

A cookie to indicate that you have approved the use of cookies.

ac_enable
_tracking

1 month

A cookie that contains information about whether tracking has been disabled.

You can also set your browser to display all the cookies we use on the website at any time, including further information about them.

The purpose of processing the cookies that we use directly is to make our website more user-friendly and allow you to save settings.

The legal basis for processing is Art. 6(1) point f) GDPR. We have a legitimate interest in providing you with a website that stores your personal preferences and makes things easier for you while visiting our website.

Right to object

You have a right to object.

You can adjust your browser setting to restrict or completely prevent the placement of cookies. You can also have cookies automatically deleted when the browser window is closed.

Find out how to delete cookies in the most commonly used browsers and how to adjust cookie settings here:

Google Chrome:                    website

Mozilla Firefox:                       website

Apple Safari:                          website

Microsoft Internet Explorer:   website

Microsoft Edge:                      website

The provision of personal data is not required by law nor by contract, nor for conclusion of a contract. You are also not obliged to provide the personal data. Failure to do so may, however, result in your not being able to use our website or not being able to use it to its full extent.

Other services we use also use cookies. We will point out the use of the cookies to you separately for the individual services.

6) Information about Google’s services

Our website makes use of various services provided by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

You can find more detailed information about the individual services provided by Google and used by our website in the privacy policy below.

Google may collect and process information (including personal data) about you through the integration of Google’s services. Google may also transfer such information to a server in a third country.

As outlined in Google’s Privacy Shield certification (you can find this at https://www.privacyshield.gov/list by using the search term “Google”), Google is committed to complying with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework regarding the collection, use and storage of personal data from EU member states and Switzerland. Google, including Google LLC and its wholly owned subsidiaries in the USA, has been certified as complying with the Privacy Shield Principles. Further information about this is available at https://www.google.de/policies/privacy/frameworks/.

Although we ourselves have no influence on the data that Google actually collects and processes, Google indicates that inter alia the following data (including personal data) may be processed:

  • log data (in particular the IP address)
  • location-related information
  • unique application numbers
  • cookies and similar technologies

Information about the types of cookies used by Google can be found at https://policies.google.com/technologies/types.

If you are signed in to your Google Account, Google may – depending on your account preferences – add the processed information to your account and treat it as personal information. Google states, among other things, the following in this regard:

“When you’re not signed in to a Google Account, we store the information we collect with unique identifiers tied to the browser, application, or device you’re using. This helps us do things like maintain your language preferences across browsing sessions.

When you’re signed in, we also collect information that we store with your Google Account, which we treat as personal information.” (https://www.google.com/intl/en/policies/privacy/index.html)

You can prevent this information from being added directly by logging out of your Google Account or by adjusting the appropriate account settings in your Google Account. You can also prevent the installation of cookies – if Google uses any – by selecting the appropriate settings in your browser; please note, however, that if you do so you may not be able to use all the functions of this website.

Find out how to delete cookies in the most commonly used browsers here:

  • Google Chrome:                    website
  • Mozilla Firefox:                      website
  • Apple Safari:                          website
  • Microsoft Internet Explorer:   website
  • Microsoft Edge:                      website

For more information, please refer to Google’s privacy policy, which can be found here:

You can find information about Google’s privacy settings at https://privacy.google.com/take-control.html

7) Google reCAPTCHA

This website uses Google reCAPTCHA (hereinafter reCAPTCHA), a captcha service provided by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google reCAPTCHA helps ensure that entries on our website are actually made by real people and not generated automatically, e.g. by software (referred to as robots).

For this purpose, reCAPTCHA (No CAPTCHA reCAPTCHA) shows you a clickable “I am not a robot” checkbox. reCAPTCHA analyzes the user’s behavior on the basis of various characteristics as soon as he or she visits the website. After clicking on the checkbox, you may also be shown various images that you must assign to a given image motif by clicking on the relevant images (e.g. selection of all images with cars).

reCAPTCHA is integrated via an interface (“API”) into Google services. Google may collect and process information (including personal data) about you through the integration of reCAPTCHA. Google may also transfer such information to a server in a third country.

reCAPTCHA may use “cookies”, text files stored on your device that allow an analysis of the use of the webpages you visit. reCAPTCHA also uses web beacons, i.e. small pixels or graphics. The information generated by the cookie in connection with the web beacon about your use of this website (including your IP address) is transmitted to a Google server, possibly in the USA or another third country, and stored there.

For information about Google’s existing Privacy Shield certification and other data relating to Google’s processing of data when using Google services, please see section “6) Information about Google’s services” of this privacy policy.

For further information about how reCAPTCHA works, please visit: https://developers.google.com/recaptcha/

For more information about Google’s privacy policy, please visit: https://policies.google.com/privacy?hl=de

For more general information, please visit https://www.google.com/intl/de/policies/privacy/#infocollect under “Data that we receive as a result of your use of our services.”

The purpose of integrating reCAPTCHA is to help us determine whether entries on our website are made by a real person or by a bot. It thus helps maintain the functionality of our website and offer you the full range of services.

The legal basis for processing of personal data described here is Art. 6(1) point f) GDPR. The required legitimate interest we have in doing so is the significant benefit that the function described above provides for our website. The automated check of whether a real person or a bot is making the entries accelerates and simplifies our workload while increasing the level of reliability of the entries. It also prevents misuse.   Google also has a legitimate interest in that the (personal) data collected help it improve its own services.

Right to object

You have a right to object. 

You can prevent placement of cookies by selecting the appropriate settings in your browser; please note, however, that if you do so you may not be able to use the full functions of this website.

Find out how to delete cookies in the most commonly used browsers here:

Google Chrome:                    website

Mozilla Firefox:                       website

Apple Safari:                          website

Microsoft Internet Explorer:   website

Microsoft Edge:                      website

The information processed is only stored for as long as is necessary for the intended purpose or required by law.

The provision of personal data is not required by law nor by contract, nor for conclusion of a contract. You are also not obliged to provide the personal data. Failure to do so may, however, result in your not being able to use our website or not being able to use it to its full extent.

