Privacy Policy

Privacy Policy

‍Any collection, processing and use (hereinafter "use") of data is solely for the purpose of providing our services. Our services have been designed to use as little personal information as possible. For that matter, "personal data" is understood as all individual details about a person or factual circumstances of an identifiable natural person (so-called "affected person"). The following statements on data protection describe what types of data are collected when accessing our website, what happens with these data and how you may object to data usage.1 General information on data processing  
‍‍

‍1.1 Person Responsible (Controller)‍


Responsible within the meaning of the EU General Data Protection Regulation (GDPR) and the new Federal Data Protection Act (BDSG) is:

AJ&Smart GmbH

Address: Köpenicker Str 10a, 10997 Berlin

Phone: +49 (0)30 23599923

Email: ajsmart@ws-datenschutz.com

Homepage: https://www.ajsmart.com/ 


1.2 Name and address of the Data Security Officer 


The data protection officer is:


Kemal Webersohn of WS Datenschutz GmbH


If you have questions about data protection, you can contact WS Datenschutz GmbH at the following email address: ajsmart@ws-datenschutz.de


WS Datenschutz GmbH

Dircksenstraße 51 D-10178 Berlin

https://webersohnundscholtz.de  


1.3 Protection of your data


We have taken technical and organizational measures to ensure that the requirements of the EU General Data Protection Regulation (GDPR) are met by us, as well as, by external service providers working for us.If we work with other companies to provide our services, such as email and server providers, this will only be done after an extensive selection process. In this selection process, each individual service provider is carefully selected for its suitability in terms of technical and organizational data protection skills. This selection procedure will be documented in writing and an agreement on the order processing of data (data processing agreement) will only be concluded if the third party complies with the requirements of Art. 28 GDPR.

Your information will be stored on specially protected servers. Access to it is only possible for a few specially authorized persons. Our website is SSL/TLS encrypted, as can be seen by the https:// at the start of our URL. This also involves e-mail communications, which is encoded via SSL certificate.


1.4 Erasure of personal data


We process personal data only if necessary. As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.


2 Use of data on this website and in logfiles


‍‍2.1 Scope of processing personal data

 
‍‍When visiting our website, our web servers temporarily store every access in a log file. The following data is collected and stored until automated erasure:‍‍‍


• IP-address of the requesting computer‍

• Date and time of access‍

• Name and URL of the retrieved file‍

• Transmitted amount of data‍

• Message if the retrieval was successful‍

• Detection data of the browser and operating system used‍

• Website from which access is made‍

• Name of your Internet access provider ‍‍‍


We or our partners may process additional data occasionally. You will find information about this below.‍‍‍


2.2 Legal basis for processing personal data

 
‍‍The legal basis for the temporary storage of the data and log files is Art. 6 para. 1 s. 1 lit. f) GDPR. Our legitimate interest is to make our website accessible for you.‍‍‍


2.3 Purpose of data processing


‍‍The processing of this data serves: the purpose of enabling the use of the website (connection establishment), system security, the technical administration of the network infrastructure, as well as to optimize the website. The IP address is evaluated only in case of attacks on our network infrastructure or the network infrastructure of our internet provider.‍‍


‍2.4 Duration of storage


‍‍As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out. This happens as soon as you close our website. Our hosting service might use data for statistical purposes. Any personal data will be anonymized for this. Our hosting service will delete this data after a period of 6 month.‍‍‍


2.5 Right of objection and erasure


‍‍In addition to the right to information, you also have a right of correction regarding the personal data stored about you, a right of deletion, a right of blocking and a right of transfer of your data.‍‍‍Furthermore, you can object to this processing at any time by contacting us or the 1&1 data protection officer. If you wish to exercise any of these rights, you can contact the 1&1 data protection officer at the address (see no. 2.6) or send an e-mail to datenschutz@ionos.de. ‍‍‍


2.6 Hosting provider
‍‍

Our website uses the services of the hosting provider 1&1. Data processing is carried out by: 

1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur.‍‍‍

For additional information, please see 1&1's privacy policy: https://www.ionos.de/terms-gtc/terms-privacy/


