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Last update: July 25, 2020
This Privacy Policy clarifies the nature, scope and purpose of the processing of personal data (hereinafter referred to as “Data”) within our online offering and the related websites, features and content, as well as external online presence, e.g. our Social Media Profile (collectively referred to as the “Online Offering”). With regard to the terminology used, e.g. “Processing” or “Controller”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
Controller
Sarwary Holding B.V.
Stollenbergweg 76
6572 AD, Berg en Dal
The Netherlands
E-mail: [email protected]
Chamber of Commerce number: 74464760
VAT identification number: NL859912073B01
Here you can find our general terms and conditions: https://adjmal.com/terms-and-conditions/
Data security contact email: [email protected]
Types of processed data:
– Inventory data (e.g., names, addresses).
– Contact information (e.g., e-mail, phone numbers).
– Content data (e.g., text input, photos, videos).
– Usage data (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. These are either customers that use our online platform to conduct research or participants of the online studies (hereinafter we refer to the affected persons as “users”).
Purpose of processing
– Provision of the online service, its functions and contents
– Answering contact requests and communicating with users
– Safety measures
– Market Research/Marketing
Used terms
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “affected person”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by assignment to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more special features that express the physical, physiological, genetic, psychological, economic, cultural or social identity of that 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 broadly defined and includes virtually every handling of data.
“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific affected person without additional information being provided, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data not assigned to an identified or identifiable natural person.
“Profiling” means any kind of automated processing of personal data which involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to job performance, economic situation, health, personal preferences, interests, reliability, behavior, whereabouts or relocation in order to analyze or predict these aspects of that natural person.
“Controller” means the natural or legal person, public authority, body or body that decides, alone or in concert with others, on the purposes and means of processing personal data.
“Processor” means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
Legal basis
In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consents is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing for the performance of our services and performance of contractual measures as well as for answering inquiries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing to fulfil our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR. In the event that the vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) GDPR serves as the legal basis.
Security
We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk, taking into account the state of the art, implementation costs and the nature, scope, circumstances and purposes of processing as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons, in accordance with Art. 32 GDPR.
Such measures shall in particular include ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, transmission, security of availability and its separation. Furthermore, we have established procedures to ensure the exercise of rights of data subjects, deletion of data and reaction to endangerment of data. Furthermore, we already consider the protection of personal data during the development or selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly pre-settings (Art. 25 GDPR).
Cooperation with contract 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 (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 fulfil the contract), you have consented to a legal obligation 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 “data processing contract”, this is done on the basis of Art. 28 GDPR.
Transfer to third-party countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this only takes place if it occurs for the fulfilment of our (pre)contractual obligations, 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 leave the data in a third country only if the special requirements of Art. 44 ff. Process GDPR. This means, for example, processing is carried out on the basis of special guarantees, such as the officially recognised determination of a data protection level corresponding to the EU (e.g. for the USA by the “Privacy Shield”) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).
Rights of affected persons
You have the right to request confirmation as to whether the data concerned are being processed and to request information about these data as well as further information and a copy of the data in accordance with Art. 15 GDPR.
You have according to Art. 16 GDPR 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 responsible entities.
In accordance with Art. 77 GDPR, you also have the right to file a complaint with the governing authority.
Right of withdrawal
You have the right to revoke your consent, provided according to Art. 7 para. 3 GDPR, at any time with future effect.
Right of objection
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 of objection in direct advertising
“Cookies” are small files that are stored on the user’s computer. Different data can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his or her visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the content of a shopping basket in an online shop or a login status can be stored. Cookies are referred to as “permanent” or “persistent” and remain stored even after the browser is closed. For example, the login status can be saved when users visit it after several days. Likewise, the interests of users used for range measurement or marketing purposes may be stored in such a cookie. “Third-party cookies” are cookies that are offered by providers other than the person responsible for operating the online offer (otherwise, if they are only its cookies, they are referred to as “first-party cookies”).
We may use temporary and permanent cookies and clarify this within the framework of our data protection declaration (privacy policy).
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored 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 many of the services, especially in the case of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that in this case not all functions of this online offer can be used.
Deletion of data
The data processed by us will be deleted or their processing restricted in accordance with Articles 17 and 18 GDPR. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory storage obligations. If the data are not deleted because they are necessary for other and legally permissible purposes, their processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax reasons.
In accordance with the Dutch tax law, we are required to keep data to fulfil our tax obligations for 7 years and 10 years regarding our electronic services.
