DATA PROTECTION DECLARATION

We, the company KUBY Ltd. (hereinafter “we” or “us”) take the protection of your personal data seriously and inform you here about data protection on our website. As part of our responsibility under data protection law, additional obligations have been imposed on us by the entry into force of the EU General Data Protection Regulation (Regulation (EU) 2016/679; hereinafter: “GDPR”) in order to ensure the protection of personal data of the person affected by processing (we also refer to you as the data subject as “customer”, “user”, “you”, “you” or “data subject”). Insofar as we decide either alone or jointly with others on the purposes and means of data processing, this includes above all the obligation to inform you transparently about the type, scope, purpose, duration and legal basis of the processing (cf. Art. 13 and 14 GDPR). With this declaration (hereinafter: “data protection information”), we inform you about how we process your personal data.

This data protection notice consists of a general part for all processing of personal data and processing situations that apply each time a website is accessed (General) and a special part, the content of which relates only to the processing situation specified there with the designation of the respective offer or product, in particular the visit to websites described in more detail here (Visit to websites).
In order to find the parts relevant to you, please refer to the following overview of the subdivision of the data protection information:

Part	Name	This part is for you
Part A	General	always relevant.
Part B	Website and social media presence	relevant if you use our website, including our social media presence.

General information

Definitions

In accordance with Art. 4 GDPR, this privacy policy is based on the following definitions:

“Personal data” (Art. 4 No. 1 GDPR) means any information relating to an identified or identifiable natural person (“data subject”). A person is identifiable if they can be identified directly or indirectly, in particular by reference to an identifier such as a name, an identification number, an online identifier, location data or information relating to their physical, physiological, genetic, mental, economic, cultural or social identity. Identifiability can also be achieved by linking such information or other additional knowledge. The origin, form or embodiment of the information is irrelevant (photos, video or audio recordings can also contain personal data).
“Processing” (Art. 4 No. 2 GDPR) means any operation which is performed on personal data, whether or not by automated means (i.e. using technical specifications). This includes, in particular, the collection (i.e. acquisition), recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of personal data, or alteration of the purposes for which they were originally processed.
“Controller” (Art. 4 No. 7 GDPR) means 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.
“Third party” (Art. 4 No. 10 GDPR) means any natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data; this also includes other legal entities belonging to the group.
A “processor” (Art. 4 No. 8 GDPR) is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller, in particular in accordance with the controller’s instructions (e.g. IT service provider). In terms of data protection law, a processor is in particular not a third party.
“Consent” (Art. 4 No. 11 GDPR) of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Name and address of the controller

The controller responsible for the processing of your personal data within the meaning of Art. 4 No. 7 GDPR is

KUBY Ltd.
6 Agiou Theodosiou
C 203 Desire Gardens
CY 8560 Peyia
office@kuby.info
Contact Data Protection Officer:
KUBY Ltd.
c/o Data Protection Officer
E-Mail: office@kuby.info

Legal basis for data processing

According to the law, the processing of personal data is generally prohibited and only permitted if the data processing falls under one of the following justifications:

Art. 6 para. 1 sentence 1 lit. a GDPR (“consent”): Where the data subject has voluntarily, in an informed and unambiguous manner, indicated by a statement or other unambiguous affirmative act that he or she consents to the processing of personal data relating to him or her for one or more specific purposes;
Art. 6 para. 1 sentence 1 lit. b GDPR: If the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
Art. 6 para. 1 sentence 1 lit. c GDPR: If processing is necessary for compliance with a legal obligation to which the controller is subject (e.g. a statutory retention obligation);
Art. 6 para. 1 sentence 1 lit. d GDPR: Where processing is necessary in order to protect the vital interests of the data subject or of another natural person;
Art. 6 para. 1 sentence 1 lit. e GDPR: If processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; or
Art. 6 para. 1 sentence 1 lit. f GDPR (“legitimate interests”): If the processing is necessary for the purposes of the legitimate (in particular legal or economic) interests pursued by the controller or by a third party, except where such interests are overridden by the interests or rights of the data subject which require protection of personal data (in particular where the data subject is a minor).

