1. An overview of data protection

General information

The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration below.

Data recording on this website

Who is the responsible party for the recording of data on this website (i.e. the “controller”)?

The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.

Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g. web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the error-free provision of the website. Other data may be used to analyze your user patterns.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.

Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.

Analysis tools and tools provided by third parties

There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs.

For detailed information about these analysis programs please consult our Data Protection Declaration below.

2. Hosting and Content Delivery Networks (CDN)

External Hosting

This website is hosted by an external service provider (host). Personal data collected on this website are stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site.

The external hosting serves the purpose of fulfilling the contract with our potential and existing customers (Art. 6 para. 1 lit. b GDPR) and in the interest of secure, fast, and efficient provision of our online services by a professional provider (Art. 6 para. 1 lit. f GDPR).

Our host will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data.

We are using the following host:

Cloudways Ltd., Junction Business Centre, 1st Floor Sqaq Lourdes, St Julians STJ3334, Malta.

Data processing

We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

Cloudways Ltd. has been acquired by DigitalOcean, LLC, 101 6th Avenue of the Americas, 10th Floor, New York, NY 10013 USA.

Sub-processors

Cloudways is a managed cloud hosting solution, and they provide the platform for hosting our website on Amazon Web Services (AWS) infrastructure. A detailed list of Cloudways Ltd.’s sub-processors is available upon request.

Personal data will be shared with Amazon.com, Inc. (Headquartered in Seattle, Washington, United States, Amazon.com, Inc. is an international organization with locations in the USA and all around the world.).

Here is a link to a page about Amazon.com, Inc.'s sub-processors: https://aws.amazon.com/compliance/sub-processors/

Data transfer to the US is based on the Standard Contractual Clauses (SCC) of the European Commission.

Privacy Policy (Amazon AWS): https://aws.amazon.com/privacy/

For more information about the handling of user data by Cloudways Ltd., please consult their Privacy Policy on: https://www.cloudways.com/en/terms.php#privacy.

As an alternative secondary solution, we may use InMotion Hosting, Inc., 360 N. Pacific Coast Highway, Suite 1055 El Segundo, CA 90245, USA.

Data processing

We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

Sub-processors

InMotion Hosting, Inc. keep a public list of their sub-processors on this page: https://www.inmotionhosting.com/compliance/sub-processors.

For more information about the handling of user data by InMotion Hosting, Inc., please consult their Privacy Policy on: https://www.inmotionhosting.com/privacy/.

Cloudflare

We use the “Cloudflare” service provided by Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA (hereinafter referred to as “Cloudflare”).

Cloudflare offers a content delivery network with DNS that is available worldwide. As a result, the information transfer that occurs between your browser and our website is technically routed via Cloudflare’s network. This enables Cloudflare to analyze data transactions between your browser and our website and to work as a filter between our servers and potentially malicious data traffic from the Internet. In this context, Cloudflare may also use cookies or other technologies deployed to recognize Internet users, which shall, however, only be used for the herein described purpose.

The use of Cloudflare is based on our legitimate interest in a provision of our website offerings that is as error-free and secure as possible (Art. 6 para. 1 lit. f GDPR).

Data transfer to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.cloudflare.com/privacypolicy/ and https://www.cloudflare.com/cloudflare-customer-scc/.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

Sub-processors

Cloudflare Inc. keep a public list of their sub-processors for the Cloudflare service on this page: https://www.cloudflare.com/gdpr/subprocessors/.

For more information on Cloudflare’s security precautions and data privacy policies, please follow this link: https://www.cloudflare.com/privacypolicy/.

3. General and mandatory information

Data protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration.

Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected.

We herewith advise you that the transmission of data via the Internet (i.e. through email communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.

Information about the responsible party (referred to as the “controller” in the GDPR)

The data processing controller on this website is:

Patrick Todorov

SYMPLACT LTD

Wilna zona trakata, ul. 28-ma no. 16

9006 Varna, Bulgaria

Phone: +359885580379

Email: [email protected]

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g. names, email addresses, etc.).

Storage duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

General information on the legal basis for the data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6 para. 1 lit. a GDPR, or Art. 9 para. 2 lit. a GDPR, if special categories of data are processed according to Art. 9 para. 1 GDPR. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49 para. 1 lit. a GDPR. The given consent can be revoked at any time for the future. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6 para. 1 lit. b GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6 para. 1 lit. c GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6 para. 1 lit. f GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

Information on data transfer to the USA and other non-EU countries

Among other things, we use tools of companies domiciled in the United States or other from a data protection perspective non-secure non-EU countries. If these tools are active, your personal data may potentially be transferred to these non-EU countries and may be processed there. We must point out that in these countries, a data protection level that is comparable to that in the EU cannot be guaranteed. For instance, U.S. enterprises are under a mandate to release personal data to the security agencies and you as the data subject do not have any litigation options to defend yourself in court. Hence, it cannot be ruled out that U.S. agencies (e.g., the Secret Service) may process, analyze, and permanently archive your personal data for surveillance purposes. We have no control over these processing activities.

Recipients of personal data

In the scope of our business activities, we cooperate with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only disclose personal data to external parties if this is required as part of the fulfillment of a contract, if we are legally obligated to do so (e.g., disclosure of data to tax authorities), if we have a legitimate interest in the disclosure pursuant to Art. 6 (1)(f) GDPR, or if another legal basis permits the disclosure of this data. When using processors, we only disclose personal data of our customers on the basis of a valid contract on data processing. In the case of joint processing, a joint processing agreement is concluded.

Revocation of your consent to the processing of data

A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6 PARA. 1 LIT. E OR F GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21 PARA. 1 GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21 PARA. 2 GDPR).

Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data at any time. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.

Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:

- In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.

- If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data instead of demanding the eradication of this data.

- If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.

- If you have raised an objection pursuant to Art. 21 para. 1 GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

Encrypted payment transactions on this website

If you are under an obligation to share your payment information (e.g. account number if you give us the authority to debit your bank account) with us after you have entered into a fee-based contract with us, this information is required to process payments.

Payment transactions using common modes of paying (Visa/MasterCard, debit to your bank account) are processed exclusively via encrypted SSL or TLS connections. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the communication with us is encrypted, third parties will not be able to read the payment information you share with us.

Rejection of unsolicited emails

We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in our legal policies to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.

4. Recording of data on this website

Cookies

Our websites and pages use what the industry refers to as “cookies”. Cookies are small data packages that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.