3 Use of cookies


‍‍3.1 Description and scope of data processing 


‍‍Our website uses cookies. This means that when using the website, cookies are stored on your computer. Cookies are small text files which are assigned to the browser you are using and which are stored on your hard drive. Through this information flows to us or the party who set the cookie. Cookies cannot run programs on or transmit viruses to your computer. They are used to analyze the use of our website in anonymized or pseudonymized form and to enable personalized advertisements on this website. The following data may be transmitted:‍‍


‍• Frequency of website visits‍

• Which functions of the website are used by you‍

• Your cookie-settings‍

• Language settings‍

• Items in shopping basket‍

• Used search terms‍‍‍


Upon entering our website, a cookie banner informs you about the use of cookies on this website and asks for your consent to the use of cookies. Also, you are pointed to the data privacy statement of this website.‍For more information, please refer to our cookie policy: Link


‍‍‍‍3.2 Legal basis for data processing


‍‍The legal basis for the processing of data by cookies, which do not only serve the functionality of our website, is Art. 6 para. 1 s. 1 lit. a) GDPR.‍‍‍ The legal basis for the processing of data for cookies, which serve only the functionality of this website, is Art. 6 para. 1 s. 1 lit. f) GDPR.‍‍‍


3.3 Purpose of data processing


‍‍Our legitimate interests are to provide you with a working website connection and to ensure a comfortable use of this website. Also, we need to process your personal data to solve occurring safety and security issues, as well as to ensure system stability.‍

The data processing takes place to make a statistical evaluation of our website possible.‍‍‍


3.4 Duration of storage 


‍‍This website uses the following types of cookies. The extend and function of each are being explained below:‍‍‍


• Transient cookies (see a)‍

• Persistent cookies (see b)‍‍‍


a) Transient cookies are automatically deleted when you close the browser. This is especially true for session cookies which store your session ID, with which various requests from your browser can be assigned to your session. This will allow your computer to be recognized when you return to our website. Session cookies are deleted when you log out or close the browser.‍‍‍


b) Persistent cookies are automatically deleted after a specified period, which may differ depending on the cookie.‍‍‍


3.5 Right to objection and erasure 


‍‍You have the possibility to revoke your consent to the data processing by means of cookies, which do not only serve the functionality of the website. In addition, we do not set cookies until you have agreed to set cookies when you visit the site. In this way, you can prevent data processing via cookies on our website. You can also delete the cookies in your browser's security settings at any time. Please note that you may not be able to use all the features of this website. The setting of cookies can also be prevented at any time by appropriate settings in your internet browser.‍‍‍


3.6 Cookie-Script

Cookie Scipt serves the practical implementation of the GDPR and other data protection related law regarding the use of cookies on our website and the integration of analytics tools by means of consent. If you give your consent via the cookie banner, the following data will be processed:‍‍


‍• Your IP address‍

• Details of your consent‍

• URL of the consent website‍

• Date and time of consent‍

• Date and time of the last page access‍‍‍


The Processing of this data is based on Art. 6 para. 1 s.1 lit. c) GDPR.‍‍‍Data processing is performed by: Objectis Ltd., Laisves st. 60, LT-05120 Vilnius, Lithuania. ‍‍‍For more information about the data processing, please visit: https://cookie-script.com/legal/privacy-policy‍‍


‍4 Contact


‍‍4.1 Description and scope of data processing


‍‍Via our website it is possible to contact us via e-mail (support@ajsmart.com) or via contact form. This will require different data to answer the request, which will be automatically saved for processing.  ‍‍‍Contact form for enterprises looking for Innovation, Product Design or Training/ for teams looking to run product strategy or design sprints:‍‍‍The following data are required to process your request:‍‍


‍• Full name ‍

• E-mail address ‍

• Type of service‍‍‍


Furthermore, you can enter the following data optionally:‍‍‍

• Location ‍

• Company name ‍

• Description of company‍‍‍


Contact form for individuals looking for Online Courses: ‍‍‍

• Fist name‍

• E-mail address ‍

• Description of you ‍‍‍


Your data will not be passed on to third parties, unless you have given your consent. ‍‍‍


4.2 Legal basis for data processing


‍‍The legal basis depends on Art. 6 para. 1 s. 1 lit. b) GDPR.‍‍‍


4.3 Purpose of data processing


‍‍The processing of personal data from the input form is used solely handling the contact request.‍‍‍