For the processing operations we carry out, we indicate the applicable legal basis in each case below. Processing may also be based on several legal bases.

Data erasure and storage duration

For the processing operations we carry out, we indicate below how long we store the data and when it is deleted or blocked. Unless an explicit storage period is specified below, your personal data will be erased or blocked as soon as the purpose or legal basis for storage no longer applies. Your data will generally only be stored on servers in the EU, subject to any disclosure in accordance with the provisions in A.(6) and A.(7).

However, data may be stored beyond the specified period in the event of an (impending) legal dispute with you or other legal proceedings or if storage is provided for by statutory provisions to which we are subject as the controller (e.g. Section 257 HGB, Section 147 AO). If the storage period prescribed by the statutory provisions expires, the personal data will be blocked or deleted, unless further storage by me is necessary and there is a legal basis for this.

Data security

We use appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorized access by third parties (e.g. TSL encryption, formerly known as SSL encryption, for our websites), taking into account the state of the art, the implementation costs and the nature, scope, context and purpose of the processing as well as the existing risks of a data breach (including its probability and impact) for the data subject. Our security measures are continuously improved in line with technological developments. We will provide you with further information on request.

Cooperation with contract processors

Like many companies, we also use external domestic and foreign service providers to process our business transactions (e.g. for IT, telecommunications, sales and marketing). These service providers only act on our instructions and are contractually obliged to comply with data protection regulations in accordance with Art. 28 GDPR.

Requirements for the transfer of personal data to third countries

As part of our business relationships, your personal data may be passed on or disclosed to third parties. These may also be located outside the European Economic Area (EEA), i.e. in third countries. Such processing takes place exclusively to fulfill contractual and business obligations and to maintain your business relationship with us. We will inform you about the respective details of the transfer at the relevant points below.

The European Commission certifies that some third countries have a level of data protection comparable to the EEA standard by means of so-called adequacy decisions in accordance with Article 45(1) GDPR (a list of these countries and a copy of the adequacy decisions can be found here: ec.europa.eu). Since 10.07.2023, this also includes the United States of America, so that data transfer there does not require any special authorization, provided that the US companies are certified according to the EU-US Data Privacy Framework; this can be seen at www.dataprivacyframework.gov. In other third countries to which personal data may be transferred, however, there may not be a consistently high level of data protection due to a lack of legal provisions. If this is the case, we ensure that data protection is adequately guaranteed. This is possible through binding corporate rules, standard contractual clauses of the European Commission for the protection of personal data, certificates or recognized codes of conduct. Please contact us if you would like more information on this. Specific information about the service providers used can be found in this privacy policy and on the consent page (or cookie banner).

No automated decision-making (including profiling)

We do not intend to use personal data collected from you for automated decision-making (including profiling).

No obligation to provide personal data

In principle, we do not make the use of our offers dependent on you providing us with personal data beforehand. As a customer, you are under no legal or contractual obligation to provide us with your personal data; however, we may only be able to provide certain services (e.g. the purchase of goods or services via our online store) to a limited extent or not at all if you do not provide the necessary data. If this should exceptionally be the case in the context of the products presented below and offered by us, you will be informed of this separately.

Legal obligation to transmit certain data

Under certain circumstances, we may be subject to a special legal or statutory obligation to provide the lawfully processed personal data to third parties, in particular public authorities (Art. 6 para. 1 sentence 1 lit. c GDPR).