Cookies can be issued by us (first-party cookies) or by third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies into websites (e.g., cookies for handling payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of these cookies (e.g., the shopping cart function or the display of videos). Other cookies may be used to analyze user behavior or for promotional purposes.

Cookies which are required for the performance of electronic communication transactions, for the provision of certain functions you want to use (functional cookies, e.g. for the shopping cart function), or those that are necessary for the optimization of the website (e.g. cookies that provide measurable insights into the web audience) (required cookies), shall be stored on the basis of Art. 6 para. 1 lit. f GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error-free and optimized provision of the operator’s services. If your appropriate consent to the storage of the cookies and similar recognition technologies has been obtained, processing occurs exclusively on the basis of the consent obtained (Art. 6 para. 1 lit. a GDPR); the given consent may be revoked at any time for the future.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited. Please refer to the following link to find instructions on how to deactivate browser cookies on your device: https://www.cookiesandyou.com/disable-cookies/

This privacy policy informs you about the cookies and services that are used on this website.

Borlabs consent technology

Our website uses the Borlabs consent technology to obtain and document your agreement to our Terms and Conditions of Service, as well as to process your privacy settings (including obtaining your consent to the use of services which establish connections to third-party servers and your consent to the storage of certain cookies in your browser or for the use of certain technologies) and for their data privacy protection compliant documentation. The Borlabs Privacy Settings box is also used to inform website visitors about our privacy practices. The provider of this technology is Borlabs GmbH, Rübenkamp 32, 22305 Hamburg, Germany (hereinafter referred to as "Borlabs").

Whenever you submit your Privacy Settings on this website, a Borlabs cookie, which archives any declarations or revocations of consent you may have entered, will be set in your browser (unless a Borlabs cookie for this website is already set in your browser). These data are not shared with the provider of the Borlabs technology.

The recorded data shall remain archived until you ask us to eradicate them, delete the Borlabs cookie on your own, or the purpose of storing the data no longer exists. This shall be without prejudice to any retention obligations mandated by law. To review the details of Borlabs’ data processing policies, please visit https://borlabs.io/kb/what-information-does-borlabs-cookie-store/.

We use the Borlabs consent technology to inform website visitors about our privacy practices, to obtain and document the declarations of consent mandated by law regarding user privacy, and to obtain and document declarations of agreement to our Terms and Conditions of Service. The legal basis for the processing of personal data and use of such cookies is Art. 6 para. 1 Sentence 1 lit. c GDPR.

Server log files

The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

- The type and version of browser used;

- The used operating system;

- Referrer URL;

- The hostname of the accessing computer;

- The time of the server inquiry;

- The IP address.

This data is not merged with other data sources.

This data is recorded on the basis of Art. 6 para. 1 lit. f GDPR. The operator of the website has a legitimate interest in the technically error-free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.

Contact form

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.

The processing of these data is based on Art. 6 para. 1 lit. b GDPR if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6 para. 1 lit. f GDPR), or on your consent (Art. 6 para. 1 lit. a GDPR) only if appropriate consent has been obtained; the given consent may be revoked at any time for the future.

The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g. after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions, in particular retention periods.

Request by email, telephone, or fax

If you contact us by email, telephone, or fax, your request, including all resulting personal data (e.g. name, request, user id) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent. If you contact us through the contact form on “members.symplact.org/contact-us/”, your user id will be attached to your request and shared with us so that we can easily identify the user account from which the request is sent.

These data are processed on the basis of Art. 6 para. 1 lit. b GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6 para. 1 lit. f GDPR) or on the basis of your consent (Art. 6 para. 1 lit. a GDPR) if it has been obtained; the given consent can be revoked at any time.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.

Registration on this website, Account Information

You have the option to register on this website to be able to use additional website functions. If you make a purchase on this website without being logged into an existing user account, your checkout information will be used to create a new user account (from which you will be making the purchase), and the checkout process will coincide with the registration process. We shall use the data you enter only for the purpose of using the respective offer or service you have registered for. The required information we request at the time of registration must be entered in full. Otherwise, we shall reject the registration.

The data you submit during the registration process will become part of your Account Information, which you may have the option to modify. If you request to change your account's email address, a verification email will be sent to the new email address to verify your request.

To notify you of any important changes to the scope of our portfolio or in the event of technical modifications, we shall use your account's email address.

The legal basis for the processing of personal data required by Art. 6 para. 1 s. 1 GDPR is Art. 6 para. 1 lit. b GDPR (contract). The provision of personal data as specified herein is necessary for the performance of a purchase contract.

The data recorded during the registration process (and your Account Information) shall be stored by us as long as you are registered on this website. Subsequently, such data shall be deleted. This shall be without prejudice to mandatory statutory retention obligations.

Email Notifications

We shall use your account's email address to send you notification emails (service emails) about specific events relating to your account. You can at any time adjust your account settings (under “Account Settings” -> “Email Preferences”) to stop receiving some of these emails.

Here is a list of some of the possible triggers for such notification emails:

Mentions:

- A member mentions you using “@YourNickname”.

Account Settings:

- Your password is changed.

Activity Feeds:

- A member replies to your post or comment.

Social Groups:

- The details of a group you manage are updated.

- You’re promoted in a group.

- You receive a new invite to join a group.

- A member requests to join a group you manage.

- Your request to join a group is accepted.

- Your request to join a group is rejected.

- You receive a new group message.

- There’s a new post in a group you're subscribed to.

- There’s a new discussion in a group you're subscribed to.

Discussion Forums:

- There’s a new discussion in a forum you’re subscribed to.

- There’s a new reply in a discussion you’re subscribed to.

Messages:

- You receive a new private message.

Member Connections:

- You receive a new connection request.

- Your connection request is accepted.

Moderation:

- You have been automatically suspended due to reaching the reporting threshold.

- Content posted by you is automatically hidden due to reaching the reporting threshold.

The legal basis for the aforementioned processing of personal data required by Art. 6 para. 1 s. 1 GDPR is Art. 6 para. 1 lit. f GDPR (legitimate interests). We have a legitimate interest in providing our customers with relevant service emails relating to their account. You have the right to at any time lodge an objection to the processing of your personal data as specified herein (relating to the aforementioned) on grounds relating to your particular situation. Should you lodge an objection, we shall no longer process your personal data as specified herein unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

Moreover, you may subscribe to receive additional notification emails. If you subscribe to additionally receive such notification emails, we will use your account's email address to provide you with the requested service.

If you subscribe to a specific forum, you will receive notification emails about new discussions created in that forum. If you subscribe to a specific forum discussion, you will receive notification emails about new replies in that discussion.

