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Privacy Policy

Introduction

We (“we”, “us”, “our”) take the protection of the data of users (“User” or “you”) of our website and/or our mobile app (the “Website” and the “Mobile App”) very seriously and are committed to protecting the information that users provide to us in connection with the use of our Website and/or our Mobile App (together, the “Digital Assets”). We are also committed to protecting and using your data in accordance with applicable law.

This Privacy Policy explains our practices regarding the collection, use, and disclosure of your data through your use of our Digital Assets (the “Services”) when you access the Services via your devices.

Please read this Privacy Policy carefully and ensure you fully understand our practices regarding your data before using our Services. If you have read and fully understood this policy but do not agree with our practices, you must discontinue use of our Digital Assets and Services. By using our Services, you acknowledge the terms of this Privacy Policy. Your continued use of the Services constitutes your consent to this Privacy Policy and any amendments thereto.

In this Privacy Policy you will learn:

  • How we collect data

  • What data we collect

  • Why we collect this data

  • With whom we share the data

  • Where the data is stored

  • How long the data is retained

  • How we protect the data

  • How we handle minors

  • Updates or changes to this Privacy Policy

What data do we collect?

Below is an overview of the data we may collect:

  • Non-identified and non-identifiable information that you provide during the registration process or that is collected via your use of our Services (“Non-Personal Data”). Non-Personal Data does not enable us to identify the individuals from whom it was collected. Non-Personal Data we collect mainly consists of technical and aggregated usage information.

  • Individually identifiable information, i.e., any data that can identify you with reasonable effort (“Personal Data”). Personal Data we collect through our Services may include information requested from time to time, such as names, email addresses, addresses, phone numbers, IP addresses, and more. When we combine Personal Data with Non-Personal Data, we will treat the combined data as Personal Data for as long as it remains combined.

How do we collect data?

The main methods we use to collect data include:

  • We collect data when you use our Services. When you visit our Digital Assets and use our Services, we may collect, record, and store usage, sessions, and related information.

  • We collect data that you provide to us yourself, for example when you contact us directly via a communication channel (e.g., an email with a comment or feedback).

  • We may collect data from third-party sources, as described below.

  • We collect data that you provide when you sign in to our Services via a third party such as Facebook or Google.

Why do we collect this data?

We may use your data for the following purposes:

  • To provide and operate our Services;

  • To develop, customize, and improve our Services;

  • To respond to your feedback, requests, and inquiries, and to provide support;

  • To analyze demand and usage patterns;

  • For other internal, statistical, and research purposes;

  • To enhance our data security and fraud prevention capabilities;

  • To investigate violations and enforce our terms and policies and to comply with applicable laws, regulations, or governmental orders;

  • To send you updates, news, promotional materials, and other information related to our Services. For marketing emails, you can choose whether to continue receiving them. If not, simply click the unsubscribe link in such emails.

With whom do we share this data?

We may share your data with our service providers to operate our Services (e.g., data storage via third-party hosting services, provision of technical support, etc.).

We may also disclose your data under the following circumstances: (i) to investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing; (ii) to establish or exercise our rights of defense; (iii) to protect our rights, property, or personal safety and the safety of our users or the public; (iv) in the event of a change of control of us or any of our affiliates (by way of merger, acquisition, or purchase of substantially all assets, etc.); (v) to collect, hold, and/or manage your data via authorized third parties (e.g., cloud service providers) as is reasonably necessary for business purposes; (vi) to work jointly with third parties to improve your user experience. For the avoidance of doubt, we may transfer, share, or otherwise use Non-Personal Data at our sole discretion.

Cookies and similar technologies

When you visit or access our Services, we authorize third parties to use web beacons, cookies, pixel tags, scripts, and other technologies and analytics services (“Tracking Technologies”). These Tracking Technologies may allow third parties to automatically collect your data in order to improve navigation on our Digital Assets, optimize their performance, ensure a customized user experience, and for security and fraud prevention purposes.

To learn more, please read our Cookie Policy.

Without your consent, we will not share your email address or other Personal Data with advertising companies or ad networks.

Where do we store the data?

Non-Personal Data
Please note that our company as well as our trusted partners and service providers are located around the world. For the purposes explained in this Privacy Policy, we store and process all Non-Personal Data we collect in different jurisdictions.

Personal Data
Personal Data may be maintained, processed, and stored in the United States, Ireland, South Korea, Taiwan, Israel, and in other jurisdictions as necessary for the proper provision of our Services and/or as required by law (as further explained below).

How long do we retain the data?