Your rights

You can assert your rights as a data subject with regard to your processed personal data at any time by contacting us using the contact details provided at the beginning. As the data subject, you have the right

to request information about your data processed by us in accordance with Art. 15 GDPR. In particular, you can request information about the purposes of processing, the category of data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of appeal, the origin of your data if it was not collected by us, as well as the existence of automated decision-making including profiling and, if applicable, meaningful information on its details;
in accordance with Art. 16 GDPR, to immediately request the rectification of incorrect data or the completion of your data stored by us
in accordance with Art. 17 GDPR, to request the erasure of your data stored by us, unless the processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of legal claims
in accordance with Art. 18 GDPR, to demand the restriction of the processing of your data if the accuracy of the data is disputed by you or the processing is unlawful;
in accordance with Art. 20 GDPR, to receive your data that you have provided to us in a structured, commonly used and machine-readable format or to request that it be transmitted to another controller (“data portability”)
to object to the processing pursuant to Art. 21 GDPR, provided that the processing is based on Art. 6 para. 1 sentence 1 lit. e or lit. f GDPR. This is particularly the case if the processing is not necessary for the performance of a contract with you. If it is not an objection to direct advertising, we ask you to explain the reasons why we should not process your data as we have done when exercising such an objection. In the event of your justified objection, we will examine the situation and either discontinue or adapt the data processing or point out to you our compelling reasons worthy of protection on the basis of which we will continue the processing;
in accordance with Art. 7 para. 3 GDPR, to withdraw your consent once given to us at any time (including before the GDPR came into force, i.e. before 25 May 2018) – i.e. your voluntary, informed and unequivocal declaration or other unambiguous confirmatory act that you consent to the processing of the personal data concerned for one or more specific purposes, if you have given such consent. As a result, we may no longer continue the data processing based on this consent in the future and, in accordance with Art. 77 GDPR, you have the right to complain to a data protection supervisory authority about the processing of your personal data, for example to the data protection supervisory authority responsible for us, named below: Commissioner for Personal Data Protection, Iasonos 1, 1082 Nicosia CY, e-mail: commissioner@dataprotection.gov.cy

Changes to the data protection information

As part of the further development of data protection law and technological or organizational changes, our data protection information is regularly reviewed to determine whether it needs to be adapted or supplemented. You will be informed of any changes in particular on our website www.kuby.info. This data protection notice is valid as of October 8, 2023.

Visiting and using our websites

Information about our company and the services we offer can be found in particular at www.clemenskuby.com, www.kuby.info and www.portal.kuby.info together with the associated subpages (hereinafter collectively referred to as “websites”). When you visit our websites and our online store, your personal data may be processed. If you leave our website via links to other providers or open corresponding pages, our responsibility ends with this click, as we then no longer have any influence on the processing of any data transferred to the third party when you click on the link, such as your IP address. For information on the handling of your personal data when using these websites, please refer to the respective privacy policies of the providers, as well as if the use of the websites of other providers involves the collection, processing or use of personal data.

Processed personal data

When using the websites for information purposes, we collect, store and process the following categories of personal data:

Log data

When you visit our website, a so-called log data record (so-called server log files) is temporarily and anonymously stored on our web server. This consists of:

the page from which the page was requested (so-called referrer URL)
the name and URL of the requested page
the date and time of the request
the description of the type, language and version of the web browser used
the IP address of the requesting computer, which is shortened so that a personal reference can no longer be established
the amount of data transferred
the operating system
the message as to whether the request was successful (access status/Http status code)
the GMT time zone difference

The log data is stored on the basis of our legitimate interests in protection against unauthorized use and misuse, and to protect our customers from this.
“Contact form data”: When contact forms are used, the data transmitted through them is processed (e.g. depending on the query: first name, surname, gender, address, telephone number, email, profession, workplace, payment data if applicable, and the time of transmission).

Purpose and legal basis of data processing

We require and use your data in order to present our company to you and, if necessary, to provide you with up-to-date information about our activities and contact options. We process the personal data described in more detail above in accordance with the provisions of the GDPR and other relevant data protection regulations and only to the extent necessary. Insofar as the processing of personal data is based on Art. 6 para. 1 sentence 1 lit. f GDPR, the aforementioned purposes also represent our legitimate interest.