Personal data (relating to subscriptions to additional email notifications) is processed on the basis of your consent (Art. 6 para. 1 lit. a GDPR). You have the right to revoke at any time any consent you have already given us. You can revoke your consent and deactivate this function at any time by simply clicking the respective unsubscribe link on the specific forum or forum discussion page. This shall be without prejudice to the lawfulness of any data processing that occurred prior to your revocation.

Furthermore, we shall use your account's email address to notify you of any legal updates (e.g. in the case of a data breach, changes to our Terms and Conditions of Service, changes to our Privacy Policy, etc.).

Personal data (relating to the sending of legal updates) is processed on the legal basis of Art. 6 para. 1 lit. c GDPR (compliance with a legal obligation).

Profile Information

Some of the profile information (e.g. name, nickname) of registered users on this website may be automatically adopted from your registration information. You may have the option to modify your profile information.

The legal basis for the processing of personal data required by Art. 6 para. 1 s. 1 GDPR is Art. 6 para. 1 lit. b GDPR (contract). The provision of personal data as specified herein is necessary for the performance of a purchase contract (providing membership profile features).

Your Profile Information shall be stored by us as long as you are registered on this website. Subsequently, such data shall be deleted. This shall be without prejudice to mandatory statutory retention obligations.

The comment function on this website

When you use the comment function on this website, information on the time the comment was generated and your email address and, if you are not posting anonymously, the username you have selected will be archived in addition to your comments. The term “comment(s)” also refers to any timeline/activity posts and any forum discussion posts.

Storage of the IP address

Our comment function stores the IP addresses of all users who enter comments. Given that we do not review the comments prior to publishing them, we need this information in order to take action against the author in the event of rights violations, such as defamation or propaganda.

Subscribing to comments

You have the option to subscribe to receive notification emails about new comments on this website. You may be sent a confirmation email, the purpose of which is to verify whether you are the actual holder of the provided email address. Personal data is processed on the basis of your consent (Art. 6 para. 1 lit. a GDPR). You have the right to revoke at any time any consent you have already given us. You can revoke your consent and deactivate this function at any time by following a respective unsubscribe link in any of the notification emails. This shall be without prejudice to the lawfulness of any data processing that occurred prior to your revocation.

Storage period for comments

Comments and any affiliated information shall be stored by us and remain on this website until the content the comment pertained to has been deleted in its entirety or if the comments had to be deleted for legal reasons (e.g. insulting comments).

Legal basis

Comments are stored on the basis of your consent (Art. 6 para. 1 lit. a GDPR). By clicking to submit your comment, you are agreeing that we process your personal data in order to adequately process and present your comment. You have the right to revoke at any time any consent you have already given us. To do so, all you are required to do is sent us an informal notification via email. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation. You may also have the ability to remove your comment yourself.

Please refer to section 11.3 of this privacy policy for more information regarding our privacy practices and the recording of data on this website.

5. Analysis tools and advertising

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. This data is summarized in a user-ID and assigned to the respective end device of the website visitor.

Furthermore, Google Analytics allows us to record your mouse and scroll movements and clicks, among other things. Google Analytics uses various modeling approaches to augment the collected data sets and uses machine learning technologies in data analysis.

Google Analytics uses technologies for the recognition of the users for the purpose of analyzing user behavior patterns (e.g. cookies or device fingerprinting). The website user information recorded by Google is transferred to a Google server in the United States, where it is stored.

This analysis tool is used on the basis of Art. 6 para. 1 lit. f GDPR. The operator of this website has a legitimate interest in the analysis of user patterns to optimize both, the services offered online and the operator’s advertising activities. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the given consent can be revoked at any time for the future.

Data transfer to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.

Objection to the recording of data

You can prevent the recording and processing of your data by Google by downloading and installing the browser plug-in available on this page: https://tools.google.com/dlpage/gaoptout?hl=en.

For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration on: https://support.google.com/analytics/answer/6004245?hl=en.

Contract data processing

We have executed a contract data processing agreement with Google and are implementing all provisions of the Bulgarian data protection agencies to the fullest when using Google Analytics.

Archiving period

Data on the user or incident level stored by Google linked to cookies, user IDs or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) will be anonymized or deleted after 2 months.

For more information about Google Analytics, please review Google’s data protection policy on: https://policies.google.com/privacy?hl=en

Google Ads

The website operator uses Google Ads. Google Ads is an online promotional program of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads enables us to display ads in the Google search engine or on third-party websites, if the user enters certain search terms into Google (keyword targeting). It is also possible to place targeted ads based on the user data Google has in its possession (e.g. location data and interests; target group targeting). As the website operator, we can analyze these data quantitatively, for instance by analyzing which search terms resulted in the display of our ads and how many ads led to respective clicks.

The use of Google Ads is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in marketing the operator’s services and products as effectively as possible.

Data transfer to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://policies.google.com/privacy/frameworks and https://privacy.google.com/businesses/controllerterms/mccs/.

Google Ads Remarketing

This website uses Google Ads Remarketing. Google Ads Remarketing is a feature of Google Ads. The provider of these solutions is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

With Google Ads Remarketing, we can assign people who interact with our online offering to specific target groups in order to subsequently display interest-based advertising to them in the Google advertising network (remarketing or retargeting).

Moreover, it is possible to link the advertising target groups generated with Google Ads Remarketing to device encompassing functions of Google. This makes it possible to display interest-based customized advertising messages, depending on your prior usage and browsing patterns on a device (e.g. cell phone) in a manner tailored to you as well as on any of your devices (e.g. tablet or PC).

If you have a Google account, you have the option to object to personalized advertising on this page: https://www.google.com/settings/ads/onweb/.

The use of Google Ads Remarketing is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the marketing of the operator’s products that is as effective as possible. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the given consent may be revoked at any time for the future.

Data transfer to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://policies.google.com/privacy/frameworks and https://privacy.google.com/businesses/controllerterms/mccs/.

For further information and the pertinent data protection regulations, please consult the Data Privacy Policies of Google on: https://policies.google.com/technologies/ads?hl=en.

Formation of Target Groups with Customer Reconciliation

For the formation of target groups, we use, among other things, the Google Ads Remarketing customer reconciliation feature. To achieve this, we transfer certain customer data (e.g. email addresses) from our customer lists to Google. If the respective customers are Google users and are logged into their Google accounts, matching advertising messages within the Google network (e.g. YouTube, Gmail or in a search engine) are displayed for them to view.