Business related processing
Additionally, we process
– contract data (e.g., subject matter of the contract, duration, customer category) and
– payment data (e.g., bank details, payment history) of our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
Order processing on our online platform and the customer/user account
We process the data of our customers in the context of the order processes in our online platform to enable them to select and order the selected products and services, as well as their payment and delivery, respectively execution.
The processed data includes inventory data, communication data, contract data, payment data and the persons affected by the processing include our customers, interested parties and other business partners. The processing takes place for the purpose of providing contractual services in the context of operating an online platform, billing, delivery and customer services. We use session cookies for storing the contents of the shopping cart and permanent cookies for storing the login status.
Processing is carried out on the basis of Art. 6 Para. 1 lit. b (execution of order processes) and c (legally required archiving) GDPR. The information marked as necessary is required to establish and fulfil the contract. We disclose the data to third parties only within the framework of delivery, payment or within the framework of legal permits and obligations to legal advisors and authorities. The data will only be processed in third countries if this is necessary for the fulfilment of the contract (e.g. at the customer’s request upon delivery or payment).
Users have to create a user account, in particular to view their orders. During the registration process, the required information will be communicated to the users. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to its storage is necessary for commercial or tax reasons according to Art. 6 Para. 1 lit. c GDPR. Data in the customer account remain up to its deletion with subsequent archiving in the case of a legal obligation. It is up to the users to save their data before the end of the contract if they have given notice of termination.
When registering, re-registering and using our online services, we store the IP address and the time of the respective user action. The data is stored on the basis of our legitimate interests as well as the user’s protection against misuse and other unauthorized use. A passing on of this data to third parties does not take place in principle, unless it is necessary for the pursuit of our claims or there is a legal obligation according to Art. 6 Abs. 1 lit. c GDPR.
The deletion takes place after the expiry of statutory warranty and comparable obligations, the necessity of data storage is reviewed every three years; in the case of statutory archiving obligations, the deletion takes place after their expiry (end of commercial law (10 years) and tax law (10 years) storage obligation).
Services
We process our customers’ data as part of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development / consulting or maintenance, implementation of campaigns and processes / handling, server administration, data analysis / consulting services and training services.
We process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of the contract, term), payment data (e.g., bank details, payment history), and usage and metadata (e.g. as part of the evaluation and performance measurement of marketing measures). We do not process special categories of personal data unless these are part of commissioned processing. This includes our customers, prospects, their customers, users, website visitors or employees, as well as third parties. The purpose of the processing is to provide contractual services, billing and our customer service. The legal basis for processing results from Art. 6 para. 1 lit. b GDPR (contractual services), Art. 6 para. 1 lit. f GDPR (analysis, statistics, optimisation, safety measures). We process data which are necessary to justify and fulfil the contractual services and point out the necessity of their disclosure. Disclosure to external parties only takes place if it is necessary within the framework of an order. When processing the data provided to us within the scope of an order, we act in accordance with the instructions of the client and the legal requirements for order processing pursuant to Art. 28 GDPR and process the data for no other purposes than those stipulated in the order.
We delete the data after the expiry of statutory warranty and comparable obligations. The necessity of storing the data is checked every three years; in the case of statutory archiving obligations, the data is deleted after their expiry. In the case of data disclosed to us within the scope of an order by the customer, we delete the data in accordance with the specifications of the order, generally after the end of the order.
Contractual Services
We process the data of our contractual partners and interested parties as well as other clients, customers, clients, clients or contractual partners (uniformly referred to as “contractual partners”) in accordance with Art. 6 para. 1 lit. b. GDPR to provide our contractual or pre-contractual services to them. The data processed here, the type, scope and purpose and the necessity of their processing, are determined by the underlying contractual relationship.
The processed data includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g. e-mail addresses and telephone numbers) as well as contract data (e.g., services used, contract contents, contractual communication, names of contact persons) and payment data (e.g., bank details, payment history).
We do not process special categories of personal data, unless these are part of a commissioned or contractual processing.
We process data which are necessary to justify and fulfil the contractual services and point out the necessity of their disclosure, unless this is evident for the contractual partners. Disclosure to external persons or companies is only made if it is required within the framework of a contract. When processing the data provided to us within the scope of an order, we act in accordance with the instructions of the customer and the legal requirements.
When using our online services, we may store the IP address and the time of the respective user action. This data is stored on the basis of our legitimate interests as well as the users’ interests in the protection against misuse and other unauthorized use. As a matter of principle, this data will not be passed on to third parties, unless it is necessary to pursue our claims pursuant to Art. 6 para. 1 lit. f. GDPR is required or there is a legal obligation in accordance with Art. 6 para. 1 lit. c. GDPR.
