Legal notice and privacy policy.
Introduction
With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes, and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online services").
The terms used are not gender-specific.
Last updated: October 26, 2020
Table of Contents
· Overview of processing activities
· Transmission and disclosure of personal data
· Data processing in third countries
· Provision of the online service and web hosting
· Contact
· Presences in social networks (social media)
· Changes and updates to the privacy policy
Responsible
Selim Say
Luxemburgerallee 16; 60385 Frankfurt am Main
Email address: info@selimsay.com
Phone: +49 (0)172-6613330
Overview of processing activities
The following overview summarizes the types of data processed and the purposes of their processing, and refers to the data subjects.
Types of data processed
• Inventory data (e.g., names, addresses).
• Content data (e.g., entries in online forms).
Contact details (e.g., email, phone numbers).
• Metadata/communication data (e.g., device information, IP addresses).
Usage data (e.g., websites visited, interest in content, access times).
Categories of affected persons
Communication partners.
• Users (e.g., website visitors, users of online services).
Purposes of processing
Conversion measurement (measuring the effectiveness of marketing measures).
Contact requests and communication.
Remarketing.
• Audience measurement (e.g., access statistics, recognition of returning visitors).
• Tracking (e.g., interest-/behavior-based profiling, use of cookies).
Server monitoring and error detection.
Provision of contractual services and customer service.
Relevant legal bases
Below, we explain the legal bases under the General Data Protection Regulation (GDPR) on which we process personal data. Please note that in addition to the GDPR, national data protection regulations may apply in your or our country of residence or establishment. If more specific legal bases apply in individual cases, we will inform you of these in the privacy policy.
• Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR) - The data subject has given consent to the processing of their personal data for one or more specific purposes.
• Contractual performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR) - The processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.
• Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
Security measures
In accordance with legal requirements, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the varying likelihood and severity of the threat to the rights and freedoms of natural persons, we implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk.
These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data, as well as access to, input of, transfer of, and ensuring the availability and separation of the data. Furthermore, we have established procedures that guarantee the exercise of data subject rights, the deletion of data, and responses to data breaches. We also consider the protection of personal data during the development and selection of hardware, software, and processes, in accordance with the principles of data protection by design and by default.
Transmission and disclosure of personal data
As part of our processing of personal data, it may be necessary to transfer or disclose data to other entities, companies, legally independent organizational units, or individuals. Recipients of this data may include, for example, payment institutions involved in payment transactions, IT service providers, or providers of services and content integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data to protect your data.
Data processing in third countries
If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or if the processing takes place in the context of using third-party services or disclosing or transferring data to other persons, bodies or companies, this will only be done in accordance with legal requirements.
Subject to explicit consent or where transfer is required by contract or law, we only process or have data processed in third countries with a recognized level of data protection, contractual obligations through so-called standard contractual clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Articles 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).
Use of cookies
Cookies are text files containing data from visited websites or domains, stored by a browser on the user's computer. A cookie primarily serves to store information about a user during or after their visit to an online service. Stored information can include, for example, language settings on a website, login status, items in a shopping cart, or the point at which a video was paused. We also include other technologies that perform the same functions as cookies in the term "cookies" (e.g., when user data is stored using pseudonymous online identifiers, also known as "user IDs").
The following cookie types and functions are distinguished:
• Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online service and closed their browser.
• Persistent cookies: Persistent cookies remain stored even after the browser is closed. This allows, for example, login status to be saved or preferred content to be displayed directly when the user revisits a website. Similarly, user interests, which are used for audience measurement or marketing purposes, can be stored in such a cookie.
• First-party cookies: First-party cookies are set by us.
• Third-party cookies : Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.
• Necessary (also: essential or absolutely required) cookies: Cookies may be absolutely necessary for the operation of a website (e.g. to save logins or other user input, or for security reasons).