For more information about Google Ads Remarketing, please review Google’s data protection policy on: https://policies.google.com/privacy?hl=en

Google Ads Conversion Tracking

This website uses Google Ads Conversion Tracking. Google Ads Conversion Tracking is a feature of Google Ads. The provider of these solutions is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

With the assistance of Google Ads Conversion Tracking, we are in a position to recognize whether the user has completed certain actions. For instance, we can analyze the how frequently which buttons on our website have been clicked and which products are reviewed or purchased with particular frequency. The purpose of this information is to compile conversion statistics. We learn how many users have clicked on our ads and which actions they have completed. We do not receive any information that would allow us to personally identify the users. Google as such uses cookies or comparable recognition technologies for identification purposes.

We use Google Ads Conversion Tracking on the basis of Art. 6 para. 1 lit. f GDPR. The operator of the website has a legitimate interest in the analysis of the user patterns with the aim of optimizing both, the operator’s web presentation and advertising. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the given consent may be revoked at any time for the future.

Data transfer to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://policies.google.com/privacy/frameworks and https://privacy.google.com/businesses/controllerterms/mccs/.

For more information about Google Ads Conversion Tracking, please review Google’s data protection policy on: https://policies.google.com/privacy?hl=en

Google DoubleClick

This website may use features of Google DoubleClick. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland, (hereinafter referred to as “DoubleClick”).

DoubleClick is used to show you interest-based ads across the Google Network. Advertisements can be tailored to the interests of the viewer using DoubleClick. For example, our ads may appear in Google search results or in banners associated with DoubleClick.

To be able to display interest adequate promotional content to users, DoubleClick must recognize the respective visitor so that it can allocate the websites visited, the clicks and other user pattern information to the user. To do this, DoubleClick deploys cookies or comparable recognition technologies (e.g. device fingerprinting). The recorded information is consolidated into a pseudonym user profile so that the respective user can be shown interest adequate advertising.

The use of Google DoubleClick takes place in the interest of targeted advertising measures. This constitutes a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the given consent may be revoked at any time for the future.

For further information on how to object to the advertisements displayed by Google, please refer to the following links: https://policies.google.com/technologies/ads and https://adssettings.google.com/authenticated.

For more information about Google DoubleClick, please review Google’s data protection policy on: https://policies.google.com/privacy?hl=en

Please refer to section 11.3 of this privacy policy for more information regarding our privacy practices and these services.

6. Newsletter

Newsletter data

In order for you to receive a newsletter offered on this website, we require from you an email address as well as some information that allows us to verify that you are the owner of the email address provided, and that you agree to receive the newsletter. Further data other than what is described herein shall not be collected or shall be collected only on a voluntary basis. For the handling of the newsletter(s), we use the newsletter service providers which are described below.

The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent (Art. 6 para. 1 lit. a GDPR). You may revoke the consent you have given to the archiving of data (e.g. the email address) and the use of this information for the sending of the newsletter at any time by clicking on the “Unsubscribe” link in the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date.

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter or after the purpose has ceased to apply. We reserve the right to delete or block email addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR.

After you unsubscribe from the newsletter distribution list, your email address may be stored by us or the newsletter service provider in a blacklist if such action is necessary to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.

MailChimp

We use the services of MailChimp for our “SymplAct Availability In Your Country” newsletter. The provider is the Rocket Science Group LLC d/b/a Mailchimp, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA (hereinafter referred to as “MailChimp”). Mailchimp is part of the Intuit group of companies and their parent entity is Intuit Inc.

Among other things, MailChimp is a service that can be deployed to organize and analyze the sending of newsletters. Whenever you enter data for the purpose of subscribing to the “SymplAct Availability In Your Country” newsletter (e.g. your email address), the information is stored on MailChimp servers in the United States.

With the assistance of the MailChimp tool, we can analyze the performance of our newsletter campaigns. If you open an email that has been sent through the MailChimp tool, a file that has been integrated into the email (a so-called web-beacon) connects to MailChimp’s servers in the United States. As a result, it can be determined whether a newsletter message has been opened and which links the recipient possibly clicked on. Technical information is also recorded at that time (e.g. the time of access, the IP address, type of browser and operating system). This information cannot be allocated to the respective newsletter recipient. Their sole purpose is the performance of statistical analyses of newsletter campaigns. The results of such analyses can be used to tailor future newsletters to the interests of their recipients more effectively.

If you do not want to permit an analysis by MailChimp, you must unsubscribe from the newsletter. We provide a link for you to do this in every newsletter message.

The data is processed based on your consent (Art. 6 para. 1 lit. a GDPR). You may revoke any consent you have given at any time by unsubscribing from the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place prior to your revocation.

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.

Data transfer to the US is based on the Standard Contractual Clauses (SCC) of the European Commission.

Data processing

We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

Here is a link to a page about Mailchimp's sub-processors: https://mailchimp.com/legal/subprocessors/.

After you unsubscribe from the newsletter distribution list, your email address may be stored by us or the newsletter service provider in a blacklist if such action is necessary to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.

For more details, please consult MailChimp’s Policies on: https://mailchimp.com/legal/, https://mailchimp.com/legal/additional-terms/ and https://mailchimp.com/legal/cookies/, as well as Inuit’s Global Privacy Statement at https://www.intuit.com/privacy/statement/.

Brevo

We use Brevo (formerly Sendinblue) for our newsletters, as well as for other (email) communication (e.g. for the provision of our chatbox feature, for responding to chatbox requests, or for sending out emails via SMTP), for Customer Relationship Managment, and for marketing automation features and tracking. The service provider is Sendinblue, a simplified joint stock company registered with the Paris Trade and Companies Register under number 498 019 298 and whose registered office is located at 106 boulevard Haussmann, 75008 Paris, France (hereinafter referred to as “Brevo”).

Brevo services can, among other things, be used to organize and analyze the sending of newsletters. Organizing the sending of newsletters includes, for example, that transactional emails can be set up to be sent out automatically when certain conditions, which are selected by us, are met. The data you enter for the purpose of subscribing to the newsletter are archived on Brevo’s servers.

Data analysis by Brevo

Brevo enables us to analyze our newsletter campaigns. For instance, it allows us to see whether a newsletter message has been opened and, if so, which links may have been clicked (thereby for example enabling us to determine the total number of clicks for each link).

