1) Information on the Collection of Personal Data and Contact Details of the Controller
1.1 We are pleased that you are visiting our website and thank you for your interest. On the following pages, we inform you about the handling of your personal data when using our website. Personal data is all data with which you can be personally identified.
1.2 The controller in charge of data processing on this website, within the meaning of the General Data Protection Regulation (GDPR), is FASHION FOR FRIENDS USA LLC, 1309 Coffeen Avenue, STE 1200, Sheridan WY 82801, United States, E-Mail: [email protected] The controller in charge of the processing of personal data is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.
1.3 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g. orders or inquiries to the controller). You can recognize an encrypted connection by the character string https:// and the lock symbol in your browser line.
2) Data Collection When You Visit Our Website
When using our website for information only, i.e. if you do not register or otherwise provide us with information, we only collect data that your browser transmits to our server (so-called "server log files"). When you visit our website, we collect the following data that is technically necessary for us to display the website to you:
- Our visited website
- Date and time at the moment of access
- Amount of data sent in bytes
- Source/reference from which you came to the page
- Browser used
- Operating system used
- IP address used (if applicable: in anonymized form)
Data processing is carried out in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to check the server log files subsequently, if there are any concrete indications of illegal use.
3) Content Delivery Network
On our website we use a content delivery network ("CDN") of the technology service provider Cloudflare Inc., 101 Townsend St. San Francisco, CA 94107, USA ("Cloudflare"). A Content Delivery Network is an online service used to deliver large media files (such as graphics, page content or scripts) through a network of regionally distributed servers connected via the internet. The use of Cloudflare's content delivery network helps us to optimise the loading speeds of our website.
The processing takes place in accordance with Art. 6 (1) point f GDPR on the basis of our legitimate interest in a secure and efficient provision, as well as improvement of the stability and functionality of our website.
In order to make your visit to our website attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your end device. Some of the cookies we use are deleted after the end of the browser session, i.e. after closing your browser (so-called session cookies). Other cookies remain on your terminal and enable us or our partner companies (third-party cookies) to recognize your browser on your next visit (persistent cookies). If cookies are set, they collect and process specific user information such as browser and location data as well as IP address values according to individual requirements. Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie. You can check the duration of the respective cookie storage in the overview of the cookie settings of your web browser.
In some cases, cookies are used to simplify the ordering process by saving settings (e.g. remembering the content of a virtual shopping basket for a later visit to the website). If personal data are also processed by individual cookies set by us, the processing is carried out in accordance with Art. 6 (1) point b GDPR either for the execution of the contract or in accordance with Art. 6 (1) point f GDPR to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and effective design of the page visit.
We work together with advertising partners who help us to make our website more interesting for you. For this purpose, cookies from partner companies are also stored on your hard drive when you visit our website (third-party cookies). You will be informed individually and separately about the use of such cookies and the scope of the information collected in each case within the following sections.
Please note that you can set your browser in such a way that you are informed about the setting of cookies and you can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or generally. Each browser differs in the way it manages the cookie settings. This is described in the help menu of each browser, which explains how you can change your cookie settings. You will find these for the respective browsers under the following links:
- Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
- Firefox: https://www.mozilla.org/en-US/privacy/websites/#cookies
- Chrome: https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=en
- Safari: https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac
- Opera: https://help.opera.com/en/latest/web-preferences/#cookies
Please note that the functionality of our website may be limited if cookies are not accepted.
5) Contacting Us
When you contact us (e.g. via contact form or e-mail), personal data is collected. Which data is collected in the case of a contact form can be seen from the respective contact form. This data is stored and used exclusively for the purpose of responding to your request or for establishing contact and for the associated technical administration. The legal basis for processing data is our legitimate interest in responding to your request in accordance with Art. 6 (1) point f GDPR. If your contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) point b GDPR. Your data will be deleted after final processing of your enquiry; this is the case if it can be inferred from the circumstances that the facts in question have been finally clarified, provided there are no legal storage obligations to the contrary.
6) Data Processing When Opening a Customer Account and for Contract Processing
Pursuant to Art. 6 (1) point b GDPR, personal data will continue to be collected and processed if you provide it to us for the execution of a contract or when opening a customer account. Which data is collected can be seen from the respective input forms. It is possible to delete your customer account at any time. This can be done by sending a message to the above-mentioned address of the controller. We store and use the data provided by you for contract processing. After complete processing of the contract or deletion of your customer account, your data will be blocked in consideration of tax and commercial retention periods and deleted after expiry of these periods, unless you have expressly consented to further use of your data or a legally permitted further use of data has been reserved by our site, about which we will inform you accordingly below.
