Grigori Afxentiou, 11
CENTRO IMPERIO, 2nd floor, Flat/Office 201
Mesa Geitonia, 4003, Limassol, Cyprus
E-mail address: email@example.com
Directors and shareholders:
N. Maximilian Stefan Henry West phal
Wai Ki Tang
Types of processed data:
- Personal data (e.g., names, addresses).
- contact information (e.g., e-mail, phone numbers).
- content data (e.g., text input, photographs, videos).
- usage data (e.g., websites visited, interest in content, access times).
- Meta / communication data (e.g., device information, IP addresses).
Categories of affected persons
Visitors and users of the online offer (hereinafter we refer to the affected persons as "users").
Purpose of processing:
- Provision of the online offer, its functions and contents.
- Answering contact requests and communicating with users.
- Safety measures.
- Reach Measurement / Marketing
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter the "data subject"); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (eg cookie) or to one or more special features, that express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.
"Processing" means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term goes far and includes virtually every handling of data.
"Pseudonymisation" means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data not assigned to an identified or identifiable natural person.
"Profiling" means any kind of automated processing of personal data which involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to job performance, economic situation, health, personal To analyze or predict preferences, interests, reliability, behavior, whereabouts or relocation of that natural person.
"Responsible person" means the natural or legal person, public authority, body or body that decides, alone or in concert with others, on the purposes and means of processing personal data.
"Processor" means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 DSGVO, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 (1) lit. b DSGVO, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c DSGVO, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f DSGVO. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO as legal basis.
In accordance with Art. 32 GDPR, we shall take into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing and testing the degree of likelihood and severity of the risk to the rights and freedoms of natural persons, and the appropriate technical and organizational measures to ensure a level of protection commensurate with the risk. The measures include, in particular, ensuring the confidentiality, integrity and availability of data through physical access control the data, as well as their access, input, disclosure, securing of availability and their separation. We have also set up procedures to ensure the enjoyment of data subject rights, data deletion and data vulnerability. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings (Article 25 GDPR).
Collaboration with contract processors and third parties
In the context of our processing disclose data to other persons and companies (contract processors or third parties), transmit them to them or otherwise grant them access to the data, this is done only on the basis of a legal permission (eg if a transmission of data to third parties, such as payment service providers, acc. Art. 6 para. 1 lit. b DSGVO is required to fulfill the contract), you have consented to a legal obligation or on the basis of our legitimate interests (eg the use of agents, webhosters, etc.). Insofar as we commission third parties to process data on the basis of a so-called "contract processing contract", this is done on the basis of Art. 28 GDPR.
Transfers to third countries
If we use data in a third country (ie outside the European Union (EU) or the European Economic Area ( EEA)) or in the context of the use of third party services or disclosure, or transmission of data to third parties, this is done only if it is to fulfill our (pre) contractual obligations, based on your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of Art. 44 et seq. DSGVO. That the processing is e.g. on the basis of specific guarantees, such as the officially recognized level of data protection (eg for the US through the "Privacy Shield") or the observance of officially recognized special contractual obligations (so-called "standard contractual clauses".)
Rights of data subjects
You have the right to to ask for a confirmation as to whether the data in question are being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR. Art. 16 DSGVO the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you. In accordance with Art. 17 GDPR you have the right to demand that the data in question be deleted immediately or alternatively as stipulated You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 GDPR and request their transmission to other persons responsible. You have based on Art. 77 DSGVO the right to file a complaint with the competent supervisory authority.
You have the right to withdraw your consent granted in accordance with. Art. 7 para. 3 DSGVO with effect for the future
You may revoke the future processing of your data in accordance with Art. 21 GDPR at any time. The objection may in particular be made against processing for the purpose of direct advertising.
Cookies and right of objection in the case of direct advertising
Deletion of data
Additional We process contract data (eg, subject matter, term, customer category). - Payment data (eg, bank details, payment history) from our customers, prospects and business partners for the purpose of providing contractual services, customer care and service, marketing, advertising and market research.
Order processing in the online shop and customer account
We process the data of our customers during the ordering process in our online shop to enable them to select and order the selected products and services, as well as their payment and delivery, or execution. The processed data includes inventory data, communication data, contract data, payment data and persons affected by the processing belong to our customers, prospects and other business partners. Processing is for the purpose of providing contractual services in the context of the operation of an online shop, billing, delivery and customer service. Here we use session cookies for the storage of the shopping cart contents and permanent cookies for the storage of the login status. Processing is based on Art. 6 para. 1 lit. b (execution of order transactions) and c (legally required archiving) DSGVO. The information marked as required for the establishment and fulfillment of the contract is required. We disclose the data to third parties only in the context of extradition, payment or in the context of legal permissions and obligations to legal advisors and authorities. The data will be processed in third countries only if necessary for the fulfillment of the contract (for example, on customer's request upon delivery or payment). Users can optionally create a user account, in particular by being able to view their orders. As part of the registration, the necessary mandatory information will be communicated to the users. The user accounts are not public and can not be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to their retention is for commercial or tax law reasons according to Art. 6 para. 1 lit. c DSGVO necessary. Information in the customer account remains until its deletion with subsequent archiving in case of a legal obligation. It is the responsibility of the users to secure their data upon termination before the end of the contract. As part of the registration and re-registration and use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user's protection against misuse and other unauthorized use. A transfer of these data to third parties does not take place, unless it is necessary for the prosecution of our claims or there is a legal obligation in accordance with. Art. 6 para. 1 lit. c DSGVO. The deletion takes place after expiry of legal warranty and comparable obligations, the necessity of keeping the data is checked every three years; in the case of legal archiving obligations, the deletion takes place after its expiration (end commercial law (6 years) and taxable (10 years) retention).