8) Use of YouTube

We use YouTube videos and YouTube plug-ins on our website. YouTube is a service provided by YouTube LLC (“YouTube”), 901 Cherry Ave, San Bruno, CA 94066, USA. YouTube LLC is a subsidiary of “Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.”

YouTube is integrated by embedding the service into our website by means of an “iFrame”. YouTube or Google may collect and process information (including personal data) about you when you load this iFrame. YouTube or Google may also transfer such information to a server in a third country.

For information about Google’s existing Privacy Shield certification and other data relating to Google’s processing of data when using Google services, please see section “6) Information about Google’s services” of this privacy policy.

We use YouTube in so-called “Extended privacy mode”. According to the information provided by Google, a video can be played without the user behavior being recorded by cookies. We do not collect any data ourselves when you watch a YouTube video on our website.

The purpose of integrating YouTube is to allow you to view various videos directly on our website.

The legal basis for processing of personal data described here is Art. 6(1) point f) GDPR. The required legitimate interest we have in doing so is the significant benefit YouTube provides. By integrating external videos, we take the weight off our servers and can use the corresponding resources elsewhere. Among other things, this can increase the stability of our servers. YouTube and Google also have a legitimate interest in that the (personal) data collected help it to improve its own services.

Right to object

You have a right to object. You can send or inform us of your objection at any time (e.g. by e-mail to [email protected]).

You can also change your cookie settings (e.g. delete cookies, block cookies, etc.). For more information, see “5) Cookies”.

The provision of personal data is not required by law nor by contract, nor for conclusion of a contract. You are also not obliged to provide the personal data. Failure to do so may, however, result in your not being able to use our website or not being able to use it to its full extent.

For more information, please refer to YouTube’s or Google’s privacy policy, which can be found here: www.google.com/policies/privacy/

You can find information about Google’s privacy settings at https://privacy.google.com/take-control.html?categories_activeEl=sign-in

9) Contact form

Our website includes a contact form that you can use to contact us via the Internet.

We use the WordPress plug-in “Contact Form 7” service to provide the contact form. The data you enter there is sent directly to our customer service department’s e-mail address.

If you use this contact form to contact us we will process the data you enter in the input fields.

The following data are part of the mandatory information:

  • e-mail address
  • subject
  • the information contained in your message text

You can also add further data as voluntary information. This may help simplify and speed up processing of your request. The following data are potentially affected in this case:

  • Name

We treat mandatory and voluntary information in the same way. The mandatory information is necessary in order to contact you and enable us to process your request. Sending of the message does not result in any data storage by us.

Please note that the extent of the personal data collected on the contact form also depends on the data that you yourself disclose in your message text on the contact form.

The purpose of processing personal data included with the mandatory and voluntary data is to process the contact request and enable us to contact the requesting party in order to respond to the request.

The legal basis for processing of personal data described here is Art. 6(1) point f) GDPR. It is in our legitimate interest to offer you the opportunity to contact us at any time so that we can answer your questions.

Personal data are only processed as long as needed to provide the relevant function and are subject to our “Data Life Cycle Concept” for the deletion of personal data.

The data you provide on registration is transferred to and stored in the CRM system “Vtiger”, No. 95, 12th Main, 3rd Block, Rajajinagar, Bangalore – 560 010 India. The CRM provider Vtiger works for us in the context of commissioned data processing.

The legal basis for the processing of personal data described here is Art. 6(1) point f) GDPR.

The required legitimate interest we have in doing so pursuant to Art. 6(1) point f) GDPR is the significant benefit that integrating a CRM system brings. Using the CRM system gives us the basis we need to provide our services and thus helps us establish a customer profile. The customer briefings you submit during the order process are also stored in our CRM system. This is absolutely necessary as it allows us to refine and improve the quality of our services continuously. Vtiger also has a legitimate interest in that the (personal) data collected help it to improve its own services.

The service provider Vtiger is based in a country for which no European Union adequacy decision has been adopted (Art. 45 GDPR). Our collaboration is thus based on standard data protection clauses of the European Commission (Art. 46 GDPR). You are welcome to request a copy of the relevant standard contractual clause from us at any time.

Right to object

You have the right at any time to object to the processing of your personal data. You can send or inform us of your objection at any time (e.g. by e-mail to [email protected]). 

The data recipient is Vtiger. The company works for us in the context of a commissioned data processing agreement. Halo Media Works Pvt Ltd, 303-305, Business Classic, Behind HP Petrol Pump, Chincholi Bunder Road, Malad West, Mumbai, Maharashtra 400064, India is another data recipient. Halo Media Works works for us in the context of commissioned data processing.

Halo Media Works is based in a country for which no European Union adequacy decision has been adopted (Art. 45 GDPR). Our collaboration is thus based on standard data protection clauses of the European Commission (Art. 46 GDPR). You are welcome to request a copy of the relevant standard contractual clause from us at any time.

Your name, e-mail address, subject and any information included in the message text will be forwarded to our customer service department at Halo Media Works Pvt Ltd, 303-305, Business Classic, Behind HP Petrol Pump, Chincholi Bunder Road, Malad West, Mumbai, Maharashtra 400064, India, who will do their best to help you with any unresolved issues you may have.

The provision of personal data is not required by law nor by contract, nor for conclusion of a contract. You are also not obliged to provide the personal data. Failure to do so may, however, result in your not being able to use our contact form.

10) Newsletter

We give you the option of subscribing to our newsletter on our website.

We use the service provided by ActiveCampaign LLC, 222 South Riverside Plaza, Chicago IL, Suite 810 60606, USA (“ActiveCampaign”) to send the newsletter.

The information you enter when subscribing to our newsletter (e-mail address) is stored on ActiveCampaign’s servers in the USA.

As outlined in ActiveCampaign’s Privacy Shield certification (you can find this at https://www.privacyshield.gov/list by using the search term “Active Campaign”), ActiveCampaign is committed to complying with the EU-US Privacy Shield Framework published by the U.S. Department of Commerce regarding the collection, use and storage of personal data from EU member states and Switzerland. ActiveCampaign LLC has been certified as complying with the Privacy Shield Principles.