7) Commentary Function
Within the scope of the commentary function on this website, in addition to your comment, information on the time of writing the comment and the name of the commentator you have chosen is stored and published on the website. Furthermore, your IP address is logged and stored. This IP address is stored for security reasons, in case the person concerned violates the rights of third parties or posts illegal content by submitting a comment. We need your e-mail address to contact you if a third party should object to your published content as unlawful. The legal basis for the storage of your data is Art. 6 (1) point b and f GDPR. We reserve the right to delete comments if they are objected to as unlawful by third parties.
8) Use of Client Data for Direct Advertising
8.1 If you subscribe to our e-mail newsletter, we will send you regular information about our offers. The only mandatory information for sending the newsletter is your e-mail address. The indication of additional possible data is voluntary and is used to allow us to address you personally. We use the so-called double opt-in procedure for sending newsletters. This means that we will not send you an e-mail newsletter, unless you have expressly confirmed to us that you agree to the sending of such a newsletter. We will then send you a confirmation e-mail asking you to confirm that you wish to receive future newsletters by clicking on an appropriate link.
By activating the confirmation link, you give us your consent to the use of your personal data in accordance with Art. 6 (1) point a GDPR. When you register for the newsletter, we store your IP address entered by the Internet Service Provider (ISP) as well as the date and time of registration so that we can trace any possible misuse of your e-mail address at a later time. The data collected by us when you register for the newsletter will be used exclusively for the purpose of advertising by means of the newsletter. You can unsubscribe from the newsletter at any time via the link provided in the newsletter or by sending a message to the responsible person named above. After your cancellation, your e-mail address will immediately be deleted from our newsletter distribution list, unless you have expressly consented to further use of your data or we reserve the right to use data in excess thereof, which is permitted by law and about which we inform you in this declaration.
8.2 Our e-mail newsletters are sent via the technical service provider, The Rocket Science Group, LLC d/b/a MailChimp, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA (https://mailchimp.com), to whom we pass on the data you provided when registering for the newsletter. This disclosure is made in accordance with Art. 6 (1) point f GDPR and serves our legitimate interest in the use of an effective, secure and user-friendly newsletter system. Please note that your data is usually transferred to a MailChimp server in the USA and stored there.
MailChimp uses this information to send and statistically evaluate the newsletter on our behalf. For evaluation purposes, the e-mails sent contain so-called web beacons or tracking pixels, which represent single-pixel image files stored on our website. This allows us to determine whether a newsletter message has been opened and which links have been clicked on. In addition, technical information is recorded (e.g. time of retrieval, IP address, browser type and operating system). The data is raised exclusively in a pseudonymized format and is not linked with other personal data from you. A direct personal relationship is excluded. This data is used exclusively for statistical analysis of newsletter campaigns. The results of these analyses can be used to better adapt future newsletters to the interests of the recipients.
If you wish to object to the data analysis for statistical evaluation purposes, you must unsubscribe from the newsletter.
Furthermore, MailChimp can use this data according to Art. 6 (1) point f GDPR even on the basis of its own legitimate interest in the demand-oriented design and optimization of the service as well as for market research purposes, for example to determine from which countries recipients come. However, MailChimp does not use the data of our newsletter recipients to address those recipients or pass that data on to third parties.
To protect your data in the USA, we have concluded a data processing agreement ("Data-Processing-Agreement") with MailChimp on the basis of the standard contractual clauses of the European Commission to enable the transmission of your personal data to MailChimp. If you are interested in viewing this data processing agreement, you can do so at the following Internet link: https://mailchimp.com/legal/data-processing-addendum/
9) Processing of Data for the Purpose of Order Handling
9.1 The personal data collected by us will be passed on to the transport company commissioned with the delivery within the scope of contract processing, insofar as this is necessary for the delivery of the goods. We will pass on your payment data to the commissioned credit institution within the framework of payment processing, if this is necessary for payment handling. If payment service providers are used, we explicitly inform you of this below. The legal basis for the transfer of data is Art. 6 (1) point b GDPR.