The data will be deleted if the data is no longer required for the fulfilment of contractual or statutory duties of care or for the handling of any warranty or comparable obligations, whereby the necessity of storing the data is checked every three years; in all other respects, the statutory storage obligations apply.
External payment service providers
We use external payment service providers through whose platforms the users and we can carry out payment transactions (e.g., each with a link to the data protection declaration)
Paypal (https://www.paypal.com/us/webapps/mpp/ua/privacy-full),
Mollie (https://www.mollie.com/en/privacy)
Skrill (https://www.skrill.com/en/footer/privacypolicy/),
Visa (https://www.visaeurope.com/privacy/),
Mastercard (https://www.mastercard.us/en-us/about-mastercard/what-we-do/privacy.html),
American Express (https://www.americanexpress.com/us/content/legal-disclosures/online-privacy-statement.html)
As part of the fulfilment of contracts, we suspend the payment service providers on the basis of Art. 6 para. 1 lit. b. GDPR. Furthermore, we employ external payment service providers on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. GDPR to provide our users with effective and secure payment options.
The data processed by the payment service providers includes inventory data such as name and address, bank data such as account numbers or credit card numbers, passwords, TANs and checksums as well as contract, totals and recipient information. This information is required to execute the transactions. However, the data entered will only be processed and stored by the payment service providers. This means that we do not receive any account or credit card related information, but only information with confirmation or negative information about the payment. The data may be transferred by the payment service providers to credit agencies. The purpose of this transmission is to verify identity and creditworthiness. For this we refer to the terms and conditions and data protection information of the payment service providers.
For payment transactions, the terms and conditions and the data protection information of the respective payment service providers, which can be accessed within the respective websites or transaction applications, apply. We refer to these also for the purpose of further information and assertion of rights of revocation, information and other interested parties.
Administration, accounting, office organization, contact information management
We process data within the framework of administrative tasks as well as the organisation of our company, financial accounting and compliance with legal obligations, e.g. archiving. We process the same data that we process in the course of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, prospects, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, thus tasks which serve the maintenance of our business activities, perception of our tasks and provision of our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the information provided in these processing activities.
We disclose or transmit data to the tax authorities, consultants, such as tax consultants or auditors, as well as similar service providers.
Furthermore, we store information on suppliers, event organisers and other business partners on the basis of our business interests, e.g. for the purpose of making contact at a later date. We store this data, which is mainly company-related, permanently.
Business analyses and market research
In order to operate our business economically, to be able to recognize market tendencies, wishes of the contracting parties and users, we analyze the data available to us to business processes, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, and metadata on the basis of Art. 6 para. 1 lit. f. GDPR, whereby the persons concerned include contractual partners, interested parties, customers, visitors and users of our online offer.
The analyses are carried out for the purpose of economic evaluations, marketing and market research. We can take into account the profiles of registered users with information, e.g. on the services they have used. The analyses serve us to increase the user-friendliness, the optimization of our offer and the economic efficiency. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with aggregated values.
If these analyses or profiles are personal, they will be deleted or made anonymous upon termination of the user, otherwise after two years from the conclusion of the contract. For the rest, macroeconomic analyses and general trend determinations are prepared anonymously wherever possible.
Data protection information in the job application process
We process the applicant data only for the purpose and in the context of the application procedure in accordance with the legal requirements. The processing of the applicant data takes place in order to fulfil our (pre)contractual obligations in the context of the application procedure within the meaning of Art. 6 para. 1 lit. b. GDPR Art. 6 para. 1 lit. f. GDPR if data processing becomes necessary for us, e.g. within the framework of legal procedures.
The application procedure requires that applicants provide us with personal data. If we offer an online form, the necessary data for application will be explicitly stated or otherwise result from the job descriptions and generally include personal data, postal and contact addresses and the documents belonging to the application, such as cover letter, curriculum vitae and certificates. In addition, applicants may voluntarily provide us with additional information.
By submitting the application to us, applicants agree to the processing of their data for the purposes of the application procedure in accordance with the type and scope set out in this data protection declaration.
If special categories of personal data within the meaning of Art. 9 para. 1 GDPR are voluntarily communicated within the scope of the application procedure, they are additionally processed in accordance with Art. 9 para. 2 letter b GDPR (e.g. health data, e.g. severely disabled status or ethnic origin). If special categories of personal data within the meaning of Art. 9 para. 1 GDPR are requested from applicants during the application procedure, they are additionally processed in accordance with Art. 9 para. 2 lit. a GDPR (e.g. health data, if these are required for the exercise of the profession).