4.4 Duration of storage


‍‍The data will be deleted as soon as we answer your request. There might occur rare cases when legal or contractual retention periods interfere with the erasure of your personal data. In this case your data will be deleted after these periods.‍‍‍


4.5 Right to objection and erasure


‍‍The user has the right to withdraw their consent to the processing of personal data at any time. If the user contacts us, they can object to storage of their personal data at any time. In such cases, the conversation cannot be continued. All personal data that has been stored in the course of the contact will be deleted.  ‍‍‍


4.6 Typeform


‍‍For the collection and transmission of data by means of contact forms, we use the service Typeform. Data processing is carried out by: 

TYPEFORM, S.L., Bac de Roda 163, 08018 Barcelona, Spain.‍‍‍

For additional information, please see Typeform privacy police: https://admin.typeform.com/to/dwk6gt


5 Newsletter


‍‍5.1 Description and scope of data processing


‍‍On our website visitors can subscribe to our newsletter. When subscribing to the newsletter, you will be asked to provide personal data for processing. This is the data that is requested in the newsletter registration form. Input fields marked with an "*" are mandatory fields:‍‍


‍• E-mail address.‍‍‍


Furthermore, you can enter the following data optionally:‍‍‍


• First name ‍‍‍


This data is necessary to send the newsletter to its recipients.‍

The newsletter will be sent via email only after the sign-up process is completed. In order to meet the requirements of the GDPR, we use DOI (Double Opt.-In). If you sign up for our newsletter, we will send a confirmation email to the address you provided us with. This email contains a confirmation link that you must click to complete the sign-up process. Following this procedure, the IP address, date and time of login are stored. This is done to prevent abuses. We won’t transfer the data to third parties.‍‍‍


5.2 Legal basis for data processing


‍‍This processing is legally based on Art. 6 para. 1 s.1 lit. a) GDPR, thus your consent.‍‍‍


5.3 Purpose of data processing


‍‍The newsletter has the functions of informing the affected parties about offers and news at a regular basis. ‍‍‍


5.4 Duration of storage


‍‍We process personal data only as long as necessary. As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.‍‍


‍5.5 Right to objection and erasure


‍‍The consent to receiving the newsletter can be revoked by you at any time. For this purpose, you can click the integrated link in each newsletter to unsubscribe. It is also possible to inform us about the revocation of the consent in any other way, e.g. via mail or email.‍‍‍


5.6 Click Funnels


‍‍5.6.1 Description and scope of data processing


‍‍The newsletter is sent by " ClickFunnels ", an online marketing platform. The data processing is carried out by: Etison LLC Click funnels, 3443 W. Bavaria St., Eagle, Idaho 83616, USA. ‍‍‍

The e-mail addresses of our newsletter recipients, as well as their other data described in this notice, are stored on Click funnels servers in the USA.  in the EU. Click funnel uses this information to send and evaluate the newsletters on our behalf. Click funnels does not use the data of our newsletter recipients and does not pass it on to third parties. The newsletters contain a so-called "web-beacon", i.e. a pixel-sized file that is retrieved from the Click funnels server when the newsletter is opened. In the course of this retrieval, information such as information about your system, your IP address and the time of the retrieval are collected. The statistical surveys also include the determination of whether the newsletters are opened, how often they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our nor Click funnels' intention to observe individual users. We trust in the reliability and IT and data security of Click funnels.‍‍‍


5.6.2 Legal basis for data processing


‍‍This data processing is legally based on our legitimate interests in efficiently and safely sending our newsletter, Art 6 para. 1 s. 1 lit. f) GDPR.‍‍‍5.6.3 Purpose of data processing
‍‍We use Click funnels as our shipping service provider to ensure effective address management and to keep in touch with you via the newsletter.‍‍‍


5.6.4 Duration of storage


‍‍According to Click funnels, Click funnels stores your personal data only as long as we use your personal data for newsletter delivery. Click funnels deletes your data when we delete you from our address file or delete our account there after a period of 30 days.‍‍‍