9.2 We work with external shipping partners to fulfil our contractual obligations to our customers. We pass on your name as well as your delivery address exclusively for the purpose of delivering goods to a shipping partner selected by us, pursuant to Art. 6 (1) point b GDPR.
9.3 Use of Payment Service Providers
- Amazon Pay
- Apple Pay
If you choose the payment method "Apple Pay" of Apple Distribution International (Apple), Hollyhill Industrial Estate, Hollyhill, Cork, Ireland, the payment processing is carried out via the "Apple Pay" function of your terminal device operated with iOS, watchOS or macOS by debiting a payment card deposited with "Apple Pay". Apple Pay uses security features built into the hardware and software of your device to protect your transactions. In order to release a payment, it is therefore necessary to enter a code previously defined by you and to verify it using the "Face ID" or "Touch ID" function of your terminal.
For the purpose of payment processing, your information provided during the ordering process, along with information about your order, will be transmitted to Apple in encrypted form. Apple then encrypts this data again with a developer-specific key before the data is transmitted to the payment service provider of the payment card stored in Apple Pay for payment processing. The encryption ensures that only the website from which the purchase was made can access the payment information. After the payment is made, Apple sends your device account number and a transaction-specific dynamic security code to the originating website to confirm the payment.
If personal data is processed in the described transmissions, the processing is carried out exclusively for the purpose of payment processing in accordance with Art. 6 Para. 1 lit. b GDPR.
Apple retains anonymised transaction data, including the approximate amount of the purchase, the approximate date and time and whether the transaction was completed successfully. Anonymisation completely excludes any personal reference. Apple uses the anonymised data to improve Apple Pay and other Apple products and services.
When you use Apple Pay on iPhone or the Apple Watch to complete a purchase made through Safari on Mac, the Mac and the authorization device communicate through an encrypted channel on Apple's servers. Apple does not process or store this information in any format that can identify you personally. You can disable the ability to use Apple Pay on your Mac in your iPhone preferences. Go to "Wallet & Apple Pay" and disable "Allow payments on Mac".
For more information about Apple Pay privacy, please visit the following web address: https://support.apple.com/en-gb/HT203027
If the payment method "Klarna Rechnungskauf" or (if offered) the payment method "Klarna Installment Purchase" is selected, payment is processed by Klarna AB (publ )[https://www.klarna.com/de], Sveavägen 46, 111 34 Stockholm, Sweden (hereinafter "Klarna"). To enable payment to be processed, your personal data (first and last name, street, house number, postcode, city, gender, e-mail address, telephone number and IP address) as well as data related to the order (e.g. B. Invoice amount, article, delivery type) is forwarded to Klarna for the purpose of identity and creditworthiness check, provided you have expressly consented to this in accordance with Art. 6 (1) point a GDPR within the ordering process. You can view to which credit agencies your data may be forwarded at: http://cdn.klarna.com/1.0/shared/content/legal/terms/Klarna/en_gb/checkout.
The credit report can contain probability values (so-called score values). If score values are included in the result of the credit report, they are based on recognized scientific, mathematical-statistical methods. The calculation of the score values includes, but is not limited to, address data. Klarna uses the information received on the statistical probability of non-payment for a balanced decision on the establishment, implementation or termination of the contractual relationship.
You can revoke your consent at any time by sending a message to the controller responsible for data processing or to Klarna. However, Klarna may still be entitled to process your personal data if this is necessary to process payments in accordance with the contract.
or regarding data subjects located in Austria https://cdn.klarna.com/1.0/shared/content/policy/data/de_at/data_protection.pdf
When a payment method offered via the payment service "mollie" is selected, the payment will be processed via the payment service provider Mollie B.V., Keizersgracht 313, 1016 EE Amsterdam, Netherlands (hereinafter referred to as "mollie"). The individual payment methods offered by mollie are communicated to the Client in the Seller's online shop. For the processing of payments, mollie may make use of other payment services, for which special terms of payment may apply. The Client will be referred to those terms of payment separetely. Further information on "mollie" can be found on the Internet at https://www.mollie.com/en/
When you pay via PayPal, credit card via PayPal, direct debit via PayPal or - if offered - "purchase on account" or "payment by instalments" via PayPal, we transmit your payment data to PayPal (Europe) S.a.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter "PayPal"). The transfer takes place in accordance with Art. 6 (1) point b GDPR and only insofar as this is necessary for payment processing.