• Statistics, marketing, and personalization cookies : Cookies are also typically used for audience measurement and when a user's interests or behavior (e.g., viewing specific content, using certain functions, etc.) on individual websites are stored in a user profile. Such profiles are used to show users content that matches their potential interests. This process is also known as "tracking," i.e., monitoring users' potential interests. If we use cookies or tracking technologies, we will inform you separately in our privacy policy or when obtaining your consent.
Information on the legal basis: The legal basis for processing your personal data using cookies depends on whether we ask for your consent. If so, and you consent to the use of cookies, the legal basis for processing your data is your explicit consent. Otherwise, data processed using cookies is processed based on our legitimate interests (e.g., in the efficient operation and improvement of our online services) or, if the use of cookies is necessary to fulfill our contractual obligations.
Storage period: Unless we provide you with explicit information on the storage period of persistent cookies (e.g., as part of a so-called cookie opt-in), please assume that the storage period can be up to two years.
General information on revocation and objection (opt-out): Depending on whether processing is based on consent or legal permission, you have the right to revoke any consent you have given or to object to the processing of your data by cookie technologies at any time (collectively referred to as "opt-out"). You can initially declare your objection via your browser settings, e.g., by disabling the use of cookies (although this may also restrict the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via a variety of services, especially in the case of tracking, through the websites https://optout.aboutads.info and https://www.youronlinechoices.com/ . You can also find further information on how to object in the details provided about the service providers and cookies used.
Processing of cookie data based on consent : Before we process or have processed any data in connection with the use of cookies, we ask users for their consent, which can be revoked at any time. Until consent is given, only cookies that are strictly necessary for the operation of our online service will be used.
• Types of data processed: Usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Affected persons: Users (e.g., website visitors, users of online services).
Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Provision of the online service and web hosting
To ensure the secure and efficient provision of our online services, we utilize the services of one or more web hosting providers, from whose servers (or servers they manage) the online services can be accessed. For these purposes, we may utilize infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance services.
The data processed in connection with providing our hosting services may include all information relating to users of our online services that is generated during use and communication. This regularly includes the IP address, which is necessary to deliver the content of online services to browsers, and all entries made within our online services or on websites.
Email sending and hosting : The web hosting services we use also include sending, receiving, and storing emails. For these purposes, the addresses of the recipients and senders, as well as other information relating to email transmission (e.g., the providers involved) and the content of the respective emails, are processed. The aforementioned data may also be processed for spam detection purposes. Please note that emails are generally not encrypted when sent over the internet. While emails are usually encrypted during transmission, they are not encrypted on the servers from which they are sent and received (unless end-to-end encryption is used). Therefore, we cannot assume any responsibility for the security of emails during transmission between the sender and their arrival on our server.
Collection of access data and log files : We (or our web hosting provider) collect data on every access to the server (so-called server log files). Server log files may include the address and name of the accessed web pages and files, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), and, as a rule, IP addresses and the requesting provider.
Server log files can be used for security purposes, e.g., to avoid overloading the servers (especially in the case of malicious attacks, so-called DDoS attacks), and to ensure server utilization and stability.
• Types of data processed: Content data (e.g., entries in online forms), usage data (e.g., websites visited, interest in content, access times), meta/communication data (e.g., device information, IP addresses).
• Affected persons: Users (e.g., website visitors, users of online services).
• Purposes of processing: Provision of contractual services and customer service, reach measurement (e.g. access statistics, recognition of returning visitors), tracking (e.g. interest-/behavior-related profiling, use of cookies), conversion measurement (measuring the effectiveness of marketing measures), server monitoring and error detection.
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Services and service providers used:
• 1&1 IONOS: Hosting platform for e-commerce/websites; Service provider: 1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany; Website: https://www.ionos.de ; Privacy policy: https://www.ionos.de/terms-gtc/terms-privacy .