Moreover, we are also able to see whether once the email was opened or a link was clicked, any previously defined actions have taken place. This lets us know, for example, if you have made a purchase after clicking on our newsletter, thereby enabling us to determine conversion rates. Brevo tracks certain events (e.g. when one of our Brevo contacts opens a page on one of our websites), and also stores such contact information in the Brevo contact profile assigned to that individual user.

Brevo also enables us to divide the subscribers to our newsletter into various categories (i.e., to “cluster” recipients). For instance, newsletter recipients can be categorized based on age, gender, or place of residence. This enables us to tailor our newsletter more effectively to the needs of the respective target groups.

If you do not want to permit an analysis by Brevo, you must unsubscribe from the newsletter. We provide a link for you to do this at the bottom of every newsletter message.

For more detailed information about how Brevo works, please follow this link: https://www.brevo.com/newsletter-software/.

Legal basis

The data is processed based on your consent (Art. 6 para. 1 lit. a GDPR). You may revoke any consent you have given at any time by unsubscribing from the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place prior to your revocation.

Storage period

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.

After you unsubscribe from the newsletter distribution list, your email address may be stored by us or the newsletter service provider in a blacklist if such action is necessary to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.

For more information, please consult Brevo’s Privacy Policy on: https://www.brevo.com/legal/privacypolicy/.

Data processing

We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

Please refer to section 11.3 of this privacy policy for more information regarding our privacy practices and these services.

7. Plug-ins and Tools

Brevo Chat

In addition to the functionalities described at the end of Section 6 of this Privacy Policy, Brevo also provides a chatbox feature which we make use of on our website. You can enter your contact details (e.g. name and email address) and message(s) into the chatbox fields to start and hold a conversation with our staff.

If you contact us via chatbox, your request, including all resulting personal data (e.g. name, email address and messages) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.

These data are processed on the basis of Art. 6 para. 1 lit. b GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6 para. 1 lit. f GDPR) or on the basis of your consent (Art. 6 para. 1 lit. a GDPR) if it has been obtained; the given consent can be revoked at any time.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.

For more information about Brevo, please refer to the text above, titled “Brevo” (under section 6 of this privacy policy).

YouTube with expanded data protection integration

Our website may have embedded videos of the website "YouTube". The operator of the YouTube website is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

We use YouTube in the expanded data protection mode. According to YouTube, this mode ensures that YouTube does not store any information about visitors to this website before they watch the video. Nevertheless, this does not necessarily mean that the sharing of data with YouTube partners can be ruled out as a result of the expanded data protection mode. For instance, regardless of whether you are watching a video, YouTube will always establish a connection with the Google DoubleClick network.

As soon as you start to play a YouTube video on this website, a connection to YouTube’s servers will be established. As a result, the YouTube server will be notified, which of our pages you have visited. If you are logged into your YouTube account while you visit our site, you enable YouTube to directly allocate your browsing patterns to your personal profile. You have the option to prevent this by logging out of your YouTube account.

Furthermore, after you have started to play a video, YouTube will be able to place various cookies or comparable technologies for recognition (e.g. device fingerprinting) on your device. In this way YouTube will be able to obtain information about this website’s visitors. Among other things, this information will be used to generate video statistics with the aim of improving the user friendliness of the site and to prevent attempts to commit fraud.

Under certain circumstances, additional data processing transactions may be triggered after you have started to play a YouTube video, which are beyond our control.

The use of YouTube is based on our interest in presenting our online content in an appealing manner. Pursuant to Art. 6 para. 1 lit. f GDPR, this is a legitimate interest. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the given consent may be revoked at any time for the future.

For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy on: https://policies.google.com/privacy?hl=en.

Vimeo

This website may use plug-ins of the video portal Vimeo. The provider is Vimeo Inc., 555 West 18th Street, New York, New York 10011, USA.

If you visit one of the pages on our website into which a Vimeo video has been integrated, a connection to Vimeo’s servers will be established. As a consequence, the Vimeo server will receive information as to which of our pages you have visited. Moreover, Vimeo will receive your IP address. This will also happen if you are not logged into Vimeo or do not have an account with Vimeo. The information recorded by Vimeo will be transmitted to Vimeo’s server in the United States.

If you are logged into your Vimeo account, you enable Vimeo to directly allocate your browsing patterns to your personal profile. You can prevent this by logging out of your Vimeo account.

Vimeo uses cookies or comparable recognition technologies (e.g. device fingerprinting) to recognize website visitors.

The use of Vimeo is based on our interest in presenting our online content in an appealing manner. Pursuant to Art. 6 para. 1 lit. f GDPR, this is a legitimate interest. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the given consent may be revoked at any time for the future.

Data transfer to the US is based on the Standard Contractual Clauses (SCC) of the European Commission and, according to Vimeo, on “legitimate business interests”. Details can be found here: https://vimeo.com/privacy.

For more information on how Vimeo handles user data, please consult the Vimeo Data Privacy Policy on: https://vimeo.com/privacy.

Bunny Stream

This website uses plug-ins of the video hosting solution Bunny Stream. The provider is BunnyWay d.o.o., Dunajska cesta 165, 1000 Ljubljana, Slovenia (hereinafter referred to as “Bunny.net”). The browser you use will establish a connection with Bunny.net servers whenever you visit pages on our website on which Bunny.net-hosted videos are embedded. As a result, Bunny.net will process personal data of yours.

Bunny Stream functions with Bunny.net’s video storage, transcoding, and streaming of video content via the Bunny Content Delivery Network (CDN).

Bunny.net may collect how many (unique) views our “Bunny Stream”-hosted videos get at any point in time. Bunny Stream also create statistics on users’ watch time, as well as how much streaming bandwidth is used in total on each of our “Bunny Stream”-hosted videos at any point in time. This data is anonymized and aggregated across all users. We have access to that data.

Bunny.net may process your IP address, technical information about your browser type, your operating system and basic device information. Bunny Stream can send back information about the stream quality, errors, buffering metrics, etc., to ensure good performance. Additionally, the iframes which are embedded on our pages might ping various Bunny.net CDN servers globally anonymously to collect performance statistics which are used to automatically adjust routing logic and optimize performance. Bunny.net servers will also receive information as to which of our pages, that have “Bunny Stream”-hosted videos embedded on them, you have visited.

The use of Bunny Stream is based on our interest in presenting our online content in an appealing manner. Pursuant to Art. 6 para. 1 lit. f GDPR, this is a legitimate interest. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the given consent may be revoked at any time for the future.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

Sub-processors

Bunny.net keep a public list of their sub-processors on this page: https://bunny.net/gdpr/sub-processors/.