PayPal reserves the right to carry out credit checks for the payment methods credit card via PayPal, direct debit via PayPal or, if offered, "purchase on account" or "payment by installments" via PayPal. For this purpose, your payment data may be passed on to credit agencies on the basis of PayPal's legitimate interest in determining your solvency pursuant to Art. 6 (1) point f GDPR. PayPal uses the result of the credit assessment in relation to the statistical probability of non-payment for the purpose of deciding on the provision of the respective payment method. The credit report can contain probability values (so-called score values). If score values are included in the result of the credit report, they are based on recognized scientific, mathematical-statistical methods. The calculation of the score values includes, but is not limited to, address data. For further information on data protection law, including the credit agencies used, please refer to PayPal's data protection declaration at: https://www.paypal.com/uk/webapps/mpp/ua/privacy-full.
You can object to this processing of your data at any time by sending a message to PayPal. However, PayPal may still be entitled to process your personal data if this is necessary for contractual payment processing.
10) Contact for Requesting Customer Rating Information
Our Own Evaluation Reminder (No Dispatch by a Customer Evaluation System)
We use your e-mail address as a one-off reminder for submitting an evaluation of your order using our own evaluation system, provided you have given us your express consent during or after placing your order in accordance with Art. 6 (1) point a GDPR. You can revoke your consent at any time by sending a message to the controller responsible for data processing.
11) Use of Videos
Use of Vimeo Videos
On our website, plugins of the video portal Vimeo of Vimeo, LLC, 555 West 18th Street, New York, New York 10011, USA are embedded. When you access a page of our website that contains such a plugin, your browser establishes a direct connection to Vimeo's servers. The content of the plugin is transmitted by Vimeo directly to your browser and integrated into the page. Through this integration, Vimeo receives the information that your browser has called up the corresponding page of our website, even if you do not have a Vimeo account or are not currently logged in to Vimeo. This information (including your IP address) is transmitted directly from your browser to a Vimeo server in the USA and stored there.
If you are logged in to Vimeo, Vimeo can immediately assign your visit of our website to your Vimeo account. If you interact with the plugins (e.g. pressing the start button of a video), this information is also transmitted directly to a Vimeo server and stored there.
The data processing operations described are carried out in accordance with Art. 6 (1) point f GDPR, on the basis of Vimeo's legitimate interest in market research and the need-based design of the service.
If you do not want Vimeo to assign the data collected via our website directly to your Vimeo account, you must log out of Vimeo before visiting our website.
For videos from Vimeo that are embedded on our site, the tracking tool Google Analytics of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland, is automatically integrated. This relates to Vimeo's own tracking which we do not have access to and which cannot be influenced by our site. Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website will generally be transmitted to and stored by Google on servers in the United States, where it may also be transmitted to servers of Google LLC.
This processing is carried out in accordance with Art. 6 (1) point f GDPR on the basis of Vimeo's legitimate interest in the statistical analysis of user behavior for optimization and marketing purposes.
To the extent required by law, we have obtained your consent to the processing of your data as described in accordance with Art. 6 (1) point a GDPR. You can withdraw your consent at any time with effect for the future. In order to exercise your right of withdrawal, please follow the procedure described above.
12.1 Facebook pixels for creating custom audiences with extended data matching feature
Within our online offer, the so-called "Facebook pixel" of the social network Facebook in extended data matching mode is applied. It is operated by Facebook Ireland Limited, 4 Grand Canal Quare, Dublin 2, Ireland (hereinafter "Facebook").
If a user, who has given his explicit consent, clicks on an advertisement placed by us and played on Facebook, an addition is made to the URL of our linked page by Facebook pixels. This URL parameter is then entered into the user's browser via a cookie after it has been forwarded, which is set by our linked page itself. In addition, this cookie collects specific customer information, such as the email address that we collect on our Facebook-associated website during transactions such as purchases, account signups, or registrations (advanced data matching). The cookie is then read by Facebook Pixel and enables the data, including the specific customer data, to be forwarded to Facebook.