5.6.5 Right to objection and erasure


‍‍ You may object to the processing of your data by Click funnels. We will then review your justified objection and inform you whether and why we will continue the data processing. In addition, you are free at any time to use the "opt-out" link at the end of each e-mail, which will result in us deleting your e-mail address from our address file, which is why Click funnels will then also no longer process your personal data. However, this does not affect address files that Click funnels manages on behalf of other clients.‍‍‍


6 Online shopping


‍‍6.1 Description and scope of data processing


‍‍When you shop at our website and a delivery is arranged, we will process your first name and surname, address, telephone number and e-mail address to complete the purchase agreement and the delivery agreement with you.‍

In the case of parcel deliveries, we also pass on your name, address, telephone number and e-mail address to our contracted processors and service providers. ‍‍‍


6.2 Legal basis for data processing


‍‍The legal basis for this data processing is Art. 6 para. 1 s.1 lit. b) GDPR. We are processing your data for the fulfilment of purchase contracts and supply agreements.‍‍‍


6.3 Purpose of data processing


‍‍We process your data to close the contract, to handle the payment, for billing, to ensure on-time delivery and to inform you about that delivery.‍We provide your data to our contracted processors and service providers, so that they can process the delivery and, if necessary, communicate with you to announce and coordinate the delivery of your ordered goods.‍‍‍


6.4 Duration of storage


‍‍We process personal data only as long as necessary. As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.‍‍‍


6.5 Right to objection and erasure


‍‍The data processing is necessary in order to be able to process your purchase contract, which is why it cannot be waived. There is therefore no option to object.‍‍


‍6.6 PayPal


‍‍6.6.1 Description and scope of data processing 


‍‍We offer PayPal as a possible payment service. PayPal is a virtual means of payment. In order to use the payment service via PayPal, you must first register with PayPal. Responsible Person is:‍PayPal (Europe) S.à.r.l. & Cie. S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg.‍‍‍

If the user uses PayPal as a means of payment, personal data of the user will be transmitted to PayPal, to which he ultimately agrees. The personal data includes: ‍‍


• First and last name ‍

• Address ‍

• E-Mail address ‍

• IP-address ‍

• Telephone number ‍

• if necessary mobile number‍

• and other data, which are necessary for the final payment transaction.‍‍‍


In addition to the transfer of data to credit bureaus, it is also possible that PayPal may transfer the personal data to affiliated companies, including subcontractors, as far as this is necessary to fulfill the contractual obligations. The same applies to order processing.‍‍‍

For the privacy policy of PayPal, please refer to the following link: https://www.paypal.com/de/webapps/mpp/ua/privacy-full‍‍‍


6.6.2 Legal basis of data processing


‍‍The legal basis for the data processing is Art. 6 para. 1 s. 1 lit. b) GDPR.‍‍‍


6.6.3 Purpose of data processing


‍‍The transmission of the data is necessary to prevent any possible misuse. We inform you that PayPal may transfer your personal information to credit bureaus. This is because PayPal reserves its right to verify the identity and creditworthiness of the user.‍‍‍


6.6.4 Duration of storage


‍‍We process personal data only as long as necessary. As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.‍‍‍


6.6.5 Right to objection and erasure


‍‍Data processing is mandatory in order to process your payment through PayPal, so it cannot be waived if you have chosen this payment method. Therefore, objecting is impossible or would lead to withdrawal from the contract.‍‍‍


6.7 Stripe


‍‍6.7.1 Description and scope of data processing 


‍‍We offer Stripe as a payment service. With Stripe, you can use payment information stored in your Stripe account to make purchases quickly and securely. To use the payment service through Stripe, prior registration is required. The data processing is carried out by:  Stripe Payments Europe Ltd (subsidiary of Stripe Inc., 510 Townsend Street, San Francisco, CA 94103, USA).‍‍‍

Data processing by Stripe is carried out only for bookings that require online payments. The information collected by Stripe includes: ‍‍‍


• Payment method‍

• Payment method information (e.g. credit or debit card number or bank account details)‍

• Purchase amount‍

• Date of purchase.‍‍‍


Different payment methods may require the collection of different categories of data. The payment method information Stripe collects depends on the payment method you choose.‍‍‍When you complete a transaction, Stripe may also receive: ‍‍‍