Please note that we retain the data we collect for as long as necessary to provide our Services, to comply with our legal and contractual obligations to you, to resolve disputes, and to enforce our agreements.
We may correct, complete, or delete inaccurate or incomplete data at our discretion at any time.

How do we protect the data?

The hosting service for our Digital Assets provides us with the online platform through which we offer our Services to you. Your data may be stored via our hosting provider’s data storage, databases, and general applications. They store your data on secure servers behind a firewall and provide secure HTTPS access to most areas of their services.

Notwithstanding the measures and efforts taken by us and our hosting provider, we cannot and do not guarantee absolute protection and security of the data you upload, post, or otherwise share with us or others.

Therefore, we ask you to set strong passwords and, where possible, to avoid transmitting confidential information to us or others whose disclosure could cause you significant or lasting harm. Since email and instant messaging are not considered secure forms of communication, please do not share confidential information via either of these channels.

How do we handle minors?

Children may use our Services. However, if they wish to access certain features, they may be required to provide certain information. Some data (including data collected via cookies, web beacons, and other similar technologies) may be collected automatically. Where we knowingly collect, use, or disclose data collected from a child, we will provide notice and obtain parental consent in accordance with applicable law. We do not condition a child’s participation in an online activity on providing more contact information than is reasonably necessary to participate in that activity. We use the data collected only in connection with the Services requested by the child.

We may also use a parent’s contact information to communicate about the child’s activities in the Services. Parents can review the data we have collected from their child, prohibit us from collecting further data from their child, and request that any data we have collected be deleted from our records.

Please contact us to view, update, or delete your child’s data. To protect your child, we may ask you to verify your identity. We may deny access to data if we believe your identity is in question. Please note that certain data may not be deleted due to other legal obligations.

Legal bases for processing (EEA)

We will use your Personal Data only for the purposes set out in this Privacy Policy and only where we believe that:

  • The use of your Personal Data is necessary to perform or enter into a contract (e.g., to provide the Services themselves or to provide customer or technical support);

  • The use of your Personal Data is necessary to comply with relevant legal or regulatory obligations; or

  • The use of your Personal Data is necessary to support our legitimate business interests (provided that such processing is always carried out in a manner that is proportionate and respects your privacy rights).

As an EEA resident you may:

  • Request confirmation whether Personal Data concerning you is being processed, and request access to your stored Personal Data and certain supplemental information;

  • Request receipt of Personal Data you have provided to us in a structured, commonly used, and machine-readable format;

  • Request rectification of your Personal Data stored by us;

  • Request deletion of your Personal Data;

  • Object to the processing of your Personal Data by us;

  • Request restriction of processing of your Personal Data; or

  • Lodge a complaint with a supervisory authority.

Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. If you have general questions about the data we collect and how we use it, please contact us as indicated below.

In providing the Services, we may transfer data across borders to affiliates or other third parties and from your country/jurisdiction to other countries/jurisdictions worldwide. By using the Services, you consent to the transfer of your data outside the EEA.

If you are located in the EEA, your Personal Data will be transferred to locations outside the EEA only where we believe there is an adequate or comparable level of protection for Personal Data. We will take appropriate steps to ensure we have suitable contractual arrangements with our third parties to ensure that appropriate safeguards are in place so that the risk of unlawful use, alteration, deletion, loss, or theft of your Personal Data is minimized and that such third parties act at all times in accordance with applicable laws.

California Consumer Privacy Act (CCPA) rights

If you use the Services as a California resident, you may be entitled under the California Consumer Privacy Act (“CCPA”) to request access to and deletion of your data.

To exercise your right to access and deletion, please see how to contact us below.

We do not sell users’ Personal Data for the purposes and intents of the CCPA.

Updates or changes to this Privacy Policy

We may revise this Privacy Policy at our sole discretion from time to time; the version posted on the Website is always current (see the “Effective date” indication). We ask you to review this Privacy Policy regularly for changes. In the event of material changes, we will post a notice on our Website. Your continued use of the Services after being notified of changes on our Website will be deemed your acknowledgment and agreement to the amended Privacy Policy and your consent to be bound by the terms of such changes.

Contact

If you have general questions about the Services or the data we collect about you and how we use it, please contact us at:

Sarah Picker
Hubertusweg 1, 82319 Starnberg, Germany
Sarah.picker@gmx.de

DISCLAIMER

The information contained herein does not constitute legal advice and should not be relied upon as such. Specific requirements for legal terms and policies may vary from state to state and/or jurisdiction to jurisdiction. As set out in our Terms of Use, you are responsible for ensuring that your Services are lawful under the laws applicable to you and that you comply with them. To ensure you fully meet your legal obligations, we strongly recommend seeking professional advice to understand which requirements apply specifically to you.

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