With the help of the Facebook pixel with extended data matching feature, Facebook is able to determine visitors of our online offer as a target group for the presentation of ads (so-called "Facebook ads"). Accordingly, the Facebook pixel with extended data matching feature to display Facebook ads placed by us will be presented only to Facebook users who have shown an interest in our online offer or who demonstrate certain characteristics (e.g. interest in certain topics or products determined by means of the websites visited) which we transmit to Facebook (so-called "custom audiences"). When using Facebook pixels, we also want to ensure that our Facebook ads match the potential interest of users and are not annoying. This allows us to evaluate the effectiveness of Facebook ads for statistical and market research purposes by tracking whether users were forwarded to our website after clicking on a Facebook ad ("conversion"). Compared to the standard variant of Facebook Pixel, the extended data matching feature helps us better measure the effectiveness of our advertising campaigns by tracking more associated conversions.
All transmitted data is stored and processed by Facebook to enable a connection to the respective user profile and to allow Facebook to use the data for its own advertising purposes in accordance with the Facebook Data Usage Guidelines (https://www.facebook.com/about/privacy/). The data may enable Facebook and its partners to place advertisements on and off Facebook.
These processes are subject to express consent in accordance with Art. 6 (1) point a GDPR.
Consent to the use of the Facebook pixel may only be given by users who are older than 13 years of age. If you are younger, please ask your parent or guardian for permission.
The information generated by Facebook is usually transferred to a Facebook server and stored there. This may also result in transmission to the servers of Facebook Inc. in the USA.
You can revoke your consent at any time by disabling Facebook pixel tracking. To do this, you can set an opt-out cookie that disables Facebook pixel tracking by clicking on the link below:
disable Facebook pixels
This opt-out cookie only works in this browser and only for this domain. If you delete your cookies in this browser, you must click on the above link again.
12.2 Google Marketing Platform
This website uses the online marketing tool Google Marketing Platform of the operator Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("GMP").
In addition, GMP can use cookie IDs to record so-called conversions that relate to ad requests. This is the case, for example, when a user sees a GMP advertisement and later, using the same browser, calls up the advertiser's website and makes a purchase via this website. According to Google, GMP cookies contain no personal information.
Due to the marketing tools used, your browser automatically establishes a direct connection with the Google server. We have no influence on the scope and further use of the data collected by Google through the use of these tools and therefore inform you as follows according to our state of knowledge: By integrating GMP, Google receives the information that you have called up the corresponding part of our website or clicked on an advertisement from us. If you are registered with a Google service, Google can allocate the visit to your account. Even if you are not registered with Google or have not logged in, it is possible that the provider will find out and save your IP address. In the context of the use of GMP, personal data may also be transmitted to the servers of Google LLC. in the USA.
If you wish to object to this tracking procedure, you can deactivate cookies for conversion tracking by setting your browser to block cookies from the domain www.googleadservices.com (see https://www.google.de/settings/ads), this setting will be deleted when you deactivate your cookies. Alternatively, you can contact the Digital Advertising Alliance at www.aboutads.info to find out how to set cookies and to adjust your desired settings. Finally, you can set your browser so that you are informed about the setting of cookies and can decide individually whether to accept them or to exclude the acceptance of cookies for certain cases or in general. If cookies are not accepted, the functionality of our website may be limited.
You can obtain further information about the data protection regulations of GMP by Google at the following Internet address: https://www.google.de/policies/privacy/
Insofar as legally required, we have obtained your consent for the processing of your data as described above in accordance with Art. 6 para. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future. In order to exercise your revocation, please follow the above-mentioned procedure for lodging an objection.
13) Web Analysis Services
13.1 Google (Universal) Analytics with Google Signals
This website uses Google (Universal) Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"). Google (Universal) Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website (including the abbreviated IP address) is usually transferred to a Google server and stored there, and may also be transferred to the servers of Google LLC. in the USA.
This website uses Google (Universal) Analytics exclusively with the extension "_anonymizeIp()", which ensures anonymization of the IP address by shortening it and excludes the possibility of direct personal reference. Through the extension, your IP address will be shortened by Google within member states of the European Union or in other signatory states of the Agreement on the European Economic Area before. Only in exceptional cases will the full IP address be transferred to a server of Google LLC. in the USA and shortened there.
On our behalf, Google will use this information to evaluate your use of the website, to compile reports on the website activities and to provide us with further services related to the use of the website and the Internet. The IP address transmitted by your browser within the framework of Google (Universal) Analytics is not combined with other Google data.