• Name‍

• Email address,‍

• Billing or shipping address ‍

• and in some cases your transaction history to authenticate you.‍‍‍


For more information, please see Stripe's privacy policy: https://stripe.com/en-lu/privacy‍   ‍


6.7.2 Legal basis for data processing


‍‍Our legal basis is based on Art. 6 para. 1 s. 1 lit. b) GDPR. ‍‍‍


6.7.3 Purpose of data processing


‍‍The transmission of the data is necessary to prevent any misuse. We inform you that Stripe may transmit the personal data to credit agencies. This is because Stripe reserves the right to check your identity and creditworthiness. ‍‍‍


6.7.4 Duration of storage


‍‍We will only store your data for as long as is necessary to process your payment and invoice you. If you are a Stripe user, Stripe will retain your personal data for as long as the services are provided to you. The data will then be deleted unless there are regulatory, contractual or legal retention obligations that prevent deletion.‍‍‍


6.7.5 Right to objection and erasure


‍‍The data processing is mandatory in order to be able to process your payment via Stripe, which is why it cannot be dispensed with if you have chosen this payment method. There is therefore no possibility to opt out.‍‍‍


7 Social media links

We have integrated social media platforms through into our services, which may result in the social media provider receiving data from you. If you click on the social media link, the website of the respective social media provider is loaded. By loading the website of the respective social media provider via our services, the respective reference data is transmitted to the respective social media provider. The social media provider thereby receives the information that you have visited us. ‍‍‍Note on data processing to the United States: If you click on a social media link, data about you may be processed by the respective provider in the United States. According to the European Court of Justice, the data protection standard in the United States is not adequate and there is a risk that your data will be processed by the U.S. authorities for control and monitoring purposes, possibly also without any legal remedy. Provided that you do not click on the links of the social media providers, no data transfer takes place.‍‍‍


Further information on data processing by the social media providers can be found here:‍‍‍

Facebook: https://de-de.facebook.com/help/pages/insights

https://de-de.facebook.com/about/privacy

https://de-de.facebook.com/full_data_use_policy

LinkedIn: https://www.linkedin.com/legal/privacy-policy

Twitter: https://twitter.com/privacy?lang=de‍

YouTube: https://www.google.de/intl/de/policies/privacy/‍

Instagram: https://help.instagram.com/155833707900388 

https://www.instagram.com/about/legal/privacy/‍‍‍8 

Tracking and analytics
‍‍For the continuous improvement of our website we use the following tracking and analytics tools. Below you can find information on which personal data is processed in each case and how you can reach the respective service providers:‍‍‍


8.1 Facebook Custom Audience / Facebook-Pixel


‍‍8.1.1 Description and data processing


‍‍Our website uses Meta’s Facebook Custom Audience or Facebook Pixel to measure conversions. Data processing is carried out by: Meta Platforms Ireland Limited, 1 Hacker Way, Menlo Park, CA 94025, USA.‍‍‍

With the help of the Facebook Pixel, we can analyze the behaviour of our website’s visitors. As a result, the effectiveness of Meta advertisements can be evaluated. Meta receives the following data:‍‍‍


• the redirect URL, ‍

• browser information,‍

• and the person's Facebook user ID if they have a Facebook account ‍‍‍


The data is stored and processed by Meta, so that a connection to the respective user profile is possible and Meta can use the data for its own advertising purposes, according to the Meta data usage directive. As a result, Meta can enable ads to be displayed on Facebook and outside of Facebook. This use of data cannot be influenced by us as the site operator. You can find Meta’s data privacy policy here: https://www.facebook.com/about/privacy/ ‍‍‍


8.1.2 Legal basis of data processing


‍‍The legal basis for processing data is your given consent, Art. 6 para. 1 s. 1 lit. a) GDPR. ‍‍‍


8.1.3 Purpose of data processing


‍‍We process your data to continue the optimization of our website and our advertising activities.‍‍‍


8.1.4 Duration of storage


‍‍The data will be deleted as soon as they are no longer needed for our recording purposes.‍‍‍