The processing of log data serves statistical purposes and to improve the quality of our website, in particular the stability and security of the connection (legal basis is Art. 6 para. 1 sentence 1 lit. f GDPR). The processing of contact form data is carried out to process customer inquiries (legal basis is Art. 6 para. 1 sentence 1 lit. a, b or f GDPR).

Duration of data processing

Your data will only be processed for as long as is necessary to achieve the above-mentioned processing purposes; the legal bases specified in the context of the processing purposes apply accordingly. With regard to the use and storage duration of cookies, please refer to “Data deletion and storage duration”. Third parties used by us will store your data on their system for as long as is necessary in connection with the provision of the services for me in accordance with the respective order. You can find more information on the storage period under “Data erasure and storage period”.

Transfer of personal data to third parties; legal basis

The following categories of recipients, which are usually processors (see A. (6)), may receive access to your personal data:

Service providers for the operation of our website and the processing of the data stored or transmitted by the systems; the legal basis for the disclosure is then Art. 6 para. 1 sentence 1 lit. b or lit. f GDPR, unless they are processors;
State bodies/authorities, insofar as this is necessary to fulfill a legal obligation. The legal basis for the transfer is then Art. 6 para. 1 sentence 1 lit. c GDPR;
Persons employed to carry out our business operations (e.g. auditors, banks, insurance companies, legal advisors, supervisory authorities, parties involved in company acquisitions or the establishment of joint ventures). The legal basis for the disclosure is then Art. 6 para. 1 sentence 1 lit. b or lit. f GDPR.

For the guarantees of an appropriate level of data protection when transferring data to third countries, see above under “Requirements for the transfer of personal data to third countries”.

In addition, we only pass on your personal data to third parties if you have given your express consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR.

Use of cookies, plugins and other services on our website

We use cookies on our website. Cookies are small text files that are assigned and stored on your hard disk to the browser you are using by means of a characteristic string of characters and through which certain information flows to the body that sets the cookie. Cookies cannot execute programs or transfer viruses to your computer and therefore cannot cause any damage. They serve to make the Internet offer more user-friendly and effective overall, i.e. more pleasant for you.

Cookies may contain data that makes it possible to recognize the device used. In some cases, however, cookies only contain information on certain settings that are not personally identifiable. However, cookies cannot directly identify a user.

A distinction is made between session cookies, which are deleted as soon as you close your browser, and permanent cookies, which are stored beyond the individual session. In terms of their function, a distinction is made between cookies:

Technical cookies: these are absolutely necessary in order to move around the website, use basic functions and ensure the security of the website; they do not collect information about you for marketing purposes, nor do they store which websites you have visited;
Performance cookies: These collect information about how you use our website, which pages you visit and, for example, whether errors occur during website use; they do not collect any information that could identify you – all information collected is anonymous and is only used to improve our website and to find out what interests our users;
Advertising cookies, targeting cookies: These are used to offer the website user needs-based advertising on the website or offers from third parties and to measure the effectiveness of these offers; advertising and targeting cookies are stored for a maximum of 13 months;
Sharing cookies: These are used to improve the interactivity of our website with other services (e.g. social networks); sharing cookies are stored for a maximum of 13 months.

Any use of cookies that is not absolutely technically necessary constitutes data processing that is only permitted with your express and active consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR. This applies in particular to the use of advertising, targeting or sharing cookies. In addition, we only pass on your personal data processed by cookies to third parties if you have given your express consent to this in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR.

It is possible to object to the use of cookies used for reach measurement and advertising purposes via optout.networkadvertising.org/ (deactivation page of the Network Advertising Initiative), the US website www.aboutads.info/choices or the European website www.youronlinechoices.com/uk/your-ad-choices/.

Social media plugins

We do not use any social media plugins on our website. If our websites contain symbols from social media providers (e.g. Facebook, LinkedIn, Xing, Instagram, TikTok), we only use these to passively link to the pages of the respective providers. No data is transferred to the providers of these networks before these links are called up.