Via a special function called "Demographics", Google Analytics also enables the compilation of statistics with statements about the age, gender and interests of site visitors based on an evaluation of interest-related advertising and with the use of third-party information. This allows the definition and differentiation of user groups of the website for the purpose of target-group-optimized marketing measures. However, data sets collected via "Demographics" cannot be assigned to a specific person.
All the processing described above, in particular the setting of Google Analytics cookies for reading information on the terminal device used, is only carried out if you have given us your express consent in accordance with Art. 6 Para. 1 letter a GDPR. Without this consent, the use of Google Analytics during your visit to our website will not take place.
You can withdraw your consent at any time with effect for the future. To exercise your right of withdrawal of consent, please deactivate this service in the "Cookie-Consent-Tool" provided on the website. We have concluded a data processing agreement with Google for the use of Google Analytics, which obliges Google to protect the data of our site visitors and not to pass it on to third parties.
For the transmission of data from the EU to the USA, Google relies on so-called standard data protection clauses of the European Commission, which are intended to ensure compliance with the European data protection level in the USA.
Further information about Google (Universal) Analytics can be found here: https://policies.google.com/privacy?hl=en&gl=en
This website also uses the Google Signals service as an extension of Google Analytics. With Google Signals, we can have Google generate cross-device reports (so-called "cross device tracking"). If you have activated "personalized ads" in your settings in your Google Account and you have linked your Internet-capable devices to your Google Account, Google can analyze user behavior across devices and create database models based on this, provided that you have given the appropriate consent for the use of Google Analytics in accordance with Art. 6 para. 1 letter a GDPR (see above). The registrations and device types of all visitors to the site who were logged into a Google account and have performed a conversion are taken into account. The data shows, among other things, on which device you clicked on a display for the first time and on which device the corresponding conversion took place. We do not receive any personal data from Google, but only statistics based on Google Signals. You have the option of deactivating the "personalized ads" function in the settings of your Google account and thus turn off the cross-device analysis. To do so, follow the instructions on this page: https://support.google.com/ads/answer/2662922?hl=en
Further information about Google Signals can be found here: https://support.google.com/analytics/answer/7532985?hl=en
This website uses the Hotjar web analysis service of Hotjar Ltd. Hotjar Ltd. is a European company based in Malta (Hotjar Ltd, Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Europe Tel.: +1 (855) 464-6788).
This tool enables us to retrace movements on our website, on which Hotjar is deployed (so-called heatmaps). For example, it explains how far users scroll and which buttons they click and how often. Furthermore, it is possible, when using this tool, to get feedback directly from our website users.
In this way, We are provided with valuable information to make our websites even faster and more customer-friendly. The above analysis is carried out on the basis of our legitimate interests in optimization and marketing purposes and in interest-based design of our website in accordance with art. 6 (1) point f GDPR. We pay particular attention to the protection of your personal data when using this tool. Therefore, we only can retrace which buttons you click and how far you scroll. Areas of sites that may contain personal information about you or third parties are automatically hidden by Hotjar and cannot be retraced at any time.
With the help of a "Do Not Track Headers", Hotjar gives every user the opportunity to prevent the Hotjar tool from being used, so that no data about the visit of the respective website is recorded. It is a setting that all common browsers in up-dated versions support. To this end, your browser sends a request to Hotjar, demanding the tracking of the respective user to be deactivated. If you visit our website with different browsers/computers, you must use the "Do Not Track Header" for each browser/computer separately.
For more detailed instructions and information about your browser, please refer to: https://www.hotjar.com/opt-out.
For more information about Hotjar Ltd. and the Hotjar tool, please refer to: https://www.hotjar.com
To the extent required by law, we have obtained your consent to the processing of your data as described in accordance with Art. 6 (1) point a GDPR. You can withdraw your consent at any time with effect for the future. In order to exercise your right of withdrawal, please follow the procedure described above.
14) Tools and Miscellaneous
14.1 Google reCAPTCHA
On this website we also use the reCAPTCHA function of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"). This function is mainly used to distinguish whether an entry is made by a natural person or misused by automatic and automated processing. The service includes the sending of the IP address and possibly other data required by Google for the reCAPTCHA service to Google and is carried out in accordance with Art. 6 (1) point f GDPR, on the basis of our legitimate interest in determining the individual willingness of actions on the Internet and avoiding misuse and spam.