8.1.5 Right to objection and erasure


‍‍You can deactivate the remarketing feature "Custom Audiences" in the Ads Settings section of Meta:‍‍‍ https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen, if you have a Facebook account. If you do not have a Facebook account, you can disable Meta’s usage-based advertising on the European Interactive Digital Advertising Alliance website:‍‍‍ http://www.youronlinechoices.com/de/praferenzmanagement/‍‍‍


8.2 Google Analytics


‍‍8.2.1 Description and scope of data processing


‍‍Our website uses Google Analytics. This is a service for analyzing access to websites of Google Inc. ("Google") and allows us to improve our website.  Data processing for the European Economic Area and for Switzerland is carried out by:

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.‍

Cookies enable us to analyze your use of our website. The information collected by a cookie are:‍‍‍


• IP address‍

• Access time ‍

• Access Duration‍‍‍


The information is transmitted to a Google server in the USA and stored there. The evaluation of your activities on our website is transmitted to us in the form of reports. Google may pass on the collected information to third parties, if required by law or if third parties process this data on behalf of Google. The Google tracking codes of our Internet offer use the function "_anonymizeIp ()", thus IP addresses are processed only shortened, in order to exclude a possible direct personal link to you. Under https://www.google.de/intl/de/policies/ as well as under http://www.google.com/analytics/terms/de.html you can find out more about the terms of use and privacy policy of Google Analytics.‍‍‍


8.2.2 Legal basis of data processing


‍‍The legal basis is your given consent, Art. 6 para 1 s. 1 lit. a) GDPR. ‍‍‍


8.2.3 Purpose of data processing


‍‍By processing the data, we can analyze how our website is used, so we can improve it for our users. ‍‍


‍8.2.4 Duration of storage


‍‍The data will be deleted after 50 months or will be deleted 50 months after your last website visit.‍‍‍


8.2.5 Right to objection and erasure


‍‍You can prevent the installation of cookies by Google Analytics in your browser settings. In this case, however, it may happen that you cannot fully use all features of our website. Also, trough browsers extensions e.g. http://tools.google.com/dlpage/gaoptout?hl=de Google Analytics can be disabled and controlled. ‍‍‍


8.3 Google Tag Manager


‍‍8.3.1 Description and scope of data processing


‍‍Google Tag Manager is a solution that allows us to manage so-called website tags via an interface (and thus, for example, integrate Google marketing services into our online offer). The Tag Manager serves as a "manager" of the implemented tags. This allows us to centrally manage integrated Google products or other analysis tools on our website. The tags embedded on the website are referred to as sections of code that make it possible to track your activities on our website. By using our website, users download the Google Tag Manager, which automatically results in the user's IP address being forwarded to Google With regard to the processing of personal data, please refer to the information on Google services. Data processing for the European Economic Area and Switzerland is carried out by: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.‍‍‍ You can access the usage guidelines of the Google Tag Manager here: https://www.google.com/intl/de/tagmanager/use-policy.html


8.3.2 Legal basis for data processing


‍‍The legal basis for the processing of personal data is your consent pursuant to Art. 6 para. 1 s. 1 lit. a) GDPR.‍‍‍


8.3.3 Purpose of data processing


‍‍Google Tag Manger simplifies the management and organization of the analysis tools used for the website. In order to integrate an analysis tool, JavaScript codes must be integrated into the website. By using Google Tag Manger, it is possible for us to manage these embedded codes from one place. ‍‍‍


8.3.4 Duration of storage


‍‍Since data storage is not carried out directly by Google Tag Manager, but the data is forwarded to the tracking tools, it is necessary to check with the individual embedded tracking tools how long the data is stored.‍‍‍


8.3.5 Right to objection and erasure


‍‍You have the option at any time to revoke a given consent to data processing with effect for the future. For this, you would have to contact the respective data protection officers of the tools. Further information regarding the management of your data can be found in the data protection statements of the tools used. ‍‍‍


9 Tools for advertisement and marketing


‍‍Tools are also included on our website to ensure that our website is displayed to you during an internet search, as a relevant search result or as an advertisement. Below, the programs used in connection with our website have been broken down for you:‍‍‍


9.1 Google Ad Manager (former Double Click)


‍‍9.1.1 Description and scope of data processing


‍‍We use Google Ad Manager. Data processing for the European Economic Area and for Switzerland is carried out by:‍Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.‍‍‍