When you register for the newsletter, we use your e-mail address for our own advertising purposes (sending e-mails) until you unsubscribe from the newsletter. You can unsubscribe at any time. In this context, we collect your name (first name and surname) and your e-mail address. The registration takes place in the so-called double opt-in procedure. After registering, you will be asked by e-mail to confirm your subscription to the newsletter. The registration is logged for evidence purposes and data on usage (time of registration and confirmation, IP address) is processed. Processing is based on your express consent (Article 6(1)(a) GDPR); logging is based on legal requirements (Article 6(1)(c), Article 7 GDPR) and to protect our legitimate interests (Article 6(1)(f) GDPR). You can withdraw your consent at any time with effect for the future, e.g. by clicking on the link provided at the end of the newsletter email to confirm that you wish to unsubscribe. Email addresses may remain stored for up to three years after revocation to safeguard our legitimate interests in order to be able to prove consent for the newsletters sent until revocation.

Quentn

We use the Quentn service to create, organize, send and analyze e-mail newsletters. The provider of Quentn is Quentn.com GmbH, Friedrich-Ebert-Str. 51, 14469 Potsdam, Germany. If you enter data to subscribe to our newsletter, it will be stored on Quentn’s servers. Information about data protection at Quentn can be found at https://quentn.com/datenschutz/. We can use the data from the newsletters sent with the help of Quentn to analyze the behavior of newsletter recipients. This includes insights into how many recipients have opened the newsletter message or how often certain links in the newsletter have been clicked on. We can also track conversions, i.e. analyze whether a certain action was taken after selecting a link in the newsletter.

Intercom

We use the Intercom service of R&D Unlimited Company, 2nd Floor, Stephen Court, 18-21 St. Stephen’s Green, Dublin 2, Ireland, to explain, create, organize and analyze our website functions. Visitors to our website can communicate directly with the website operator via the Intercom Chat Messenger in order to clarify pre-contractual questions and enable consultations. Intercom stores the IP address and the conversation ID in order to be able to respond to inquiries. In addition, a cookie is set that enables chats to be continued later even without registration. This data is automatically deleted after nine months if no new visit is made. Visitors can provide their e-mail address on a voluntary basis to enable a subsequent reply by e-mail. This e-mail address will only be used to answer the request and will not be passed on for advertising purposes or to third parties. In addition, we use Intercom to analyze the use of our services, whereby only a limited amount of your data, such as login date and some personal information, is provided. For more information about Intercom’s use of cookies, please see their cookie policy on the website. Intercom also collects publicly available contact and social information associated with you to improve the user experience. Details of Intercom’s privacy practices are available at https://www.intercom.com/legal/privacy.

Hosting and content delivery networks, cloud services

Cloud services, CDNs and hosts are used for the purpose of fulfilling contracts with our potential and existing customers (Art. 6 para. 1 lit. b) GDPR) and in the interest of a secure, fast and efficient provision of our online offer by a professional provider (Art. 6 para. 1 lit. f) GDPR). We have this website and any other data stored or hosted and processed by an external service provider. Among other things, the hoster or service provider stores the data from your inquiries via the contact form; this data is deleted there after our processing. Furthermore, the other personal data collected on this website is stored on the hoster’s servers. This includes IP addresses, contact requests, meta and communication data, contract data, contact data, names, website accesses and other data generated via a website. Our hoster will only process your data to the extent necessary to fulfill its performance obligations and follow our instructions with regard to this data. There is an order processing contract with our hoster or service provider in accordance with Art. 28 GDPR.

OVH GmbH

We use the company OVH GmbH, Dudweiler Landstraße 5, 66123 Saarbrücken, Germany, as a cloud service. You can find OVH GmbH’s privacy policy at https://www.ovhcloud.com/de/personal-data-protection/. We have concluded an order agreement contract with OVH GmbH.

Web hosting

We use the company Webspace-Verkauf.de ISP e.K., Lichtenfelser Str. 17 a, D-96271 Grub am Forst, Germany as our web host. Their privacy policy is publicly accessible under the domain https://www.webspace-verkauf.de/datenschutz.html. We have concluded an order processing contract with Webspace-Verkauf.de ISP e. K.