If made available, applicants can send us their applications via an online form on our website. The data is encrypted and transmitted to us according to the state of the art.
Applicants can also send us their applications by e-mail. Please note, however, that e-mails are generally not sent in encrypted form and that the applicants themselves must ensure that they are encrypted. We cannot therefore accept any responsibility for the transmission of the application between the sender and receipt on our server and therefore recommend that you use an online form or the postal dispatch. Instead of using the online application form and e-mail, applicants can still send us their application by post.
If the application is successful, the data provided by the applicants can be further processed by us for the purpose of employment. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which the applicants are entitled to do at any time.
The deletion will take place after a period of six months, subject to a justified revocation by the applicant, so that we can answer any follow-up questions to the application and meet our obligations under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with tax regulations.
Talent pool
As part of the application, we offer applicants the opportunity to be included in our “talent pool” for a period of two years on the basis of consent within the meaning of Art. 6 (1) (b) and Art. 7 GDPR.
The application documents in the talent pool will only be processed in the context of future job advertisements and the search for employees and will be destroyed at the latest on expiry of the deadline. Applicants are informed that their consent to inclusion in the talent pool is voluntary, has no influence on the current application procedure and they can revoke this consent at any time for the future and declare their objection within the meaning of Art. 21 GDPR.
Registration
Users can create a user account. Within the scope of registration, the required mandatory data are communicated to the users and processed on the basis of Art. 6 para. 1 letter b GDPR for the purpose of providing the user account. The processed data includes in particular the login information (name, password and an e-mail address). The data entered during registration will be used for the purpose of using the user account and its purpose.
Users may be notified by e-mail of information relevant to their user account, such as technical changes. If users have cancelled their user account, their data will be deleted with regard to the user account, subject to a statutory retention obligation. It is up to the users to save their data before the end of the contract if they have given notice of termination. We are entitled to irretrievably delete all user data stored during the term of the contract.
As part of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The data is stored on the basis of our legitimate interests as well as the user’s protection against misuse and other unauthorized use. A passing on of this data to third parties does not take place in principle, unless it is necessary to pursue our claims or there is a legal obligation in accordance with Art. 6 para. 1 lit. c. GDPR. The IP addresses are anonymized or deleted after 7 days at the latest.
DISQUS – Comment Feature
On the basis of our legitimate interests in an efficient, secure and user-friendly comment management pursuant to Art. 6 para. 1 letter f. GDPR we make use of the commentary service DISQUS, offered by DISQUS, Inc. 301 Howard St, Floor 3 San Francisco, California- 94105, USA. DISQUS is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law: https://www.privacyshield.gov/participant?id=a2zt0000000TRkEAAW&status=Active.
To use the DISQUS comment feature, users can log in via their own DISQUS user account or an existing social media account (e.g. OpenID, Facebook, Twitter or Google). DISQUS obtains the user’s login data from the platforms. It is also possible to use the DISQUS comment function as a guest, without creating or using user accounts at DISQUS or one of the specified social media providers.
We only embed DISQUS with its functions into our website, whereby we can influence the comments of the users. However, the users enter into a direct contractual relationship with DISQUS, in the context of which DISQUS processes the comments of the users and is a contact for any deletion of the user’s data. We refer to the DISQUS data protection declaration: https://help.disqus.com/terms-and-policies/disqus-privacy-policy and also point out to users that they can assume that DISQUS stores not only the comment content but also their IP address and the time of the comment and can store cookies on the users’ computers and use them to display advertising. However, users may object to the processing of their data for the purpose of displaying advertisements: https://disqus.com/data-sharing-settings.
Comments
If users leave comments or other contributions, their IP addresses may be used on the basis of our legitimate interests within the meaning of Art. 6 (1) (f). GDPR for 7 days. This takes place for our safety, if someone leaves illegal contents in comments and contributions (insults, forbidden political propaganda, etc.). In this case, we can be prosecuted ourselves for the comment or contribution and are therefore interested in the identity of the author.
Furthermore, we reserve the right, on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. GDPR to process user information for spam detection.
On the same legal basis, we reserve the right, in the case of surveys, to store the IP addresses of users for their duration and to use cookies to avoid multiple submissions.
The data provided in the context of comments and contributions will be permanently stored by us until the user objects.
Comment subscriptions
Users may subscribe to the follow-up comments with their consent in accordance with Art. 6 para. 1 lit. a GDPR. Users will receive a confirmation email to verify that they are the owner of the email address they entered. Users can unsubscribe from ongoing comment subscriptions at any time. The confirmation email will contain information on the cancellation options. For the purpose of providing proof of user consent, we store the time of registration together with the IP address of the users and delete this information when users unsubscribe from the subscription.