For more information about Bunny Stream’s privacy practices, please refer to this page: https://bunny.net/gdpr/.

Link to Bunny.net’s Privacy & Data Policy: https://bunny.net/privacy/

VdoCipher

This website uses plug-ins of the video hosting solution VdoCipher. The provider is VdoCipher Media Solutions Pvt. Ltd., 91Springboard, Building no. 145 Sector 44 Gurgaon, India - 1220.

The browser you use will establish a connection with third-party servers whenever you visit pages on our website in which VdoCipher-hosted videos are embedded. As a result, these third parties will process personal data of yours. The third parties are Amazon.com, Inc. and Google.

These third parties may collect your IP address, technical information about your browser type, your operating system, basic device information, and process information about the pages you have visited on our website.

VdoCipher uses Global AWS Cloud Infrastructure that consists of three primary components: Storage on AWS S3, Transcoding via VdoCipher algorithms on AWS EC2, and Streaming of video content via Cloudfront CDN. Apart from these, there are over 10 other AWS services that are built into VdoCipher's video hosting infrastructure.

Cloudfront.net is part of a Content Delivery Network (CDN). CloudFront is an Amazon AWS service. Connections to CloudFront servers will be established (to cloudfront.net and/or to subdomains of cloudfront.net).

Personal data will be shared with Amazon.com, Inc. (Headquartered in Seattle, Washington, United States, Amazon.com, Inc. is an international organization with locations in the USA and all around the world.).

Here is a link to a page about Amazon.com, Inc.'s sub-processors: https://aws.amazon.com/compliance/sub-processors/

Data transfer to the US is based on the Standard Contractual Clauses (SCC) of the European Commission..

Privacy Policy (Amazon AWS): https://aws.amazon.com/privacy/

Connections to ajax.googleapis.com (Google servers) will be established. This way, Google can run scripts on our website.

Personal data will be shared with Google LLC, 1600 Amphitheatre Parkway, Mountain View, California 94043 USA and Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland (Google is an international organization with locations in the USA, Ireland etc.).

Here is a link to a page about Google's sub-processors: https://privacy.google.com/businesses/subprocessors/

Privacy Policy (Google): https://policies.google.com/privacy

The first-party cookie "uid" has a 20 year expiry time and is only loaded onto the domain path(s) of the respective video(s).

VdoCipher may collect how many (unique) views our VdoCipher videos get at any point in time. VdoCipher create statistics on how much streaming bandwidth is used in total on each of our VdoCipher-hosted videos at any point in time. This data is anonymized and aggregated across all users. We have access to that data. VdoCipher also collect the IP addresses of users who watch VdoCipher-hosted videos (IP-logging), receive information as to which of our pages you have visited, receive information about your user account on the website, and are able to collect insights into your browsing patterns.

The legal basis for the processing of personal data required by Art. 6 para. 1 s. 1 GDPR is Art. 6 para. 1 lit. b GDPR (contract). The establishment of connections to third-party servers and the provision of personal data as specified herein is necessary for the performance of a Membership purchase contract (providing the customer with piracy-protected video content).

hCaptcha

We use the hCaptcha anti-bot service (hereinafter referred to as "hCaptcha") on our website. This service is provided by Intuition Machines, Inc., a Delaware US Corporation (hereinafter referred to as "IMI").

hCaptcha is used to check whether the data entered on our website (such as on a comment form or password reset form) has been entered by a human or by an automated program. To do this, hCaptcha analyzes the behavior of the website or mobile app visitor based on various characteristics. This analysis starts automatically as soon as the website or mobile app visitor enters a part of the website where hCaptcha is enabled. For the analysis, hCaptcha evaluates various information (e.g. IP address, how long the visitor has been on the website or app, or mouse actions taken by the user). The data collected during the analysis is forwarded to IMI. hCaptcha analysis in the "invisible mode" may take place completely in the background. Website visitors are not alerted that such an analysis is taking place if the user is not shown a challenge.

Data processing is based on Art. 6 para. 1 lit. f GDPR: the website or mobile app operator has a legitimate interest in protecting their web presentations against abusive automated crawling and spam. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the given consent may be revoked at any time for the future. IMI acts as a "data processor" acting on behalf of its customers as defined under the GDPR, and a "service provider" for the purposes of the California Consumer Privacy Act (CCPA).

The processing of data is based on Standard Contract Clauses, included in the Data Processing Supplement to the General Terms and Conditions of IMI or in the data processing agreements.

For more information about hCaptcha and IMI's privacy policy and terms of use, please visit the following links: https://hcaptcha.com/privacy/ and https://hcaptcha.com/terms/.

Akismet

We use Akismet on this website to reduce spam. This service is provided by Aut O’Mattic A8C Ireland Ltd., 25 Herbert Pl, Dublin, D02 AY86, Ireland, whose parent company is based in the US.

Akismet is used to check whether form entries on our website (such as on a comment form or contact form) are spam. For this purpose, we process the provided visitor name, mail address, IP address, comment text, browser type and access time. When Akismet is enabled on this site, only the personal data needed to carry out Akismet's core function of protecting us against spam is collected. For detailed insights into which types of your personal data Akismet may process, please refer to their special Privacy Notice for visitors to their users’ sites: "https://automattic.com/privacy-notice/". There are short retention periods of between two weeks and ninety days for the vast majority of the spam-related data collected for the provision of the Akismet service, at which point it is automatically deleted from their companies’ databases. Anyone can opt-out of all long-term tracking for the very small subset of data they do keep longer by using the contact form on "https://akismet.com/contact/".

Personal data will be shared with Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA, and Aut O’Mattic A8C Ireland Ltd., 25 Herbert Pl, Dublin, D02 AY86, Ireland. Automattic Inc. is also the controller for some of the processing activities related to Services provided by Aut O’Mattic A8C Ireland Ltd.

Here is a link to a page about Automattic Inc.'s sub-processors: "https://automattic.com/subprocessor-list/".

The legal basis for the processing of personal data required by Art. 6 para. 1 s. 1 GDPR is Art. 6 para. 1 lit. f GDPR (legitimate interests). We have a legitimate interest in using the Akismet service to protect our website against spam attacks. It is common practice for website operators to use third-party spam protection solutions for such purposes. It is necessary for the third-party service provider to process certain personal data of yours in order for their solutions to function properly. In GDPR terms, this is a "legitimate interest" use of that data.

You have the right to at any time lodge an objection to the processing of your personal data as specified herein on grounds relating to your particular situation.