AWS

For the hosting of our database and web content, we use the service “Amazon Web Services” (“AWS” for short) from Amazon Web Services, Inc, 410 Terry Avenue North, Seattle, WA 98109, United States of America. Your data is stored exclusively in a data center in Frankfurt/Main, Germany, which is certified according to ISO 27001, 27017 and 27018 as well as PCI DSS Level 1. Strict access restrictions are implemented and all data is transmitted and stored in encrypted form. AWS has submitted to the EU-US Privacy Shield, which is intended to ensure compliance with European data protection standards. Detailed information on data protection at AWS can be found at https://aws.amazon.com/de/compliance/eu-data-protection/ and https://aws.amazon.com/de/privacy/.

Tracking and analysis services, marketing

We use analysis services on our websites to collect information about your visit to our website, which enables us to understand the functionality of our website and make it more user-friendly. The data is processed statistically. Your IP address is shortened by the last octet by default, so that the previously personal user data is directly anonymized and cannot be assigned to an individual user. We also evaluate your usage behavior pseudonymously in order to adapt our advertising to your personal interests. For this purpose, we record your activities on this website (e.g. surfing behavior, subpages visited, length of stay, etc.). The data will not be merged with the bearer of the pseudonym without your express consent; as the provider, we have a legitimate interest in analyzing user behavior in order to optimize both our website and our advertising. We will obtain the necessary consent from you.

Google Analytics

We use Google Analytics for web analysis, reach measurement and the measurement of user flows. You can find information about Google Analytics at marketingplatform.google.com/intl/en/about/analytics/. The provider of the service is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, a subsidiary of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States of America (“Google”). The legal basis for use is Art. 6 para. 1 sentence 1 lit. a) and Art. 49 para. 1 sentence 1 lit. a GDPR. The level of data protection is guaranteed both by standard contractual clauses (business.safety.google/adsprocessorterms) and by certification under the Privacy Shield Agreement (www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active). You can find the order processing contract at business.safety.google/adsprocessorterms. Privacy policy: policies.google.com/privacy. You can object to the use of Google Analytics with the following opt-out tool and prevent its use: tools.google.com/dlpage/gaoptout?hl=en. You can also find setting options for the display of advertisements at adssettings.google.com/authenticated.

By using cookies, Google generates information about the use of the websites; Google Ireland has the data processed by Google LLC in the USA. Google uses the information collected to evaluate your use of the website, to compile reports on website activity for website operators and to provide other services relating to website activity and internet usage.

We use IP masking, i.e. a method of protecting user data through pseudonymization by shortening the IP address. Google shortens your IP address within the European Union or in other signatory states to the Agreement on the European Economic Area before storing and transmitting it, so that a direct personal reference is excluded. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.

Google Tag Manager

Within our website, we use Google Tag Manager, a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. With the help of Google Tag Manager, various codes and services can be integrated into our websites in a structured and standardized manner. The Google Tag Manager implements the corresponding tags or “activates” them. During such activation, Google may process certain information, including personal data, namely online identifiers (including cookie IDs) and IP addresses. It is possible that Google may transfer this information to a server in a third country outside the EU. You can find information about the Google Tag Manager at https://www.google.de/tagmanager/use-policy.html and at https://www.google.com/intl/de/policies/privacy/index.html. We have concluded an order processing contract with Google. Our aim in implementing the Google Tag Manager is to integrate various services in a simple and structured way. The Google Tag Manager also helps to optimize the loading time of various services. The legal basis for the processing of your data is your consent (Article 6(1)(a) GDPR) and our legitimate interest (Article 6(1)(f) GDPR).

Facebook Pixel, Custom Audiences and Conversion

We use the “Facebook pixel” of the social network Facebook (Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, United States of America, or for EU citizens Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, “Facebook”) for the operation, optimization and analysis of customer behavior. Facebook is certified under the Privacy Shield Agreement, www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active. In addition, the general information in this privacy policy on the transfer of data to third countries is relevant.