You can cancel the receipt of our subscription at any time, i.e. revoke your consent. We may store the e-mail addresses we have unsubscribed for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of these data is limited to the purpose of a possible defence against claims. An individual application for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.
Akismet Anti-Spam
Our online offer uses the service “Akismet” offered by Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA. The use is based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f) GDPR. With the help of this service, comments of real people are distinguished from spam comments. All comment information is sent to a server in the USA, where it is analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data will be stored after this time. This information includes the name entered, the e-mail address, the IP address, the comment content, the referrer, information on the browser used, the computer system and the time of entry.
Further information on Akismet’s collection and use of the data can be found in Automattic’s privacy policy: https://automattic.com/privacy/.
Users are welcome to use pseudonyms or refrain from entering their name or email address. You can completely prevent the transfer of data by not using our comment system. That would be a pity, but unfortunately we see no other alternatives that work just as effectively.
Access of profile pictures at Gravatar
We use the service Gravatar of Automattic Inc. 60 29th Street #343, San Francisco, CA 94110, USA, within our online offer and especially in our blog.
Gravatar is a service where users can log in and store profile pictures and their e-mail addresses. If users leave contributions or comments with the respective e-mail address on other online presences (above all in blogs), their profile pictures can be displayed next to the contributions or comments. For this purpose, the e-mail address provided by the users is transmitted to Gravatar in encrypted form for the purpose of checking whether a profile has been saved for it. This is the sole purpose of the transmission of the e-mail address and it will not be used for other purposes, but will be deleted thereafter.
The use of Gravatar is based on our legitimate interests within the meaning of Art. 6 Para. 1 letter f) GDPR, as we offer the possibility of personalising their contributions with a profile picture with the help of Gravatar.
By displaying the images, Gravatar obtains the IP address of the users, as this is necessary for communication between a browser and an online service. Further information on the collection and use of data by Gravatar can be found in Automattic’s data protection information: https://automattic.com/privacy/.
If users do not want an image associated with their email address to appear in Gravatar’s comments, you should use a non-Gravatar email address for commenting. We would also like to point out that it is also possible to use an anonymous or no e-mail address if users do not wish their own e-mail address to be sent to Gravatar. Users can completely prevent the transfer of data by not using our comment system.
Access of Emojis and Smilies
Within our WordPress blog, graphical emojis (or smilies), i.e. small graphical files that express feelings, are used that are obtained from external servers. The providers of the servers collect the IP addresses of the users. This is necessary so that the emoji files can be transmitted to the users’ browsers. The Emoji service is offered by Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA. Privacy policy of Automattic: https://automattic.com/privacy/. The server domains used are s.w.org and twemoji.maxcdn.com, whereby to our knowledge these are so-called content-delivery networks, i.e. servers which serve only a fast and secure transmission of the files and the personal data of the users are deleted after the transmission.
Emojis are used on the basis of our legitimate interests, i.e. interest in an attractive design of our online offer in accordance with Art. 6 para. 1 lit. f. GDPR.
Contact
When contacting us (e.g. via contact form, e-mail, telephone or social media), the user’s details for processing the contact enquiry and its processing pursuant to Art. 6 para. 1 letter b. (in the context of contractual/pre-contractual relationships), Art. 6 para. 1 lit. f. (other requests) GDPR. User information can be stored in a customer relationship management system (“CRM system”) or comparable request organization.
We delete the requests if they are no longer necessary. We review this requirement every two years; the statutory archiving obligations also apply.
CRM-System HubSpot
We use the CRM system of hubspot.com HubSpot Inc, 25 First Street, 2nd Floor, Cambridge, MA 02141, USA, in order to process user inquiries faster and more efficiently (legitimate interest according to art. 6 par. 1 lit. f. GDPR).
HubSpot is certified under the Privacy Shield Agreement, providing an additional guarantee to comply with European data protection law if data is processed in the USA. (https://www.privacyshield.gov/participant?id=a2zt0000000TN8pAAG&status=Active).
HubSpot uses the user data only for technical processing of the requests and does not pass them on to third parties. To use HubSpot, at least a correct e-mail address is required. Pseudonymous use is possible. During the processing of service requests, it may be necessary to collect further data (name, address).
If users do not agree to the collection and storage of data in HubSpot’s external system, we offer them alternative contact options for submitting service requests by e-mail, telephone, fax or post.