Squarespace : Squarespace offers Software as a Service (SaaS) for creating and hosting websites. Service provider: Squarespace, Inc., 8 Clarkson St, New York, NY 10014, USA; Website: https://www.squarespace.com ; Privacy policy: https://www.squarespace.com/privacy .
Contact
When you contact us (e.g. via contact form, email, telephone or social media), the information provided by the requesting persons will be processed to the extent necessary to answer the contact requests and any requested measures.
Responding to contact requests within the framework of contractual or pre-contractual relationships is done to fulfill our contractual obligations or to answer (pre-)contractual inquiries, and otherwise on the basis of our legitimate interests in answering the inquiries.
• Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. entries in online forms).
• Affected persons: Communication partners.
Purposes of processing: Contact requests and communication.
• Legal basis: Contract performance and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b. GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Presences in social networks (social media)
We maintain online presences within social networks and process user data in this context in order to communicate with the users active there or to offer information about ourselves.
Please note that user data may be processed outside the European Union. This may pose risks for users, as it could, for example, make it more difficult to enforce their rights.
Furthermore, user data within social networks is generally processed for market research and advertising purposes. For example, user profiles can be created based on usage patterns and the resulting user interests. These user profiles can then be used to display advertisements both within and outside the networks that are presumably tailored to the users' interests. For these purposes, cookies are typically stored on users' computers, recording their usage patterns and interests. Additionally, user profiles can also store data independent of the devices used by the users (especially if the users are members of the respective platforms and are logged in).
For a detailed description of the respective processing methods and the options for objecting (opt-out), we refer to the privacy policies and information provided by the operators of the respective networks.
Regarding requests for information and the assertion of data subject rights, we would like to point out that these can be most effectively addressed directly with the service providers. Only the providers have access to user data and can take appropriate action and provide information directly. However, should you require assistance, you can contact us.
Facebook : We are jointly responsible with Facebook Ireland Ltd. for the collection (but not the further processing) of data from visitors to our Facebook page (so-called "Fan Page"). This data includes information about the types of content users view or interact with, or the actions they take (see "Things you and others do and provide" in the Facebook Data Policy: https://www.facebook.com/policy ), as well as information about the devices used by users (e.g., IP addresses, operating system, browser type, language settings, cookie data; see "Device Information" in the Facebook Data Policy: https://www.facebook.com/policy ). As explained in the Facebook Data Policy under "How do we use this information?", Facebook also collects and uses information to provide analytics services, so-called "Page Insights," to page administrators so they can gain insights into how people interact with their pages and the content associated with them. We have entered into a special agreement with Facebook ("Information about Page Insights," https://www.facebook.com/legal/terms/page_controller_addendum ) which, in particular, regulates the security measures Facebook must observe and in which Facebook has agreed to comply with data subject rights (i.e., users can, for example, submit requests for information or deletion directly to Facebook). The rights of users (in particular, the rights to information, deletion, objection, and lodging a complaint with the competent supervisory authority) are not restricted by the agreements with Facebook. Further information can be found in the "Information about Page Insights" ( https://www.facebook.com/legal/terms/information_about_page_insights_data ).
• Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. email, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
• Affected persons: Users (e.g., website visitors, users of online services).
• Purposes of processing: Contact requests and communication, tracking (e.g. interest-/behavior-related profiling, use of cookies), remarketing, reach measurement (e.g. access statistics, recognition of returning visitors).
• Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. GDPR).
Services and service providers used:
Instagram : Social network; Service provider: Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, Parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.instagram.com ; Privacy policy: https://instagram.com/about/legal/privacy .
• Facebook: Social network; Service provider: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, Parent company: Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA; Website: https://www.facebook.com ; Privacy policy: https://www.facebook.com/about/privacy ; Opt-out option: Ad settings: https://www.facebook.com/settings?tab=ads
• Pinterest: Social network; Service provider: Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA; Website: https://www.pinterest.com ; Privacy policy: https://about.pinterest.com/de/privacy-policy ; Opt-out option: https://about.pinterest.com/de/privacy-policy .