We have also concluded a commissioned data processing agreement (Art. 28 GDPR) with ActiveCampaign. The agreement stipulates that ActiveCampaign undertakes to protect the data of our users, while processing said data exclusively in accordance with the data protection regulations on our behalf and in accordance with our instructions. Further information about this is available at https://www.activecampaign.com/privacy-policy/.

If you register for our newsletter, we process the following information (including personal data) about you:

  • e-mail address
  • date and time
  • IP address

In order to be able to present proof of consent and delivery in a legally compliant manner, we store the following data regarding registration, change, confirmation and delivery of the newsletter for each user profile that is generated with an e-mail address confirmed by the double opt-in procedure:

  • date and time
  • IP address

We also process the following information (including personal data) from you within the scope of your use of our newsletter:

  • object and profile reference
  • e-mail address
  • date on which the user account is opened
  • IP address
  • type of action (registration, update)
  • permission change
  • metadata regarding the action
  • name
  • company
  • phone
  • country
  • language
  • personal website
  • coupon codes used
  • free trial offers used
  • name of account manager
  • geo-tag
  • newsletter consent
  • verification of user account
  • ProImageEditors websites visited
  • completed e-mail automation

The data are processed by us, ActiveCampaign, Stellar Attractions and – if applicable – subcontractors of ActiveCampaign as part of the data processing. Subcontractors of ActiveCampaign process the data according to instructions and on our behalf just as ActiveCampaign does.

We make use of ActiveCampaign’s service to analyze the success and reach of our newsletters (campaigns). We evaluate, for example, whether you open a newsletter and how you otherwise use the newsletter.

For this purpose, ActiveCampaign uses and stores cookies in order to make statistical surveys and build up interest profiles. ActiveCampaign may also use web beacons (invisible graphics). These web beacons can be used to evaluate information such as visitor traffic on websites. The information generated by the cookie and web beacons about the use of our website (including users’ IP addresses) is transmitted to an ActiveCampaign server, possibly in the USA or another third country, and stored there. ActiveCampaign may share this information with its contractual partners. This allows us to understand how you react to individual newsletters we send you (e.g. whether you opened the newsletter).

By registering for the newsletter, you consent to the processing of your personal data (Art. 6(1) point a) GDPR), whereby we use a double opt-in procedure to ensure secure registration:

First you enter the mandatory data (e.g. e-mail address) and consent to processing of your personal data by ticking the appropriate box. Then you are automatically sent an e-mail with a confirmation or activation link that you are also prompted to confirm or activate. This ensures that the e-mail address you enter on our website really is yours.

Collecting and processing the user’s e-mail address allows us to deliver the newsletter. Further personal data are collected and processed as part of the registration process in order to prevent misuse of our newsletter or the e-mail address used. The processing described above also helps us to prove that you have given us your consent.

Processing cookie and measurement data allows us to track the success and reach of our newsletters.

Your consent pursuant to Art. 6(1) point a) GDPR is the legal basis for processing the personal data needed for technical provision of the newsletter and for processing of cookie and measurement data.

Our legitimate interest according to Art. 6(1) point f) GDPR is the legal basis for processing further personal data. We have a legitimate interest in being able to prove that you have given us your consent. We also have a legitimate interest in being able to prevent or prove misuse of our newsletter.

Your rights:

  1. Right of revocation

Right of revocation

You have the right to revoke your consent at any time, without affecting the lawfulness of the processing that took place on the basis of the consent up to the time of revocation. You can send or inform us of your revocation of consent at any time (e.g. by e-mail to [email protected]).

You can also revoke your consent simply by clicking on the “Cancel subscription to this newsletter” link provided for this purpose in our newsletter.

  1. Right to object

If the processing of your data is not covered by your consent (especially log files), you have a right to object.

Right to object

You can send or inform us of your objection at any time (e.g. by e-mail to [email protected]).

Your registration data will thus only be stored as long as your newsletter subscription is active. The data are deleted as soon as they are no longer required for the purpose for which they were collected and are subject to our “Data Life Cycle Concept” for the deletion of personal data. If you do not confirm the e-mail as part of the double opt-in procedure, your registration will be automatically deleted after 15 days.

ActiveCampaign and Stellar Attractions are the relevant data recipients. They work for us in the context of a commissioned data processing agreement.

The provision of personal data is not required by law nor by contract, nor for conclusion of a contract. You are also not obliged to provide the personal data. Failure to do so would, however, mean that we would be unable to provide you with a newsletter.

11) Registration option (registration and user account)

We give you the option of registering on our website and creating a user account.

  1. a) Initial registration:

The first step of registration gives you the option of filling out a registration form. The data required in the input fields are processed in this step.

We use the service provided by ActiveCampaign LLC, 222 South Riverside Plaza, Chicago IL, Suite 810 60606, USA (“ActiveCampaign”) for the registration form.

If you use our registration form, the information you provide is stored on ActiveCampaign’s servers in the USA and on our servers in order to integrate the information into our ordering system and your user profile.

As outlined in ActiveCampaign’s Privacy Shield certification (you can find this at https://www.privacyshield.gov/list by using the search term “Active Campaign”), ActiveCampaign is committed to complying with the EU-US Privacy Shield Framework published by the U.S. Department of Commerce regarding the collection, use and storage of personal data from EU member states and Switzerland. ActiveCampaign LLC has been certified as complying with the Privacy Shield Principles.

We have also concluded a commissioned data processing agreement (Art. 28 GDPR) with ActiveCampaign. The agreement stipulates that ActiveCampaign undertakes to protect the data of our users, while processing said data exclusively in accordance with the data protection regulations on our behalf and in accordance with our instructions. Further information about this is available at https://www.activecampaign.com/privacy-policy/.