14.2 Google Maps
Our website uses Google Maps (AP’I) of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland (“Google”). Google Maps is a web service for displaying interactive (country) maps in order to display geographical information visually. Using this service will show you our location and will make it easier for you to find us.
When you access the sub-pages that contain the Google Maps map, information about your use of our website (such as your IP address) is transmitted to and stored by Google on servers. When using Google Maps, personal data may also be transmitted to the servers of Google LLC. in the USA. This is regardless of whether Google provides a user account that you are logged in with or whether no user account exists. If you are logged in to Google, your information will be directly associated with your account. If you do not wish to be associated with your profile on Google, you must log out before activating the button. Google saves your data (even for users who are not logged in) as usage profiles and evaluates them. Such an evaluation takes place according to Art. 6 (1) point f GDPR, on the basis of the legitimate interests of Google in the insertion of personalized advertising, market research and/or demand-oriented design of its website. You have the right to object to the creation of these user profiles. If you want to do so, you must contact Google to exercise this right.
To the extent required by law, we have obtained your consent to the processing of your data as described above in accordance with Art. 6 (1) point a GDPR. You can revoke your consent at any time with effect for the future. In order to exercise your revocation, please follow the procedure described above for submitting an objection.
14.3 - Google Web Fonts
This site uses web fonts provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google") to uniformly display fonts. When you call up a page, your browser loads the required web fonts into its browser cache to display texts and fonts correctly.
To do this, the browser you are using must have a connection to Google's servers. When using Google Maps, personal data may also be transmitted to the servers of Google LLC. in the USA. In this way, Google will be informed that our website has been accessed via your IP address. Google Web Fonts are used for the purpose of a uniform and attractive presentation of our online offers and its use is in our legitimate interest within the meaning of Art. 6 (1) point f GDPR. If your browser does not support web fonts, a default font is used by your computer.
14.4 Applications for job advertisements by e-mail
On our website, we advertise current vacancies in a separate section, for which interested parties can apply by e-mail using the contact address provided.
If applicants want to be included in the application process, they must provide us with all personal details required for a well-founded and informed assessment and selection in conjunction with their application by e-mail.
The required data should include general personal information (name, address, telephone or electronic contact) as well as performance-specific evidence showing the qualifications required for the advertised position. In addition, health-related information may be required, which in the interest of social protection must be given special attention to regarding the applicant's person according to labor and social law.
The components an application must contain to be considered and the form in which these components must be sent by e-mail can be found in the respective job advertisement.
After receipt of the application sent using the e-mail contact address supplied, the applicant data will be stored by us and evaluated exclusively for the purpose of processing the application. In the event of queries arising in the course of processing the application, we will use either the e-mail address supplied by the applicant with his application or a telephone number supplied, at our discretion.
The legal basis for such processing, including the contacting of applicants for queries, is basically Art. 6 (1) point b GDPR in conjunction with Art. 26 (1) Federal Data Protection Act. According to these provisions, the completion of the application procedure is deemed to be the initiation of an employment contract.
If special categories of personal data within the meaning of Art. 9 (1) GDPR (e.g. health data such as information on severely disabled status) are requested from applicants as part of the application procedure, processing will take place in accordance with Art. 9 (2) point b GDPR, so as to enable us to exercise the rights arising from labor law, social security and social protection law and to fulfil our obligations in this regard.
The processing of special categories of data may also be based cumulatively or alternatively on Art. 9 (1) point h GDPR if it is used for the purposes of health care or occupational medicine, for the assessment of the applicant's ability to work, for medical diagnostics, health or social care or for the management of systems and services in the health or social sector.
If, in the course of the evaluation described above, the applicant is not selected or if an applicant withdraws his application prematurely, his data transmitted by e-mail as well as all electronic correspondence including the original application e-mail will be deleted at the latest after 6 months following a corresponding notification. This period shall be determined on the basis of our legitimate interest in being able to answer any follow-up questions regarding the application and, if necessary, to comply with our obligation to provide evidence under the regulations governing the equal treatment of applicants.
In the event of a successful application, the data provided will be processed on the basis of Art. 6 (1) point b GDPR in conjunction with Art. 26 (2) Federal Data Protection Act for the purposes of implementing the employment relationship.