Users can find further information in HubSpot’s data protection declaration: https://legal.hubspot.com/privacy-policy.
Newsletter
With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter you agree to the receipt and the described procedures.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter “newsletters”) only with the consent of the recipients or a legal permission. If the contents of a newsletter are specifically described within the scope of a registration, they are decisive for the consent of the users. In addition, our newsletters contain information about our services and us.
Double opt-in and logging: Subscription to our newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no one can log in with other e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes the storage of the login and confirmation time, as well as the IP address. The changes to your data stored with the shipping service provider are also logged.
Credentials: To subscribe to the newsletter, simply enter your name and e-mail address. We ask you to enter your name in the newsletter in order to address you personally.
The sending of the newsletter and the performance measurement associated with it are carried out on the basis of the recipients’ consent pursuant to Art. 6 para. 1 lit. a, Art. 7 GDPR or, if consent is not required, on the basis of our legitimate interests in direct marketing pursuant to Art. 6 para. 1 lt. f. GDPR.
The registration procedure is recorded on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR. We are interested in the use of a user-friendly and secure newsletter system that serves both our business interests and the expectations of users and also allows us to provide proof of consent.
Cancellation/Revocation – You can cancel the subscription to our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store the e-mail addresses we have unsubscribed for up to three years on the basis of our legitimate interests before we delete them in order to be able to prove a previously given consent. The processing of these data is limited to the purpose of a possible defence against claims. An individual application for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.
Newsletter – Provider
The newsletter is sent through the email marketing service Mailerlite Paupio g. 28, Vilnius 11341, Lithuania. The data protection regulations of the service provider can be viewed here: https://www.mailerlite.com/privacy-policy. The service provider will be used on the basis of our legitimate interests in accordance with Art. 6 para. 1 lit. f. GDPR and an order processing contract pursuant to Art. 28 para. 3 sentence 1 GDPR.
The service provider can use the recipient’s data in pseudonymous form, i.e. without assignment to a user, to optimize or improve its own services, e.g. to technically optimize the dispatch and presentation of the newsletter or for statistical purposes. However, the shipping service does not use the data of our newsletter recipients to write them down itself or to pass the data on to third parties.
Newsletter – Analytics
The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file which is downloaded from our server when the newsletter is opened or, if we use a shipping service provider, from whose server. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval are initially collected.
This information is used to technically improve the services based on the technical data or the target groups and their reading behaviour based on their retrieval locations (which can be determined using the IP address) or access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our endeavour, nor, if used, that of the shipping service provider, to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our contents to them or to send different contents according to the interests of our users.
A separate revocation of the success measurement is unfortunately not possible, in this case the entire newsletter subscription must be cancelled.
Hosting und E-Mail-Service
The hosting services we use serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail delivery, security services and technical maintenance services that we use for the purpose of operating this online offer.
We or our hosting provider process inventory data, contact data, content data, contract data, usage data, and meta- and communication data of customers, interested parties, and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer according to Art. 6 Para. 1 lit. f GDPR in conjunction with. Art. 28 GDPR (conclusion of order processing contract).
Content-Delivery-Network Cloudflare
We use a Content Delivery Network (CDN), offered by Cloudflare, Inc. 101 Townsend St, San Francisco, CA 94107, USA. Cloudflare is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law. (https://www.privacyshield.gov/participant?id=a2zt0000000GnZKAA0&status=Active).
A CDN is a service with the help of which contents of our online offer, in particular large media files, such as graphics or scripts, are delivered faster with the help of regionally distributed servers connected via the Internet. User data is processed solely for the aforementioned purposes and to maintain the security and functionality of the CDN.
The use is based on our legitimate interests, i.e. interest in a secure and efficient provision, analysis and optimisation of our online offer in accordance with Art. 6 para. 1 lit. f. GDPR.
For more information, see Cloudflare’s privacy policy: https://www.cloudflare.com/security-policy.
Google Tag Manager
Google Tag Manager is a solution with which we can manage so-called website tags via an interface (and thus integrate Google Analytics and other Google marketing services into our online offering, for example). The Tag Manager itself (which implements the tags) does not process any personal data of the users. With regard to the processing of users’ personal data, reference is made to the following information on the Google services. Usage guidelines: https://www.google.com/analytics/tag-manager/use-policy/.
Google Analytics
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) we make use of Google Analytics, a web analysis service of Google LLC (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by users is generally transferred to a Google server in the USA and stored there.
Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (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 associated with the use of this online offer and the use of the Internet. Pseudonymous user profiles can be created from the processed data.