External payment service providers
Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks and organization of our operations, financial accounting and compliance with legal obligations, such. archiving. In doing so, we process the same data that we process in the course of rendering our contractual services. The processing principles are Art. 6 para. 1 lit. c. DSGVO, Art. 6 para. 1 lit. f. DSGVO. The processing affects customers, prospects, business partners and website visitors. The purpose and interest in processing lies in administration, financial accounting, office organization, data archiving, that is, tasks that serve to maintain our business, perform our duties and provide our services. The deletion of the data in terms of contractual performance and contractual communication corresponds to the information provided in these processing activities. We disclose or transmit data to the financial administration, consultants, such as tax accountants or auditors, and other fee agents and payment service providers. Furthermore, based on our business interests, we store information about suppliers, promoters and other business partners, e.g. for later contact. This majority of company-related data, we store in principle durably.
Business economics analysis and market research
In order to operate our business economically, to be able to identify market trends, wishes of the contractors and users, we analyze the data we have on business transactions, contracts, inquiries, etc. We process stock data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. DSGVO, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offer. The analyzes are carried out for the purpose of business analysis, marketing and market research. In doing so, we can provide the profiles of registered users with information, e.g. take into account their services. The analyzes serve us to increase the user-friendliness, the optimization of our offer and the business economics. The analyzes are for us alone and will not be disclosed externally unless they are anonymous, aggregated value analyzes. If these analyzes or profiles are personal, they will be deleted or anonymised upon termination of the users, otherwise after two years from the conclusion of the contract. Incidentally, the overall economic analysis and general trend provisions are created anonymously if possible.
Participation in Affiliate Affiliate Programs
Within our online offer, we rely on our legitimate interests (i.e., interest in the analysis, optimization and economic operation of our online offer) acc. Art. 6 para. 1 lit. f DSGVO industry-standard tracking measures as required for the operation of the affiliate system. Below we clarify the users about the technical background. The services offered by our contractual partners can also be advertised and linked to other websites (so-called affiliate links or after-buy systems, if, for example, links or services of third parties are offered after conclusion of a contract). The operators of the respective websites receive a commission if users follow the affiliate links and then take advantage of the offers. In summary, our online offering requires us to be able to keep track of whether users who are interested in affiliate links and / or the offers available to us then take advantage of the offers on the affiliate links or on our online platform. For this, the affiliate links and our offers are supplemented by certain values that are part of the link or otherwise, e.g. in a cookie, can be set. The values include in particular the source website (referrer), time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking specific values such as Ad ID, affiliate ID, and categorizations. The online user IDs used by us are pseudonymous values. That the online identifiers themselves do not contain personal data such as names or e-mail addresses. They only help us determine whether the same user who clicked on an affiliate link or was interested in an offer through our online offer, perceived the offer, i. e.g. has signed a contract with the provider. However, the online identification is personal in so far as the partner company and also us, the online identification together with other user data are available. Only then can the partner company tell us whether the user has accepted the offer and we, for example, The bonus can be paid.
Privacy Notice in the application process
Users can create a user account. As part of the registration, the required mandatory information is communicated to the users and based on Art. 6 para. 1 lit. b DSGVO processed for purposes of providing the user account. The processed data include in particular the login information (name, password and an e-mail address). The data entered during registration will be used for the purpose of using the user account and its purpose. Users may have access to information relevant to their user account, e.g. technical changes, be informed by e-mail. If users have terminated their user account, their data will be deleted with respect to the user account, subject to a statutory retention requirement. It is the responsibility of the users to secure their data upon termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract. As part of the use of our registration and registration functions as well as the use of the user account, the IP address and the time of the respective user action will be saved. The storage is based on our legitimate interests, as well as the user's protection against misuse and other unauthorized use. A transfer of these data to third parties does not take place, unless it is necessary for the prosecution of our claims or there is a legal obligation in accordance with. Art. 6 para. 1 lit. c DSGVO. The IP addresses are anonymized or deleted after 7 days at the latest.