Visitors to our websites are assigned to a target group for the display of ads (“Facebook ads”) with the help of Facebook’s pixel. As a result, advertising measures are only displayed to those who correspond to the information we have transmitted to Facebook and who may be interested in the measures as visitors or who have certain characteristics (e.g. interests in certain topics or products determined on the basis of the websites visited) that we transmit to Facebook (so-called “Custom Audiences”). With the help of the Facebook pixel, we also want to ensure that our Facebook ads are not annoying. In addition, the effectiveness of advertising on Facebook can be used for statistical and market research purposes by determining whether users have been redirected to our website after clicking on a Facebook ad (so-called “conversion”).

The legal basis for use is Art. 6 para. 1 sentence 1 lit. a) and Art. 49 para. 1 sentence 1 lit. a GDPR. We have concluded a contract data processing agreement with Facebook. The processing of data by Facebook takes place within the framework of Facebook’s data usage policy (www.facebook.com/policy.php). Information is available in the Facebook help section (www.facebook.com/business/help/651294705016616). You have the option to object to the collection by the Facebook pixel and thus to the use of your data for Facebook ads. You can change the platform-independent settings for usage-based advertising on Facebook in accordance with the Facebook help pages (www.facebook.com/settings?tab=ads).

Automation and AI

Zapier

We use “Zapier”, a service provided by Zapier Inc (548 Market St #6241, San Francisco, CA 94104, United States of America), to automate actions between different web applications. This enables us to optimize and accelerate our online presence. It is possible that data may be transferred to Zapier servers in the USA. Nevertheless, we have signed a data processing agreement with Zapier. In addition, the EU standard contractual clauses secure this data processing. This use serves our legitimate interest in accordance with Art. 6 para. 1 lit. f) GDPR. You can find out more about Zapier’s privacy policy here: https://zapier.com/privacy/

OpenAI

To answer inquiries and optimize our customer service, we use “ChatGPT”, an AI-supported chat function from OpenAI, L.L.C., 3180 18th St, San Francisco, CA 94110, United States of America. When interacting with ChatGPT, entered questions and answers are processed to generate a suitable answer. The data transfer is encrypted. OpenAI does not store these conversations for the long term and does not use them for advertising purposes or to pass them on to third parties. However, interactions with ChatGPT may be analyzed anonymously by OpenAI for research and improvement purposes. Data processing by ChatGPT serves the purpose of improving our service offering and serves our legitimate interest pursuant to Art. 6 para. 1 lit. f) GDPR. Further information on data processing and data protection at OpenAI and ChatGPT can be found in OpenAI’s official privacy policy at https://openai.com/policies/privacy-policy

Video, conference and webinar services

Vimeo

We embed videos on our website using the Vimeo service offered by Vimeo LLC, 555 West 18th Street, New York, New York 10011, United States of America. When you access a website in which a Vimeo video is embedded, a connection to the Vimeo server is established. Data is processed there, such as your IP address, your browser or operating system, the website from which you access the video and the type and scope of your actions on the website (duration, clicks, etc.). Further information on data protection at Vimeo can be found at https://vimeo.com/privacy or https://vimeo.com/cookie_policy with regard to the cookies set. The legal basis for our processing is your consent in accordance with Art. 6 para. 1 lit. a) GDPR and, in addition, our legitimate interest in being able to offer our services easily and conveniently for you.

Zoom

We use the “Zoom” video conferencing system offered by Zoom Video Communications, Inc, 55 Almaden Blvd, Suite 600, San Jose, CA 95113, United States of America, https://support.zoom.us/hc/de. This is for the purpose of communicating with you. We and/or Zoom process the data collected in this context, such as image data, the spoken word, entered texts, IP address, user name and e-mail, to arrange appointments, registration, participation and follow-up of such video conferences. During the image transmission you initiate, sensitive data such as health data or religious beliefs may also be communicated under certain circumstances. The video conference will only be recorded with your consent and with prior notice. We have contractually commissioned Zoom with the processing. You can find Zoom’s privacy policy here: https://zoom.us/de-de/privacy.html.