If you register on our website, we process the following information (including personal data) about you:

  • object and profile reference
  • e-mail address
  • date and time
  • IP address
  • type of action (registration, update, permission change)
  • metadata regarding the action

In order to be able to present proof of consent and delivery in a legally compliant manner, we store the following data regarding registration, change, confirmation and delivery of the newsletter for each user profile that is generated with an e-mail address confirmed by the double opt-in procedure:

  • date and time
  • IP address

We also process the following information (including personal data) from you within the scope of your use of our registration form:

  • object and profile reference
  • e-mail address
  • date and time
  • IP address
  • type of action (registration, update)
  • permission change
  • metadata regarding the action

The following data are also processed on registration:

  • geo-tag:
  • time & date:
  • e-mail openings:

The data are processed by us, ActiveCampaign, Stellar Attractions, Vtiger and – if applicable – subcontractors of ActiveCampaign as part of data processing. Subcontractors process the data according to instructions and on our behalf just as ActiveCampaign does.

By registering, you consent to the processing of your personal data (Art. 6(1) point a) GDPR); we use a double opt-in procedure to ensure secure registration:

First you enter the mandatory data (e.g. e-mail address) and consent to processing of your personal data by ticking the appropriate box. Then you are automatically sent an e-mail with a confirmation or activation link that you are also prompted to confirm or activate. This ensures that the e-mail address you enter on our website really is yours. Once you have confirmed the activation link, you can set your user password and then place your first order.

Collection and processing of the data you provide during the registration process allows us to send you the confirmation e-mail and offer you the option of creating a user account on our website. Further personal data are collected and processed as part of the registration process in order to prevent misuse of our registration form or the e-mail address used. The processing described above also helps us to prove that you have given us your consent.

The purpose of using the geo-tag is to enable us to identify where our customers come from and tailor our services accordingly, and to identify spam accounts. The purpose of processing the time and date is to filter out active accounts. The purpose of processing e-mail openings is to track the efficiency of the newsletter campaigns and thus continuously improve them.

Our legitimate interest according to Art. 6(1) point f) GDPR is the legal basis for processing further personal data. We have a legitimate interest in being able to prove that you have given us your consent. We also have a legitimate interest in being able to prevent or prove misuse of our registration form.

The data you provide on registration is transferred to and stored in the CRM system “Vtiger”, No. 95, 12th Main, 3rd Block, Rajajinagar, Bangalore – 560 010 India. The CRM provider Vtiger works for us in the context of commissioned data processing.

The legal basis for the processing of personal data described here is Art. 6(1) point f) GDPR.

The service provider Vtiger is based in a country for which no European Union adequacy decision has been adopted (Art. 45 GDPR). Our collaboration is thus based on standard data protection clauses of the European Commission (Art. 46 GDPR). You are welcome to request a copy of the relevant standard contractual clause from us at any time.

The required legitimate interest we have in doing so pursuant to Art. 6(1) point f) GDPR is the significant benefit that integrating a CRM system brings. Using the CRM system gives us the basis we need to provide our services and thus helps us establish a customer profile. The customer briefings you submit during the order process are also stored in our CRM system. This is absolutely necessary as it allows us to refine and improve the quality of our services continuously. Vtiger also has a legitimate interest in that the (personal) data collected help it to improve its own services.

Your rights:

  1. Right of revocation

Right of revocation

You have the right to revoke your consent at any time, without affecting the lawfulness of the processing that took place on the basis of the consent up to the time of revocation. You can send or inform us of your revocation of consent at any time (e.g. by e-mail to [email protected]).

You can also revoke your consent simply by clicking on the “Cancel subscription to this newsletter” link provided for this purpose in our newsletter.

  1. Right to object

If the processing of your data is not covered by your consent (especially log files), you have a right to object.

Right to object

You can send or inform us of your objection at any time (e.g. by e-mail to [email protected]).

Our server host, Stellar Attractions, Vtiger and ActiveCampaign are the relevant data recipients. They work for us in the context of a commissioned data processing agreement.

The data are deleted as soon as they are no longer required for the purpose for which they were collected and are thus subject to our “Data Life Cycle Concept” for the deletion of personal data. If you do not confirm the e-mail as part of the double opt-in procedure, your registration will be automatically deleted after 15 days.

The provision of the aforementioned data is not required by law nor by contract, nor for concluding a contract. You are also not obliged to provide the personal data. Failure to do so, however, means that you cannot register with us as a user.

  1. b) User account:

After registering as a user on our website, you can enter further data under “My profile” to complete your user profile and thus create a user account. 

The data required in the input fields are processed in this step.

To create a user profile, we use the service provided by ActiveCampaign LLC, 222 South Riverside Plaza, Chicago IL, Suite 810 60606, USA (“ActiveCampaign”) and our CRM system “Vtiger”, No. 95, 12th Main, 3rd Block, Rajajinagar, Bangalore – 560 010 India.

If you provide additional information after registration, the information you give is stored on ActiveCampaign’s servers in the USA.

As outlined in ActiveCampaign’s Privacy Shield certification (you can find this at https://www.privacyshield.gov/list by using the search term “Active Campaign”), ActiveCampaign is committed to complying with the EU-US Privacy Shield Framework published by the U.S. Department of Commerce regarding the collection, use and storage of personal data from EU member states and Switzerland. ActiveCampaign LLC has been certified as complying with the Privacy Shield Principles.

We have also concluded a commissioned data processing agreement (Art. 28 GDPR) with ActiveCampaign. The agreement stipulates that ActiveCampaign undertakes to protect the data of our users, while processing said data exclusively in accordance with the data protection regulations on our behalf and in accordance with our instructions. Further information about this is available at https://www.activecampaign.com/privacy-policy/.

The data are processed by us, ActiveCampaign, Stellar Attractions, Vtiger and – if applicable – subcontractors of ActiveCampaign as part of data processing. Subcontractors process the data according to instructions and on our behalf just as ActiveCampaign does.

Collection and processing of the data you provide when creating your user account allows us to offer you the option of creating a user account on our website.

The legal basis for the processing of personal data is Art. 6(1) point b) GDPR.