Deletion of data
The data we process will be deleted in accordance with legal requirements as soon as the consents allowing its processing are revoked or other permissions cease to apply (e.g., if the purpose of processing this data no longer exists or it is no longer necessary for that purpose).
Unless the data is deleted because it is required for other legally permissible purposes, its processing will be restricted to those purposes. This means the data will be blocked and not processed for any other purpose. This applies, for example, to data that must be retained for commercial or tax law reasons, or whose storage is necessary for the establishment, exercise, or defense of legal claims, or for the protection of the rights of another natural or legal person.
Further information regarding the deletion of personal data can also be found in the individual data protection notices of this privacy policy.
Changes and updates to the privacy policy
We ask that you regularly review the content of our privacy policy. We will update the privacy policy as soon as changes to our data processing activities make this necessary. We will inform you if any changes require action on your part (e.g., consent) or any other individual notification.
If we provide addresses and contact information for companies and organizations in this privacy policy, please note that the addresses may change over time and ask you to check the information before contacting them.
Rights of data subjects
As a data subject, you have various rights under the GDPR, which arise in particular from Articles 15 to 21 GDPR:
· Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) of the GDPR, including profiling based on those provisions. Where personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
• Right of withdrawal of consent: You have the right to withdraw any consent you have given at any time.
• Right of access: You have the right to request confirmation as to whether data concerning you is being processed, and to access this data as well as further information and a copy of the data in accordance with legal requirements.
• Right to rectification: In accordance with legal requirements, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.
• Right to erasure and restriction of processing: In accordance with legal requirements, you have the right to request that data concerning you be erased without undue delay, or alternatively, in accordance with legal requirements, to request a restriction of the processing of the data.
• Right to data portability: You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format, or to request its transmission to another controller, in accordance with the legal requirements.
• Right to lodge a complaint with a supervisory authority: You also have the right, in accordance with legal requirements, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you believe that the processing of personal data relating to you infringes the GDPR.
Definitions of terms
This section provides an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are defined primarily in Article 4 of the GDPR. The legal definitions are binding. The following explanations, however, are intended primarily to aid understanding. The terms are listed alphabetically.
Conversion tracking: Conversion tracking (also known as "visit action analysis") is a method used to determine the effectiveness of marketing measures. Typically, a cookie is stored on users' devices within the websites where the marketing measures are implemented and then retrieved again on the target website. For example, this allows us to track whether the ads we placed on other websites were successful.
• Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. a cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Audience measurement: Audience measurement (also known as web analytics) is used to analyze visitor traffic to an online service and can include visitors' behavior or interests in specific information, such as website content. With the help of audience analysis, website owners can, for example, determine when visitors access their website and which content they are interested in. This allows them to better tailor the website content to their visitors' needs. Pseudonymous cookies and web beacons are frequently used for audience analysis to recognize returning visitors and thus obtain more accurate analyses of online service usage.
• Remarketing: The term "remarketing" or "retargeting" refers to the practice of recording, for example for advertising purposes, which products a user has shown interest in on a website, in order to remind the user of these products on other websites, e.g. in advertisements.
Server monitoring and error detection: We use server monitoring and error detection to ensure the availability and integrity of our online services and to technically optimize them. Performance, utilization, and similar technical metrics are processed, providing information about the stability and any anomalies of our online services. In the event of errors or anomalies, individual user requests are recorded to identify and resolve the source of the problem.
Tracking : "Tracking" refers to the process of observing user behavior across multiple online services. Typically, behavioral and interest information related to the online services used is stored in cookies or on the servers of the tracking technology providers (so-called profiling). This information can then be used, for example, to display advertisements to users that are likely to match their interests.
• Controller: The term "controller" refers to the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
• Processing: "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and encompasses virtually any handling of data, be it collection, analysis, storage, transmission or erasure.
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