We use Google Analytics only with IP anonymization enabled. This means that Google will reduce the IP address of users within Member States of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user’s browser is not merged with other Google data. Users may refuse the use of cookies by selecting the appropriate settings on their browser software; users may also prevent Google from collecting data generated by the cookie and relating to their use of the website and from processing this data by downloading and installing the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
Further information on data use by Google, setting and objection options, can be found in Google’s data protection declaration. (https://policies.google.com/technologies/ads) as well as in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
Users’ personal data will be deleted or anonymized after 14 months.
Google Universal Analytics
We use Google Analytics in the design as „Universal-Analytics“. „Universal Analytics“ refers to a process by Google Analytics in which the user analysis is based on a pseudonymous user ID and thus a pseudonymous profile of the user is created with information from the use of various devices (so called „Cross-Device-Tracking“).
Target group assessment with Google Analytics
We use Google Analytics to display the ads placed by Google and its partners within advertising services only to users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products that are determined by the web pages visited) that we transmit to Google (so-called “remarketing” or “Google Analytics Audiences”). With the help of remarketing audiences we would also like to ensure that our ads correspond to the potential interest of the users.
Google AdSense with personalized Ads
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) we make use of the AdSense services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).
Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
We use the AdSense service, which is used to display ads on our website and pay us for their insertion or other use. For these purposes, usage data such as the click on an advertisement and the IP address of the user are processed, whereby the IP address is shortened by the last two digits. Therefore, the processing of the user’s data is pseudonymised.
We use AdSense with personalized ads. Google uses the websites visited by users or the apps used and the user profiles created in this way to draw conclusions about their interests. Advertisers use this information to align their campaigns with these interests, which is beneficial for users and advertisers alike. For Google, ads are personalized when collected or known information determines or affects ad selection. These include past searches, activities, site visits, use of apps, demographic and location information, and more. Specifically, this includes demographic targeting, targeting on interest categories, remarketing, and targeting on customer match lists and target group lists uploaded to DoubleClick Bid Manager or Campaign Manager.
Further information on data use by Google, setting and objection options, can be found in Google’s data protection declaration (https://policies.google.com/technologies/ads) as well as in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
Google AdWords and Conversion-Analytics
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) we make use of the AdWords services of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (“Google”).
Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
We use the online marketing process Google “AdWords” to place ads in the Google Advertising Network (e.g., in search results, in videos, on websites, etc.) so that they are displayed to users who have a presumed interest in the ads. This allows us to display ads for and within our online offer more specifically in order to present users only ads that potentially correspond to their interests. For example, if a user is shown ads for products in which he is interested in other online offers, this is referred to as “remarketing”. For these purposes, when our and other websites on which the Google Advertising Network is active are accessed, Google directly executes a code from Google and (re)marketing tags (invisible graphics or code, also known as “web beacons”) are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies can also be used instead of cookies). In this file it is noted which websites the user visits, which contents he is interested in and which offers the user has clicked on, technical information on the browser and operating system, referring websites, visiting time and further information on the use of the online offer.
We also receive an individual “conversion cookie”. The information collected with the help of cookies is used by Google to generate conversion statistics for us. However, we only see the total number of anonymous users who clicked on our ad and were redirected to a page with a conversion tracking tag. However, we do not receive any information that personally identifies users.
User data is processed pseudonymously within the Google advertising network. This means that Google does not store and process, for example, the names or e-mail addresses of users, but processes the relevant data cookie-related within pseudonymous user profiles. This means from Google’s point of view, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly permitted Google to process the data without this pseudonymisation. The information collected about the users is transmitted to Google and stored on Google’s servers in the USA.
Further information on data use by Google, setting and objection options, can be found in Google’s data protection declaration (https://policies.google.com/technologies/ads) as well as in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).
Online presence in social media
We maintain online presences within social networks and platforms in order to communicate with active customers, interested parties and users and to inform them about our services. When accessing the respective networks and platforms, the terms and conditions and the data processing guidelines of their respective operators apply.
Unless otherwise stated in our privacy policy, we process the data of users who communicate with us within social networks and platforms, e.g. write articles on our websites or send us messages.
Integration of third-party services and content
Within our online offer, we make no representations or warranties of any kind based on our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) content or service offerings of third parties to incorporate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).
This always presupposes that the third party providers of this content perceive the IP address of the users, since without the IP address they could not send the content to their browser. The IP address is therefore required for the display of this content. We make every effort to use only those contents whose respective providers use the IP address only for the delivery of the contents. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. 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 technical information about the browser and operating system, referring websites, visiting time and other information about the use of our online offer, as well as be linked to such information from other sources.