The data you provide in your user account are transferred to and stored in the CRM system “Vtiger”, No. 95, 12th Main, 3rd Block, Rajajinagar, Bangalore, 560 010 India. The CRM provider Vtiger works for us in the context of commissioned data processing.

The service provider Vtiger is based in a country for which no European Union adequacy decision has been adopted (Art. 45 GDPR). Our collaboration is thus based on standard data protection clauses of the European Commission (Art. 46 GDPR). You are welcome to request a copy of the relevant standard contractual clause from us at any time.

The required legitimate interest we have in doing so pursuant to Art. 6(1) point f) GDPR is the significant benefit that integrating a CRM system brings. Using the CRM system gives us the basis we need to provide our services and thus helps us establish a customer profile. The customer briefings you submit during the order process are also stored in our CRM system. This is absolutely necessary as it allows us to refine and improve the quality of our services continuously. Vtiger also has a legitimate interest in that the (personal) data collected help it improve its own services.

The user account you create is not public and cannot be indexed by search engines. If you want to delete your user account, please contact our customer service department at… As soon as we have deleted the user account you created, the data you entered to create the user account are deleted, subject to retention necessary for commercial or tax reasons and subject to our “Data Life Cycle Concept”. The information you enter in your user account remains there until it is deleted and is subsequently archived if there is a legal obligation to do so or if we have a legitimate interest in doing so. This may be the case, for example, in the event of a legal dispute.

Right to object

You have the right at any time to object to the processing of your personal data. You can send or inform us of your objection at any time (e.g. by e-mail to [email protected]

Our server host, Stellar Attractions, Vtiger and ActiveCampaign are the relevant data recipients. They work for us in the context of a commissioned data processing agreement. 

Insofar as we have specified Art. 6(1) point b) GDPR as the legal basis, the provision of personal data is required in order to register and thus also in order to conclude the contract. Failure to provide the data would result in the contract not being concluded.

The provision of the aforementioned personal data is otherwise not required by law nor by contract, nor for concluding a contract. You are also not obliged to provide the personal data. Failure to do so however means that you will not be able to create a user account.

12) Ordering and processing

As part of the ordering process on our website, we process data to help you select and order the services you want and to facilitate payment for and delivery or execution of said services.

As a registered user, you can log in to the ordering system to place an order via an http-encrypted website with a SSL certificate. After selecting the services you require, you can fill out a form with information such as the number of files, job, name, and other instructions.

The next step is to confirm the order information.

At the end of the ordering process you will be redirected to a payment page. With regard to payment transactions, please see the explanations and information in the section “15) Payment transactions” in this privacy policy.

The processed data includes the following

  • inventory data
  • communications data
  • contract data
  • payment data
  • billing data

The following data are also processed when the order is sent:

  • your IP address
  • date and time
  • traffic source

We process data from our customers, prospective customers and other business partners.

Once your chosen payment method has been successfully approved, an order will be generated and a confirmation will be sent to the e-mail address you provided.

The data are processed for the purpose of providing contractual services, invoicing, and delivery of the ordered image processing and customer service.

The legal basis for the data processing described here is Art. 6(1) point b) GDPR.

Insofar as we process the image file, we process it as a contractor for the data controller. This is the photographer who uses our services. The data controller can provide you with information about the legal basis for said processing. We have concluded a commissioned data processing agreement with the data controller (Art. 28 GDPR).

We use session cookies to store the contents of the shopping cart as part of the ordering process.

The legal basis for processing the data associated with placement of the cookie is Art. 6(1) point f) GDPR. We have a legitimate interest in ensuring that the data you initially enter as part of the ordering process continues to be stored for you on our website during the rest of the ordering process.

Our legitimate interest according to Art. 6(1) point f) GDPR is the legal basis for processing further personal data. 

Date and time are recorded by ActiveCampaign LLC, 222 South Riverside Plaza, Chicago IL, Suite 810 60606, USA. (“ActiveCampaign”) who work for us in the context of a commissioned data processing agreement. 

We use those data to identify active or inactive users. This is necessary in order to evaluate and improve the quality of our services continuously.

Once the payment process is complete, you can upload the files (including your free trial order) using your browser, SFTP, and cloud storage services. With regard to the various ways of uploading the image files and sending them to us and the associated data processing, please see the explanations and information in section “15) Upload options for image files” of this privacy policy.

Our ordering system separates incoming information into two groups: the order instructions and the files that are forwarded to production for further processing. Halo Media Works Pvt Ltd, 303-305, Business Classic, Behind HP Petrol Pump, Chincholi Bunder Road, Malad West, Mumbai, Maharashtra 400064, India takes care of production. Halo Media Works works for us in the context of commissioned data processing.

Halo Media Works is based in a country for which no European Union adequacy decision has been adopted (Art. 45 GDPR). Our collaboration is thus based on standard data protection clauses of the European Commission (Art. 46 GDPR). You are welcome to request a copy of the relevant standard contractual clause from us at any time.

The customer data and job ID are forwarded to our customer service department at Halo Media Works Pvt Ltd, 303-305, Business Classic, Behind HP Petrol Pump, Chincholi Bunder Road, Malad West, Mumbai, Maharashtra 400064, India, who will do their best to help you with any unresolved issues you may have.

As soon as an order you place has been completed, we will contact you by e-mail.  You can then download the finished files in your user profile under “My orders”.

You can download the finished files up to 15 days after they have been made available to you. A copy of the file(s) you ordered will also be stored for 30 days after order completion on our in-house backup server with the following address: Halo Media Works Pvt Ltd, 303-305, Business Classic, Behind HP Petrol Pump, Chincholi Bunder Road, Malad West, Mumbai, Maharashtra 400064, India.

The data you provide as part of your order are stored by our server host: centron GmbH, Heganger 29, D-96103 Hallstadt, Germany. We have concluded a commissioned data processing agreement with the server host.