Should you lodge an objection, we shall no longer process your personal data as specified herein unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

Data transfer to the US is based on the standard contractual clauses of the EU Commission. Details can be found here: https://wordpress.com/support/data-processing-agreements/.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

For more information about Akismet's and Automattic's privacy practices and terms of use, please visit the following links: https://automattic.com/privacy/ ; https://akismet.com/gdpr/ ; and https://akismet.com/tos/.

Google reCAPTCHA

We may use “Google reCAPTCHA” (hereinafter referred to as “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

The purpose of reCAPTCHA is to determine whether data entered on this website (e.g. information entered into a contact form) is being provided by a human user or by an automated program. To determine this, reCAPTCHA analyzes the behavior of the website visitors based on a variety of parameters. This analysis is triggered automatically as soon as the website visitor enters the site. For this analysis, reCAPTCHA evaluates a variety of data (e.g. IP address, time the website visitor spent on the site or cursor movements initiated by the user). The data tracked during such analyses are forwarded to Google.

reCAPTCHA analyses run entirely in the background. Website visitors are not alerted that an analysis is underway.

Data are stored and analyzed on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the protection of the operator’s websites against abusive automated spying and against SPAM. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the given consent may be revoked at any time for the future.

For more information about Google reCAPTCHA please refer to the Google Data Privacy Policy and Terms Of Use on these pages: https://policies.google.com/privacy?hl=en and https://policies.google.com/terms?hl=en.

Google Fonts

Google reCAPTCHA uses so-called Google Fonts provided by Google. When you access a page on our website that uses Google reCAPTCHA, only if you have given prior consent for the use of reCAPTCHA, your browser will load the required fonts into your browser cache to correctly display text and fonts.

To do this, the browser you use will have to establish a connection with Google’s servers. As a result, Google will learn that your IP address was used to access this website. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the given consent may be revoked at any time for the future.

If your browser should not support Google Fonts, a standard font installed on your computer will be used.

We have made a reasonable effort to avoid using Google Fonts on the website in any way other than as specified herein.

For more information on Google Fonts, please follow this link: https://developers.google.com/fonts/faq and consult Google’s Data Privacy Policy on: https://policies.google.com/privacy?hl=en.

Google Maps

This website uses the mapping service Google Maps. The provider is Google Cloud EMEA Limited (“Google”), 70 Sir John Rogerson's Quay, D02 R296, Dublin 2, Ireland.

We use the “Places API”, the “Geocoding API”, and the “Maps JavaScript API”. To enable the use of the Google Maps features, your IP address must be stored. As a rule, this information is transferred to one of Google’s servers in the United States, where it is archived. The operator of this website has no control over the data transfer. Google Maps features may use Google fonts for the purpose of uniform depiction of fonts. When you access Google Maps features, your browser will load the required fonts into your browser cache, to correctly display text and fonts.

We use Google Maps to present our online content in an appealing manner and to make the locations disclosed on our website easy to find. This constitutes a legitimate interest as defined in Art. 6 para. 1 lit. f GDPR. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the given consent may be revoked at any time for the future.

Data transfer to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://workspace.google.com/terms/mcc_terms.html and https://workspace.google.com/terms/dpa_terms.html.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

Page with a list of Google's sub-processors for these services: https://cloud.google.com/terms/subprocessors.

For more information on the handling of user data, please review Google’s Data Privacy Policy on: https://policies.google.com/privacy?hl=en.

Wordfence

We use the "Wordfence" service provided by Defiant Inc, Defiant, Inc, 800 5th Ave Ste 4100, Seattle, WA 98104, USA (hereinafter referred to as "Wordfence").

Wordfence is designed to protect our website from unwanted access or malicious cyberattacks. To accomplish this, our website establishes a permanent connection with Wordfence’s servers, which check and block their databases against access to our website.

The use of Wordfence is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the most effective protection of his website against cyberattacks. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the given consent may be revoked at any time for the future.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.wordfence.com/help/general-data-protection-regulation/.

Data processing

We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

For more information on the handling of user data, please review Wordfence’s Privacy Policy on: https://wordfence.com/privacy-policy/.

AWS SES (Simple Email Service)

We use AWS SES to send out transactional and service emails. Personal data will be shared with Amazon.com, Inc. (Headquartered in Seattle, Washington, United States, Amazon.com, Inc. is an international organization with locations in the USA and all around the world.), the provider of this service.

Here is a link to a page about Amazon.com, Inc.'s sub-processors: https://aws.amazon.com/compliance/sub-processors/

Data transfer to the US is based on the Standard Contractual Clauses (SCC) of the European Commission..

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

For more information, please consult Amazon's Privacy Notice regarding AWS Services: https://aws.amazon.com/privacy/

The processing of personal data is based on Art. 6 para. 1 lit. b GDPR if the email, which is sent out, is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in sending out service emails / transactional emails (Art. 6 para. 1 lit. f GDPR).

Google Workspace

We use Google Workspace to send and receive emails. The provider is Google Cloud EMEA Limited (“Google”), 70 Sir John Rogerson's Quay, D02 R296, Dublin 2, Ireland.

Data transfer to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://workspace.google.com/terms/mcc_terms.html and https://workspace.google.com/terms/dpa_terms.html.

Data processing

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

Page with a list of Google's sub-processors for these services: https://workspace.google.com/terms/subprocessors.html.

For more information on the handling of user data, please review Google’s Data Privacy Policy on: https://policies.google.com/privacy?hl=en.

Please refer to section 11.3 of this privacy policy for more information regarding our privacy practices and these services.

8. eCommerce, payment service providers, and accounting

Processing of Customer and Contract Data

We collect, process, and use personal customer and contract data for the establishment, content arrangement and modification of our contractual relationships. Data with personal references to the use of this website (usage data) will be collected, processed, and used only if this is necessary to enable the user to use our services or required for billing purposes. The legal basis for these processes is Art. 6 para. 1 lit. b GDPR.

The collected customer data shall be deleted upon completion of the order or termination of the business relationship and upon expiration of any existing statutory archiving periods. This shall be without prejudice to any statutory archiving periods.

Data transfer upon closing of contracts for online stores, retailers, and the shipment of merchandise

Whenever you order merchandise from us, we will share your personal data with the transportation company entrusted with the delivery as well as the payment service commissioned to handle the payment transactions. Only the data these respective service providers require to meet their obligations will be shared. The legal basis for this sharing is Art. 6 para. 1 lit. b GDPR, which permits the processing of data for the fulfillment of contractual or pre-contractual obligations. If you give us your respective consent pursuant to Art. 6 para. 1 lit. a GDPR, we will share your email address with the transportation company entrusted with the delivery so that this company can notify you on the shipping status for your order via email. You have the option to revoke your consent at any time.