15) Rights of the Data Subject
15.1 The applicable data protection law grants you the following comprehensive rights of data subjects (rights of information and intervention) vis-à-vis the data controller with regard to the processing of your personal data:
- Right of access by the data subject pursuant to Art. 15 GDPR: You shall have the right to receive the following information: The personal data processed by us; the purposes of the processing; the categories of processed personal data; the recipients or categories of recipients to whom the personal data have been or will be disclosed; the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing personal data concerning the data subject or to object to such processing; the right to lodge a complaint with a supervisory authority; where the personal are not collected from the data subject, any available information as to their source; the existence of automated decision-making, including profiling and at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject; the appropriate safeguards pursuant to Article 46 when personal data is transferred to a third country.
- Right to rectification pursuant to Art. 16 GDPR: You have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning you and/or the right to have incomplete personal data completed which are stored by us.
- Right to erasure (“right to be forgotten”) pursuant to Art. 17 GDPR: You have the right to obtain from the controller the erasure of personal data concerning you if the conditions of Art. 17 (2) GDPR are fulfilled. However, this right will not apply for exercising the 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.
- Right to restriction of processing pursuant to Art. 18 GDPR: You have the right to obtain from the controller restriction of processing your personal data for the following reasons: As long as the accuracy of your personal data contested by you will be verified. If you oppose the erasure of your personal data because of unlawful processing and you request the restriction of their use instead. If you require the personal data for the establishment, exercise or defense of legal claims, once we no longer need those data for the purposes of the processing. If you have objected to processing on grounds relating to your personal situation pending the verification whether our legitimate grounds override your grounds.
- Right to be informed pursuant to Art. 19 GDPR: If you have asserted the right of rectification, erasure or restriction of processing against the controller, he is obliged to communicate to each recipient to whom the personal date has been disclosed any rectification or erasure of personal data or restriction of processing, unless this proves impossible or involves disproportionate effort. You have the right to be informed about those recipients.
- Right to data portability pursuant to Art. 20 GDPR: You shall have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format or to require that those data be transmitted to another controller, where technically feasible.
- Right to withdraw a given consent pursuant to Art. 7 (3) GDPR: You have the right to withdraw your consent for the processing of personal data at any time with effect for the future. In the event of withdrawal, we will immediately erase the data concerned, unless further processing can be based on a legal basis for processing without consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
- Right to lodge a complaint pursuant to Art. 77 GDPR: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.
15.2 RIGHT TO OBJECT
IF, WITHIN THE FRAMEWORK OF A CONSIDERATION OF INTERESTS, WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR PREDOMINANT LEGITIMATE INTEREST, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON THE GROUNDS THAT ARISE FROM YOUR PARTICULAR SITUATION.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO FURTHER PROCESSING IF WE CAN PROVE COMPELLING REASONS WORTHY OF PROTECTION FOR PROCESSING WHICH OUTWEIGH YOUR INTERESTS, FUNDAMENTAL RIGHTS AND FREEDOMS, OR IF THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS.
IF WE PROCESS YOUR PERSONAL DATA FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA WHICH ARE USED FOR DIRECT MARKETING PURPOSES. YOU MAY EXERCISE THE OBJECTION AS DESCRIBED ABOVE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT ADVERTISING PURPOSES.
16) Duration of Storage of Personal Data
The duration of the storage of personal data is based on the respective legal basis, the purpose of processing and - if relevant – on the respective legal retention period (e.g. commercial and tax retention periods).
If personal data is processed on the basis of an express consent pursuant to Art. 6 (1) point a GDPR, this data is stored until the data subject revokes his consent.
If there are legal storage periods for data that is processed within the framework of legal or similar obligations on the basis of Art. 6 (1) point b GDPR, this data will be routinely deleted after expiry of the storage periods if it is no longer necessary for the fulfillment of the contract or the initiation of the contract and/or if we no longer have a justified interest in further storage.
When processing personal data on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection in accordance with Art. 21 (1) GDPR, unless we can provide compelling grounds for processing worthy of protection which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.
If personal data is processed for the purpose of direct marketing on the basis of Art. 6 (1) point f GDPR, this data is stored until the data subject exercises his right of objection pursuant to Art. 21 (2) GDPR.
Unless otherwise stated in the information contained in this declaration on specific processing situations, stored personal data will be deleted if it is no longer necessary for the purposes for which it was collected or otherwise processed.