The data you provide when placing an order are transferred to and stored in the CRM system “Vtiger”, No. 95, 12th Main, 3rd Block, Rajajinagar, Bangalore – 560 010 India. The CRM provider Vtiger works for us in the context of commissioned data processing.

The service provider Vtiger is based in a country for which no European Union adequacy decision has been adopted (Art. 45 GDPR). Our collaboration is thus based on standard data protection clauses of the European Commission (Art. 46 GDPR). You are welcome to request a copy of the relevant standard contractual clause from us at any time.

The required legitimate interest we have in doing so pursuant to Art. 6(1) point f) GDPR is the significant benefit that integrating a CRM system brings. Using the CRM system gives us the basis we need to provide our services and thus helps us establish a customer profile. The customer briefings you submit during the order process are also stored in our CRM system. This is absolutely necessary as it allows us to refine and improve the quality of our services continuously. Vtiger also has a legitimate interest in that the (personal) data collected help it improve its own services.

Right to object

You have the right at any time to object to the processing of your personal data. You can send or inform us of your objection at any time (e.g. by e-mail to [email protected]).

The relevant data recipients are Halo Media Works, Active Campaign, Vtiger, and our server host, who work for us in the context of a commissioned data processing agreement.

Insofar as we have specified Art. 6(1) point b) GDPR as the legal basis, the provision of personal data is required to place an order and thus to conclude the contract. Failure to provide the data would result in the contract not being concluded.

The provision of the aforementioned personal data is otherwise not required by law nor by contract, nor for concluding a contract. You are also not obliged to provide the personal data. Failure to do so, however, means that you will not be able to place an order and we will not be able to conclude a contract with you.

13) Use of Workfront

As a customer, after placing an order our website gives you the option of requesting a “proof of work” of the images being processed. For this purpose, w use the service provided by Workfront, 3301 Thanksgiving Way, Suite 100, Lehi, Utah 84043, USA (previously ProofHQ:  https://www.workfront.com/proofhq).

Customers can thus obtain proof or an interim status for images that have already been processed. This allows the customer to decide, based on the images sent, whether the processed images are acceptable or whether a modification is required.

This service option involves voluntary provision of data.

The processed data includes the following:

  • If you request a “proof of work”, your e-mail address, name and processed image(s) will be uploaded to Workfront.

Workfront then sends the respective customer an e-mail containing a link that enables him or her to view the images. You can then use the link to accept the “proof of work” as without objection or provide feedback on the order. If you accept the “proof of work”, the process is finished, otherwise a new process run starts after your feedback.

As outlined in Workfront’s Privacy Shield certification (you can find this at https://www.privacyshield.gov/list by using the search term “Workfront”), Workfront is committed to complying with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework regarding the collection, use and storage of personal data from EU member states and Switzerland. Workfront has been certified as complying with the Privacy Shield Principles. Further information about this is available at https://www.google.de/policies/privacy/frameworks/.

We use Workfront to give our customers the option of being sent a “proof of work” after having placed an order and of thus promptly sending feedback and/or requesting changes. This helps us to improve our website continuously.

The legal basis for processing of personal data described here is Art. 6(1) point f) GDPR. The required legitimate interest we have in doing so is the significant benefit the functions described above provide for our website. Allowing customers to provide timely feedback on our services helps us react and optimize our website in line with the interests of our customers.

Right to object

You have a right to object. You can send or inform us of your objection at any time (e.g. by e-mail to [email protected]).

The data recipient is Workfront, a company that works for us in the context of a commissioned data processing agreement.

The information it processes is stored for 30 days and automatically deleted at the end of this retention period.

For more information about Workfront’s data handling practices, please refer to Workfront’s privacy policy:

https://www.workfront.com/privacy-policy

and

https://www.workfront.com/sites/default/files/files/2019-01/Workfront%20Privacy%20FAQ.pdf

The provision of personal data is not required by law nor by contract, nor for conclusion of a contract. You are also not obliged to provide the personal data. Failure to do so may, however, result in your not being able to use our website and services or not being able to use it to its full extent.

14) Upload options for image files

a) Upload via browser

Our website allows you to use your browser to upload the images required for the provision of our contractual services.

We process the following data for this purpose:

  • the image(s)
  • the name of the image in the log file
  • and the customer ID in the ordering system.

The legal basis for the processing of personal data is Art. 6(1) point b) GDPR.

Insofar as we process the image file, we process it as a contractor for the data controller. This is the photographer who uses our services. The data controller can provide you with information about the legal basis for said processing. We have concluded a commissioned data processing agreement with the data controller (Art. 28 GDPR).

With regard to the ordering process and the associated data processing, please see the explanations and information in section “16) Ordering and processing”.

The provision of personal data is required in order to perform the contractual services and thus also to conclude the contract. Failure to provide the data would result in the contract not being concluded.

b) Upload via SFTP

Our website allows you to use Secure File Transfer Protocol (SFTP) to upload the images required for the provision of our contractual services. 

The Secure File Transfer Protocol ensures secure file transfer over a reliable data stream. The SFTP protocol runs over a secure channel to ensure that passwords and file information are never transmitted in plain text. These file transfer protocols encrypt the connection between your computer and the FTP server. Your data are then transferred to and from your computer via this encrypted connection (SSH tunnel).

We process the following data for this purpose:

  • the image(s)
  • order number
  • IP address
  • date

The legal basis for the processing of personal data is Art. 6(1) point b) GDPR.

Insofar as we process the image file, we process it as a contractor for the data controller. This is the photographer who uses our services. The data controller can provide you with information about the legal basis for said processing. We have concluded a commissioned data processing agreement with the data controller (Art. 28 GDPR).

With regard to the ordering process and the associated data processing, please see the explanations and information in section “16) Ordering and processing”.

The provision of personal data is required in order to perform the contractual services and thus also to conclude the contract. Failure to provide the data would result in the contract not being concluded.

c) Use of cloud storage services (via Dropbox upload link, WeTransfer or Google Drive)

  1. aa) Dropbox

You can upload the files to the https://www.dropbox.com platform. Dropbox is a file hosting service (also referred to as cloud storage) provided by Dropbox Inc. 333 Brannan St, San Francisco, CA 94107, USA (“Dropbox”).

