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Introduction

  1. We are committed to safeguarding the privacy of our website visitors, service users and individual customers.
  2. This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
  3. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
  4. In this policy, “we”, “us” and “our” refer to Kevin Johannes Worner.

About us

  1. Controller
    Kevin Worner
    Kurfuerstendamm 234
    10719 Berlin
  2. Data Protection Officer
    Regarding the present legal situation, we are not obliged to appoint a data protection officer. If there are any questions regarding this data protection policy or data protection related issues, please contact us.

The personal data that we collect

  1. In this Section 3 we have set out the general categories of personal data that we process. In case, we did not obtain the data directly from you, you get information about the source and specific categories of that data.
  2. We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
  3. We may process data enabling us to get in touch with you (“contact data”). The contact data may include your name and email address. Instead, you can choose your telephone number, postal address and/or social media account identifiers. This data will never be processed without your explicit consent.
  4. We may process your website user account data (“account data”) if you choose to create an account. The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences.
    If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider (e.g. Google or Facebook).
  5. We may process information relating to transactions, including purchases of goods and/or services, that you enter with us and/or through our website (“transaction data”). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details.

Purposes of processing and legal basis

  1. In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
  2. Operations – We may process your personal data for the purposes of operating our website. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and services, according to Art. 6 Sec. 1 f) GDPR.
  3. Research and analysis – We may process usage data for the purposes of researching and analysing the use of our website and services. The legal basis for this processing are our legitimate interests, namely monitoring, supporting, improving and securing our website and services, according to Art. 6 Sec. 1 f) GDPR.
  4. Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website and services, and the protection of others, according to Art. 6 Sec. 1 f) GDPR.
  5. Direct marketing – We may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email. The legal basis for this processing is only consent according to Art. 6 Sec. 1 a) GDPR or an existing contract according to Art. 6 Sec 1 b) GDPR. We will never use your data for this purpose in any other case.
  6. Contract Fulfillment – We may process your personal data for the purposes of processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract according to Art. 6 Sec. 1 b) GDPR.

Providing your personal data to others

  1. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and obtaining professional advice.
  2. Your personal data held in our website database will be stored on the servers of our hosting services providers Bubble Group Inc. We have agreed on provisions to ensure the safety of your personal data.
  3. We may disclose your contact or transaction data to our suppliers or subcontractors insofar as reasonably necessary for the fulfillment of your orders or contract. We have incorporated terms to ensure the correct processing of your data when disclosed to our subcontractors.
  4. In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

International transfers of your personal data

  1. In this Section 6, we provide information about the circumstances in which your personal data may be transferred to countries outside European Union or European Economic Area (EEA).
  2. You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
  3. The hosting facilities for our website are situated in the USA. We have agreed on provisions to ensure the safety of your personal data.

Retaining and deleting personal data

  1. This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
  2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
  3. We will retain your personal data as follows:
    • usage data will be retained for 2-3 weeks following the date of collection;
    • contact data will be retained for a period of 2-3 months following the date of the most recent contact between you and us
    • account data will be retained for the period of the account’s existence. We will delete the data following the closure of the relevant account.
    • communication data can be retained up to six years, if this is required. If this is not the case, the communication data is deleted some months after the communication in question.
    • transaction data will be retained for a minimum period of ten years following the date of the transaction, this is required by law.
  4. Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Your rights

  1. In this Section 8, we have listed the rights that you have under data protection law.
  2. Your principal rights under data protection law are:
    • the right to access – you can ask for copies of your personal data according to Art. 15 GDPR;
    • the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data according to Art. 16 GDPR;
    • the right to erasure – you can ask us to erase your personal data according to Art. 17 GDPR;
    • the right to restrict processing – you can ask us to restrict the processing of your personal data according to Art. 18 GDPR;
    • the right to object to processing – you can object to the processing of your personal data according to Art. 19 GDPR;
    • the right to data portability – you can ask that we transfer your personal data to another organisation or to you according to Art. 20 GDPR;
    • the right to complain to a supervisory authority – you can complain about our processing of your personal data according to Art. 77 Sec. 1 GDPR; – Berliner Beauftragte für Datenschutz und Informationsfreiheit (Friedrichsstraße 219, 10969 Berlin)
    • the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent according to Art. 21 Sec. 3 GDPR.
  3. These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
  4. You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out in section 2.

About Cookies

  1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
  2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
  3. Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

Cookies that we use

We use cookies for the following purposes:

  • security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally
  • analysis – we use cookies to help us to analyse the use and performance of our website and services
  • cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally
  • authentication and status – we use cookies to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website
  • shopping cart – we use cookies to maintain the state of your shopping cart as you navigate our website
  • Advertising – we use cookies to help us to display advertisements that will be relevant to you, if you are member
  • personalisation – we use cookies to store information about your preferences and to personalise our website for you, if you are member

Cookies used by our service providers

  1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
  2. We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google’s use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google’s privacy policy at https://policies.google.com/privacy.

Managing cookies

  1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
    • https://support.google.com/chrome/answer/95647 (Chrome);
    • https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
    • https://help.opera.com/en/latest/security-and-privacy/ (Opera);
    • https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
    • https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and
    • https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
  2. Blocking all cookies will have a negative impact upon the usability of many websites.
  3. If you block cookies, you will not be able to use all the features on our website.

Amendments

  1. We may update this policy from time to time by publishing a new version on our website.
  2. You should check this page occasionally to ensure you are happy with any changes to this policy.
  3. We will notify you of significant changes to this policy when you enter the site.

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