Comments and contributions
If users leave comments or other contributions, their IP addresses may be based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO be stored for 7 days. This is for our own safety, if someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author. Furthermore, we reserve the right, in accordance with our legitimate interests. Art. 6 para. 1 lit. f. DSGVO to process the information of users for the purpose of spam detection. The data provided in the comments and contributions, are stored by us until the opposition of the user durably.
By contacting us (eg by contact form, e-mail, telephone or via social media) are the information of the user to process the contact request and their settlement gem. Art. 6 para. 1 lit. b) DSGVO processed. User information can be stored in a Customer Relationship Management System ("CRM System") or comparable request organization. We delete the requests, if they are no longer required. We check the necessity every two years; Furthermore, the legal requirements for archiving.
With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures as well as your right of objection. By subscribing to our newsletter, you agree to the receipt and the procedures described. Content of the newsletter: We send newsletters, e-mails and other electronic notifications with advertising information (hereinafter "newsletter") only with the consent of the recipient or a legal permission. Insofar as the contents of a newsletter are concretely described, they are authoritative for the consent of the users. Incidentally, our newsletter contains information about our services and us. Double opt-in and logging: Registration for our newsletter is done in a so-called double-opt-in procedure. That After registration, you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. The registration for the newsletter will be logged in order to prove the registration process according to the legal requirements. This includes the storage of the login and the confirmation time, as well as the IP address. Likewise, changes to your data stored with the shipping service provider will be logged. Credentials: To subscribe to the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to give a name in the newsletter for personal address. The dispatch of the newsletter and the related performance measurement is based on the consent of the recipient gem. Art. 6 para. 1 lit. a, Art. 7 DSGVO in connection with § 7 Abs. 2 Nr. 3 UWG or on the basis of the legal permission according to Art. § 7 Abs. 3 UWG. The logging of the registration process is based on our legitimate interests in accordance with. Art. 6 para. 1 lit. f DSGVO. Our interest lies in the use of a user-friendly and secure newsletter system, which serves both our business interests and the expectations of the users and also allows us to prove our consent. Termination / Revocation - You may terminate the receipt of our newsletter at any time, ie. Revoke your consent. A link to cancel the newsletter can be found at the end of each newsletter. We may save the submitted email addresses for up to three years based on our legitimate interests before we delete them to provide prior consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for cancellation is possible at any time, provided that the former existence of a consent is confirmed at the same time.
Newsletter - Mailchimp
Newsletter - Success Measurement
The newsletters contain a so-called "web beacon", i. a pixel-sized file that is retrieved from the server when opening the newsletter from our server, or if we use a shipping service provider. This call will initially collect technical information, such as information about the browser and your system, as well as your IP address and time of retrieval. This information is used to improve the technical performance of services based on their specifications or audience and their reading habits, based on their locations (which can be determined using the IP address) or access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our goal nor, if used, that of the shipping service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to deliver different content according to the interests of our users.
The hosting services we use are for the purpose of providing the following services: Infrastructure Platform services, computing capacity, storage space and database services, security and technical maintenance services we use to operate this online offer. Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer acc. Art. 6 para. 1 lit. f DSGVO i.V.m. Art. 28 DSGVO (conclusion of contract processing contract).
Collection of access data and logfiles
We, or our hosting provider, collects on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO Data on every access to the server on which this service is located (so-called server log files). The access data includes name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider , Logfile information is stored for security purposes (for example, to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Any information that is required for further evidence is excluded from the removal until final resolution of the incident.
Content Delivery Network by Fastly Inc.We use a Content Delivery Network (CDN) provided by Fastly Inc. 475 Brannan St. #300, San Francisco, CA 94107, United States. Fastly is certified under the Privacy Shield Agreement, providing a guarantee to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnZKAA0&status=Active). A CDN is a service that helps deliver content from our online offering, especially large media files, such as graphics or scripts, using regionally distributed and Internet-connected servers. The processing of the data of the users takes place solely on the aforementioned ticks and the maintenance of the security and functionality of the CDN. For more information, please refer to Fastly's terms of service: https://www.fastly.com/terms/
Target-grouping with Google Analytics
We use Google Analytics to display the ads displayed within Google's advertising services and its affiliates, only to those who have shown an interest in our online offering or that have certain characteristics (eg interests in certain topics or products that are determined by the websites visited) that we transmit to Google (so-called "remarketing" or "Google Analytics audiences"). With the help of the Remarketing Audiences, we also want to ensure that our ads meet the potential interest of the users.
Google AdWords and Conversion Metering
Social Media Online Presentations
Incorporation of third-party services and content
We rely on our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f) within our online offer . DSGVO) content or service offers from third party providers to their content and services, such as Include videos or fonts (collectively referred to as "content"). This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the device of the user and include technical information about the browser and operating system, referring websites, visit time and other information on the use of our online offer, and they may as well be connected with such information from different sources.
Using Facebook Social Plugins