Data transfer upon closing of contracts for services and digital content

We share personal data with third parties only if this is necessary in conjunction with the handling of the contract; for instance, with the financial institution tasked with the processing of payments.

Any further transfer of data which has not been specified in this privacy policy shall not occur or shall only occur if you have expressly consented to the transfer. Any sharing of your data with third parties in the absence of your express consent, for instance for advertising purposes, shall not occur unless specified in this Privacy Policy.

The basis for the processing of data is Art. 6 para. 1 lit. b GDPR, which permits the processing of data for the fulfilment of a contract or for pre-contractual actions.

Payment services

We integrate payment services of third-party companies on our website. When you make a purchase from us, your payment data (e.g. name, payment amount, bank account details, credit card number) are processed by the payment service provider for the purpose of payment processing. For these transactions, the respective contractual and data protection provisions of the respective providers apply. The processing of personal data as specified herein is based on Art. 6 para. 1 lit. b GDPR (contract processing) and on the interest of a smooth, convenient, and secure payment transaction (Art. 6 para. 1 lit. f GDPR). Insofar as your appropriate consent has been obtained for certain actions, Art. 6 para. 1 lit. a GDPR is the legal basis for data processing; the given consent may be revoked at any time for the future.

We use the following payment services / payment service providers within the scope of this website:

Stripe

The provider for customers within the EU is Stripe Payments Europe, Ltd,1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland (hereinafter referred to as “Stripe”).

Data transfer to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://stripe.com/de/privacy and https://stripe.com/de/guides/general-data-protection-regulation.

Data processing

We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

Details on data processing practices can be found in Stripe’s Privacy Policy: https://stripe.com/de/privacy.

Apple Pay

We use Apple Pay through Stripe. The provider is Apple Inc, Infinite Loop, Cupertino, CA 95014, USA. The Apple privacy policy can be found here: https://www.apple.com/legal/privacy/.

Google Pay

We use Google Pay through Stripe. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. You can find Google’s privacy policy here: https://policies.google.com/privacy.

PayPal

The provider of this payment service is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter referred to as “PayPal”).

Data transfer to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.paypal.com/de/webapps/mpp/ua/pocpsa-full.

Data processing

We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

Details on data processing practices can be found in PayPal’s privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

Please refer to section 11.3 of this privacy policy for more information regarding our privacy practices and these services.

9. Online-based Audio and Video Conferences (Conference tools)

Data processing

We use online conference tools, among other things, for communication with our customers. The tools we use are listed in detail below. If you communicate with us by video or audio conference using the Internet, your personal data will be collected and processed by the provider of the respective conference tool and by us. The conferencing tools collect all information that you provide/access to use the tools (email address and/or your phone number). Furthermore, the conference tools process the duration of the conference, start and end (time) of participation in the conference, number of participants and other “context information” related to the communication process (metadata).

Furthermore, the provider of the tool processes all the technical data required for the processing of the online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or loudspeaker and the type of connection.

Should content be exchanged, uploaded, or otherwise made available within the tool, it is also stored on the servers of the tool provider. Such content includes, but is not limited to, cloud recordings, chat/ instant messages, voicemail uploaded photos and videos, files, whiteboards, and other information shared while using the service.

Please note that we do not have complete influence on the data processing procedures of the tools used. Our possibilities are largely determined by the corporate policy of the respective provider. Further information on data processing by the conference tools can be found in the data protection declarations of the tools used, and which we have listed below this text.

Purpose and legal bases

The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6 para. 1 sentence 1 lit. b GDPR). Furthermore, the use of the tools serves to generally simplify and accelerate communication with us or our company (legitimate interest in the meaning of Art. 6 para. 1 lit. f GDPR). Insofar as appropriate consent has been obtained, the tools in question will be used on the legal basis of Art. 6 para. 1 lit. a GDPR (consent); the given consent may be revoked at any time for the future.

Duration of storage

Data collected directly by us via the video and conference tools will be deleted from our systems immediately after you request us to delete it, revoke your consent to storage, or the reason for storing the data no longer applies. Stored cookies remain on your end device until you delete them. Mandatory legal retention periods remain unaffected.

We have no influence on the duration of storage of your data that is stored by the operators of the conference tools for their own purposes. For details, please directly contact the operators of the conference tools.

Conference tools used

We employ the following conference tools:

Zoom

We use Zoom. The provider of this service is Zoom Communications Inc, San Jose, 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA. For details on data processing practices, please refer to Zoom’s privacy policy: https://zoom.us/en-us/privacy.html.

Data transfer to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://zoom.us/de-de/privacy.html.

Data processing

We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.

10. Custom Services

Handling applicant data

We offer website visitors the opportunity to submit job applications to us (e.g. via email, via postal services on by submitting the online job application form). Below, we will brief you on the scope, purpose and use of the personal data collected from you in conjunction with the application process. We assure you that the collection, processing, and use of your data will occur in compliance with the applicable data privacy rights and all other statutory provisions and that your data will always be treated as strictly confidential.

Scope and purpose of the collection of data

If you submit a job application to us, we will process any affiliated personal data (e.g. contact and communications data, application documents, notes taken during job interviews, etc.), if they are required to make a decision concerning the establishment of an employment relationship. The legal grounds for the aforementioned are Art. 6 para. 1 lit. b GDPR (General Contract Negotiations) and – provided you have given us your consent – Art. 6 para. 1 lit. a GDPR. You may revoke any consent given at any time. Within our company, your personal data will only be shared with individuals who are involved in the processing of your job application.

If your job application should result in your recruitment, the data you have submitted will be archived on the grounds of Art. 6 para. 1 lit. b GDPR for the purpose of implementing the employment relationship in our data processing system.

Data Archiving Period

If we are unable to make you a job offer or you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests (Art. 6 para. 1 lit. f GDPR) for up to 6 months from the end of the application procedure (rejection or withdrawal of the application). Afterwards the data will be deleted, and the physical application documents will be destroyed. The storage serves in particular as evidence in the event of a legal dispute. If it is evident that the data will be required after the expiry of the 6-month period (e.g. due to an impending or pending legal dispute), deletion will only take place when the purpose for further storage no longer applies.

Longer storage may also take place if you have given your agreement (Article 6 para. 1 lit. a GDPR) or if statutory data retention requirements preclude the deletion.