Vimeo
We can integrate videos of the platform “Vimeo” of the provider Vimeo Inc, Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA. Privacy Policy: https://vimeo.com/privacy into our online offering. Please note that Vimeo may use Google Analytics and refer to the privacy policy (https://www.google.com/policies/privacy) and opt-out options for Google Analytics (http://tools.google.com/dlpage/gaoptout?hl=de) or Google’s settings for data use for marketing purposes (https://adssettings.google.com/.).
YouTube
We integrate the videos of the platform “YouTube” of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated into our online offering.
Google Fonts
We integrate the fonts (“Google Fonts”) of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated into our online offering.
Google Maps
We integrate the maps of the service “Google Maps” of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, into our online offering. The processed data may include in particular IP addresses and location data of the users, which, however, are not collected without their consent (as a rule within the framework of the settings of their mobile devices). The data can be processed in the USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.
Facebook Social Plugins
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. GDPR) Social Plugins (“Plugins”) of the social network facebook.com, which is operated by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”).
This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offer within Facebook. The list and the appearance of the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/.
Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law. (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
When a user calls up a function of this online offer that contains such a plugin, his device establishes a direct connection to the Facebook servers. The content of the plugin is transmitted by Facebook directly to the user’s device and integrated into the online offer. The processed data can be used to create user profiles. We therefore have no influence on the amount of data Facebook collects with the help of this plugin and therefore inform users according to our level of knowledge.
By integrating the plugins, Facebook receives information that a user has called up the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to his Facebook account. When users interact with the plugins, such as pressing the Like button or posting a comment, the information is sent directly from your device to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to obtain and store their IP address. According to Facebook, only an anonymized IP address is 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 relevant rights and setting options for the protection of the privacy of the users, can be found in the Facebook data protection information: 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 it to his membership data stored on Facebook, he must log out of Facebook before using our online offer and delete his cookies. Further settings and objections to 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 site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
Functions and contents of the Twitter service, offered by Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, can be integrated into our online offering. This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offer within Twitter.
If the users are members of the Twitter platform, Twitter can assign calling up the above content and functions to the users’ profiles there. Twitter is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law. (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active). Privacy policy: https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization.
Within our online offer, functions and contents of the Instagram service, offered by Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025, USA, can be integrated. This may include, for example, content such as images, videos or texts and buttons that users can use to share content from this online offering within Instagram. If the users are members of the Instagram platform, Instagram can assign the call of the above contents and functions to the profiles of the users there. Privacy Policy of Instagram: http://instagram.com/about/legal/privacy/.
Within our online offer, functions and contents of the LinkedIn service, offered by inkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland, can be integrated. This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online offer within LinkedIn. If the users are members of the LinkedIn platform, LinkedIn can assign the call of the above contents and functions to the profiles of the users there. Privacy Policy of LinkedIn: https://www.linkedin.com/legal/privacy-policy. LinkedIn is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law. (https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active). Privacy Policy: https://www.linkedin.com/legal/privacy-policy, Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
Children’s Privacy
We recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. The Site and the Services are not directed to children under the age of 13. We do not target this Site or Services to children under 13. We do not knowingly collect personally identifiable information from children under the age of 13. If you are under the age of 13, please do not participate in any study and do not provide us with any personally identifiable information.
Age of consent
By using our services, you represent that you are at least 18 years of age.
Disclosure
If you are a Participant in an online study, we will not provide your personally identifiable information to the Customer.
If an External Web Site (as defined below) directly collects personally identifiable information about you, your use of the External Web Sites is subject to the terms of use and privacy policies located on the linked to External Web Sites. We will also disclose your personally identifiable information (a) if we are required to do so by law, regulation or other government authority or otherwise in cooperation with an ongoing investigation of a governmental authority, (b) to enforce our Terms of Use or user agreements or to protect our rights or (c) to protect the safety of users of our Site and our Services.
We will not sell your personally identifiable information to any company or organization, but we may transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganization in which we participate or to a purchaser or acquirer of all or a portion of our assets to which this Site and our Services relates.
Privacy Policy Updates
We may need to update this Privacy Policy from time to time. We will post our updated Privacy Policy on our Site located at Adjmal.com and in the Services, along with a notice that the Privacy Policy has been changed so you are aware of what personally identifiable information we may collect and how we may use this information. We encourage you to review this Privacy Policy regularly for any changes. Your continued use of this Site, Services and/or continued provision of personally identifiable information to us will be subject to the terms of the then-current Privacy Policy.
Questions
If you:
Please contact us via email at [email protected]
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