Demio

We use the “Demio” service to conduct webinars. This is offered by Banzai International, Inc, 101 Yesler Way, Suite 600, Seattle WA, 98104, United States of America. We process the data on the basis of your consent and to fulfill the contract (Article 6 paragraph 1 sentence 1 letters a and b GDPR). In this context, we process your personal data that we become aware of in the course of your participation (e.g. e-mail address, name, text entries, reactions, IP address). We have concluded a data processing agreement with Demio. Further information on data processing by Demio can be found on the Demio website at https://www.demio.com/privacy-policy.

WebinarJam

We use WebinarJam for the organization and implementation of webinars. The service provider is Genesis LLC, 7660 Fay Ave #H184, La Jolla, California, United States of America. When you participate in a webinar via WebinarJam, your personal data, including your IP address and any content you enter (such as your e-mail address or messages in the chat), is backed up on WebinarJam’s servers. The basis for the use of WebinarJam is Art. 6 para. 1 lit. b GDPR (fulfillment of a contract) as well as our legitimate interest in the qualitative implementation of our webinars in accordance with Art. 6 para. 1 lit. f GDPR. If consent has been obtained, the data processing is based solely on Art. 6 para. 1 lit. a GDPR and Section 25 para. 1 TTDSG. This applies in particular if the consent includes the storage of cookies or access to terminal device information within the meaning of the TTDSG. Such consent can be withdrawn at any time. For more detailed information on the processing of your data by WebinarJam, please visit their privacy policy: https://home.webinarjam.com/privacypolicy.

Payment service provider / contract processing

Digistore24

Our products are not sold by us, but by Digistore24 GmbH, St.-Godehard-Straße 32, D-31139 Hildesheim, Germany, e-mail: support@digistore24.com, in its own name. Only Digistore24 GmbH will be your contractual partner in this case. In the event of a purchase, the contractual terms and conditions and the data protection provisions of Digistore24 GmbH apply, available on the respective product page or at https://www.digistore24.com/page/privacy. Digistore24 GmbH does not process data on our behalf, but acts on its own responsibility. Digistore24 is obliged and declares that it processes customer data in accordance with data protection law. The legal basis for this is Art. 6 para. 1 sentence 1 lit. b) GDPR. We receive your data collected during the purchase from Digistore24 GmbH so that we can fulfill the contract for Digistore24 GmbH and process this data in our customer account for the purpose of fulfilling the contract and for communication, including legally permissible offers of further services.

Other service providers for websites and cloud storage

Clickfunnels

We use the Clickfunnels service of Etison LLC, headquartered at 3443 W. Bavaria Street, Eagle, Idaho 8366 USA, to generate and publish our website, to carry out marketing tests and to measure the success of our website(s) in other ways. Bavaria Street, Eagle, Idaho 83616, USA. Clickfunnels is a landing page generator that collects personal data (in particular IP addresses) during operation. The processing is carried out on the basis of Art. 6 para. 1 lit. f GDPR. The transfer of data to the USA takes place on the basis of the EU adequacy decision and on the basis of Art. 46 para. 2 lit. c GDPR (EU standard data protection clauses). Further information on data processing and information on data protection by Clickfunnels can be found at https://signup.clickfunnels.com/privacy-policy and https://signup.clickfunnels.com/gdpr-policy.

pCloud

We use the pCloud service as cloud storage. This is offered by pCloud AG, Zugerstrasse 74, CH-6340 Baar/Switzerland. You can find out more about pCloud at their website https://www.pcloud.com/de/ and their privacy policy at https://www.pcloud.com/de/privacy_policy.html. The processing is carried out on the basis of Art. 6 para. 1 lit. f GDPR.