Dropbox uses servers at locations in the USA and around the world.

As outlined in Dropbox’s Privacy Shield certification (you can find this at https://www.privacyshield.gov/list by using the search term “Dropbox”), Dropbox is committed to complying with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework regarding the collection, use and storage of personal data from EU member states and Switzerland. Dropbox has been certified as complying with the Privacy Shield Principles. Further information about this is available at https://www.google.de/policies/privacy/frameworks/.

According to Dropbox itself, if you delete your Dropbox Basic, Plus or Professional account, Dropbox erases your stored data 30 days later. If you are a Dropbox Business user, your administrator is responsible for deactivating your account and erasing your files.

Dropbox uses automated decision making (including machine learning) to collect and process your personal information in order to provide and improve its services and, depending on the particular case, to market them in order to pursue its legitimate interests or with your consent.

We have concluded a commissioned data processing agreement with Dropbox (Art. 28 GDPR).

Privacy information about this Dropbox service can be found at https://www.dropbox.com/de/privacy. For more information about Dropbox, visit https://www.dropbox.com/help/security/privacy-policy-faq.

The legal basis for the processing of personal data is Art. 6(1) point b) GDPR.

Insofar as we process the image file, we process it as a contractor for the data controller. This is the photographer who uses our services. The data controller can provide you with information about the legal basis for said processing. We have concluded a commissioned data processing agreement with the data controller (Art. 28 GDPR).

With regard to the ordering process and the associated data processing, please see the explanations and information in section “16) Ordering and processing”.

The data recipient is Dropbox Inc. The company works for us in the context of a commissioned data processing agreement.

The provision of personal data is required in order to perform the contractual services and thus also to conclude the contract. Failure to provide the data would result in the contract not being concluded.

  1. bb) WeTransfer

You can upload the files to the https://wetransfer.com/ platform. WeTransfer is a file hosting service introduced in 2009. The service provider is WeTransfer B.V., Oostelijke Handelskade 751, 1019 BW Amsterdam, Netherlands. The primary purpose of WeTransfer is not to permanently store and share files with others, but rather to send large files to one or more recipients (i.e. short-term storage on the server for the purpose of downloading files in the near future). It is not necessary to register with WeTransfer in order to use the service. You only have to store your own e-mail address and that of the recipient. According to the operator, files are erased from the server one week after uploading.

WeTransfer uses servers in both the USA and the EU. If you upload files in the EU, according to WeTransfer they will be stored exclusively on servers in the EU.

When you use WeTransfer, WeTransfer states that it processes the following data:

  • your IP address
  • your e-mail address
  • the recipient’s e-mail address (our e-mail address)
  • your message to the recipient (to us)
  • our IP address
  • file name, size and type
  • country of origin and language settings
  • browser type and version
  • operating system

WeTransfer states that it stores the personal data associated with an upload for no longer than 12 months. The file(s) you upload are stored at WeTransfer for 7 days and then automatically deleted. If you use WeTransfer Plus, the process is somewhat different.

We have concluded a commissioned data processing agreement with WeTransfer (Art. 28 GDPR).

Privacy information about the WeTransfer service can be found at https://wetransfer.com/legal/privacy.

The legal basis for the processing of personal data is Art. 6(1) point b) GDPR.

Insofar as we process the image file, we process it as a contractor for the data controller. This is the photographer who uses our services. The data controller can provide you with information about the legal basis for said processing. We have concluded a commissioned data processing agreement with the data controller (Art. 28 GDPR).

With regard to the ordering process and the associated data processing, please see the explanations and information in section “16) Ordering and processing”.

The data recipient is WeTransfer B.V. The company works for us in the context of a commissioned data processing agreement.

The provision of personal data is required in order to perform the contractual services and thus also to conclude the contract. Failure to provide the data would result in the contract not being concluded.

cc) Google Drive

You can upload the files to the https://www.google.com/intl/de_ALL/drive/ platform. Google Drive is a file hosting service (also referred to as cloud storage) operated by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

For information about Google’s existing Privacy Shield certification and other data relating to Google’s processing of data when using Google services, please see section “6) Information about Google’s services” of this privacy policy.

We have concluded a commissioned data processing agreement with Google (Art. 28 GDPR).

The legal basis for the processing of personal data is Art. 6(1) point b) GDPR.

Insofar as we process the image file, we process it as a contractor for the data controller. This is the photographer who uses our services. The data controller can provide you with information about the legal basis for said processing. We have concluded a commissioned data processing agreement with the data controller (Art. 28 GDPR).

With regard to the ordering process and the associated data processing, please see the explanations and information in section “16) Ordering and processing”.

The data recipient is Google. We have concluded a commissioned data processing agreement with Google.

The provision of personal data is required in order to perform the contractual services and thus also to conclude the contract. Failure to provide the data would result in the contract not being concluded.

15) Payment transactions

  1. a) Payment with PayPal

We give you the option of paying with PayPal. After completing your order, you will be directed to the website of the payment provider PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (“PayPal”). When you pay with PayPal, we transmit information (including personal data) to PayPal which then processes it for the purpose of payment processing. When you pay with PayPal, we transmit the following data in particular to PayPal:

  • price
  • currency
  • unique user ID (client token)

PayPal places cookies on your device when you visit the PayPal website or use PayPal services. PayPal uses these cookies to identify you as a customer, personalize PayPal services, content and advertising, evaluate the effectiveness of advertising, and ensure your account’s security. You can prevent the placement of cookies by selecting the appropriate settings on your browser, provided that the cookies are not required to prevent fraud or ensure the security of the webpages managed by PayPal. However, please note that if you do so you may not be able to use all the functions of PayPal.

PayPal’s current privacy policy is available at https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

We receive the following data from PayPal as part of the transaction:

  • transaction ID
  • credit card number (only the last four digits)
  • total order amount
  • currency
  • date and time of transaction
  • status confirmation (transaction successful or failed)

The purpose of processing these data is to carry out the payment process and execute the contract.

The legal basis for processing the data as part of the ordering process and the execution of the contract is Art. 6(1) point b) GDPR. We store the data only for as long as necessary to process and complete your order and comply with the legal storage periods.

The provision of the aforementioned personal data is required for concluding a contract. Failure to provide the data would result in the contract not being concluded.

  1. b) Braintree

You also have the option of paying with Braintree. Braintree is a division of PayPal that specializes in mobile and web payment systems for e-commerce companies.If you pay with Braintree, we transmit information (including personal data) to Braintree which then processes it for the purpose of payment processing. When you pay with Braintree, we transmit the following data in particular to Braintree:

  • price
  • currency
  • unique user ID (client token)

PayPal places cookies on your device when you visit the Braintree website or use PayPal services. PayPal uses these cookies to identify you as a customer, personalize PayPal services, content and advertising, evaluate the effectiveness of advertising, and ensure your account’s security. You can prevent the placement of cookies by selecting the appropriate settings on your browser, provided that the cookies are not required to prevent fraud or ensure the security of the webpages managed by PayPal. However, please note that if you do so you may not be able to use all the functions of Braintree or PayPal.

PayPal’s current privacy policy is available at https://www.braintreepayments.com/en-de/legal/braintree-privacy-policyand https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

We receive the following data from Braintree or PayPal as part of the transaction:

  • transaction ID
  • credit card number (only the last four digits)
  • total order amount
  • currency
  • date and time of transaction
  • status confirmation (transaction successful or failed)

The purpose of processing these data is to carry out the payment process and execute the contract.

The legal basis for processing the data as part of the ordering process and the execution of the contract is Art. 6(1) point b) GDPR. We store the data only for as long as necessary to process and complete your order and comply with the legal storage periods.

The provision of the aforementioned personal data is required for concluding a contract. Failure to provide the data would result in the contract not being concluded.

  1. c) Payment – prepayment

We offer you the option of completing your order via the “prepayment” payment option. We send you our payment details so that you can transfer the amount to our account.  This means that we receive the data that your bank transfers to our bank as part of the transfer. This includes your payment data and your first and last name in particular. We will process those data as part of further contract execution.

The purpose of us processing these data is to carry out the payment process and execute the contract.

The legal basis for the processing is Art. 6(1) point b) GDPR. We store the data only for as long as necessary to process and complete your order and comply with the legal storage periods.

The provision of the aforementioned personal data is required for concluding a contract. Failure to provide the data would result in the contract not being concluded.

16) Contact

You can contact us by mail, telephone, fax or e-mail.

If you contact us by mail, we may process your address data (e.g. last name, first name, street, town, postal code), date and time of receipt as well as any information in the text of your letter.

If you contact us by telephone, we may process your telephone number and, if necessary, your name, your e-mail address, the time of your call and details of your inquiry during the conversation.

If you contact us by e-mail, we process in particular your e-mail address, the time the e-mail is sent and the information contained in the message text (including attachments if applicable).

The purpose of processing these data is to process the contact request and to enable us to contact the requesting party in order to respond to the request.

The legal basis for processing of personal data described here is Art. 6(1) point f) GDPR. It is in our legitimate interest to offer you the opportunity to contact us at any time so that we can answer your questions.

The personal data are deleted as soon as they are no longer required for the purpose of collection and are thus subject to our “Data Life Cycle Concept” for the deletion of personal data.

Right to object

You have a right to object. You can send or inform us of your objection at any time (e.g. by e-mail to [email protected]).

The provision of personal data is not required by law nor by contract, nor for conclusion of a contract. You are also not obliged to provide the personal data. Failure to do so may, however, result in your not being able to contact us or our not being able to contact you.

17) Social networks & external links

In addition to this website, we are also present on various social media and you can access our pages there by clicking the relevant buttons on our website. Personal data may be transmitted to the provider of the social network when you visit us there.

Please note that user data may also be transferred to a server in a third country in this case and thus be processed outside of the European Union. US providers certified under the Privacy Shield undertake to comply with EU data protection standards. Further information about this is available at https://www.privacyshield.gov/Program-Overview.

In addition to storing the data you actually enter when visiting this social medium, the social network provider may also process further information.

The social network provider may also process the most important information about the computer system from which you are visiting, such as your IP address, the type of processor you are using, and the browser version and plug-ins you are using.

If you are logged on with your personal user account for the respective network while visiting such a webpage, the network can assign the visit to this account.

Information about the purpose and scope of this data collection by the respective social network, further processing of your data there and your rights in this regard can be found in the relevant provisions of the data controller, e.g.:

Please also note that our website contains further links to third-party websites and that we have no influence over the data processing of those third-party websites.

18) Data security

We secure our website and other systems by taking technical and organizational measures against loss, destruction, access, alteration or distribution of your data by unauthorized persons. Although we carry out regular checks in this regard, it is not possible for us to ensure complete protection against all hazards.

19) Changes to privacy policy

Changes in the law or in our internal processes may make it necessary to adapt this privacy policy accordingly.

In the event of such a change, we will notify you of this under the heading “Privacy policy” heading 4 weeks before making the planned change.

20) Revocation of consent

You have the right to revoke the consent you have given at any time with effect for the future, without affecting the lawfulness of the processing that took place on the basis of the consent up to the time of revocation.

21) Data subject rights

You have the following rights:

  • right to information (Art. 15 GDPR)
  • right to rectification (Art. 16 GDPR)
  • right to object (Art. 21 GDPR)
  • right to erasure (Art. 17 GDPR)
  • right to restriction of processing (Art. 18f. GDPR)
  • right to data portability (Art. 20 GDPR)

Please feel free to contact us about any inquiries of this kind you may have. Please note that we must ensure that it is actually the data subject concerned who is making such an inquiry.

You have the right to lodge a complaint with a data protection supervisory authority, without prejudice to any other administrative or judicial remedy.

Our website does not use any automated decision making. 

Updated: December 12th, 2019