Google Ad Manager uses information of your visits of this and other websites to generate advertisements of products and services that might interest you. For further information on the methods used or what you can do to prevent Google Ad Manager from using this information, please refer to the following link:‍‍‍ https://www.google.de/policies/technologies/ads/


9.1.2 Legal basis of data processing


‍‍Legal basis is Art. 6 para 1 s. 1 lit. a) GDPR. ‍‍‍


9.1.3 Purpose of data processing


‍‍We use Google Ad Manager to generate advertisements for our website visitors. Our interest is to cooperate with other companies to reach a broader audience.‍‍‍


9.1.4 Duration of storage


‍‍The data will be deleted as soon as they are no longer needed for our recording purposes.‍‍‍


9.1.5 Right to objection and erasure


‍‍The setting of cookies can be prevented by appropriate settings in your Internet browser at any time. The already set cookies can also be deleted in the settings of the Internet browser. We express our concern that preventing cookies from being set may mean that not all features are fully available.‍‍‍


9.2 Google Ads


‍‍9.2.1 Description and scope of data processing


‍‍We have integrated the services of Google Ads (formerly Google AdWords) on our website. Google Ads is an internet advertising service. We use Google Ads to gain relevance in the results of Google's search engine. Data processing for the European Economic Area and for Switzerland is carried out by: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.‍

If the user accesses our website through a Google ad, Google will set a so-called conversion cookie on the user's system. For the explanation of the cookies, please refer to the pass to the cookies. The conversion cookie is used to create and analyze web-use statistics.‍‍‍ The conversion cookie stores the IP address when visiting the website. This data is stored in the USA. It is possible that Google will share this information with third parties.  ‍‍‍For further privacy notices of Google refer to: https://policies.google.com/privacy?hl=en&gl=de‍‍‍


9.2.2 Legal basis of data processing


‍‍The legal basis is your consent pursuant to Art. 6 para. 1 s. 1 lit. a) GDPR. ‍‍‍


9.2.3 Purpose of data processing


‍‍In particular, we use Google Ads to gain relevance in the results of Google's search engine.These advertisements are carried out to reach a greater audience. ‍‍‍


9.2.4 Duration of storage


‍‍30 days after setting the conversion cookie the cookie loses its validity. This means that the user can no longer be identified. Within these 30 days both- us and Google can track which subpages have been accessed.‍‍‍


9.2.5 Right to objection and erasure


‍‍The setting of cookies can be prevented by appropriate settings in the user's Internet browser at any time. The already set cookies can also be deleted in the settings of the Internet browser. We express our concern that preventing cookies from being set may mean that not all features are fully available.‍The user may separately object to interest-based personalized advertising by Google. Please refer to the following link: www.google.de/settings/ads ‍‍‍


9.3 Google AdSense


‍‍9.3.1 Description and scope of data processing


‍‍We use Google AdSense on the website. This is an online service used for promotional purposes. Google AdSense allows the placement of advertisements on third party websites.  Data processing for the European Economic Area and for Switzerland is carried out by:‍‍‍Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.‍‍‍

Google AdSense places a cookie on the affected person. Regarding the clarification of “cookies”, see the passage on cookies above. The information stored by cookie can be recorded, collected and evaluated by Google Inc. or third parties. In addition, Google AdSense also uses so-called "WebBacons" (small invisible graphics) for the collection of information, through the use of which simple actions such as the visitor traffic on the website can be recorded, collected and evaluated.‍


The information generated by the cookie and / or WebBeacon about your use of this website is transmitted to a Google server in the USA and stored there. Google uses the information to evaluate your web behaviour with respect to the AdSense ads. Google may also transfer this information to third parties if required by law or as far as third parties process this data on behalf of Google. Your IP address will not be associated with other Google data stored by Google.‍‍‍For more information about Google AdSense, please refer to the following link: https://www.google.de/intl/de/adsense/start/‍‍‍


9.3.2 Legal basis of data processing


‍‍Legal basis is the Art. 6 para 1 s. 1 lit. a) GDPR. Our interest is to gain popularity by using these advertisements.‍‍‍


9.3.3 Purpose of data processing


‍‍The purpose of data processing is to reach a wider audience by using targeted advertisements.‍‍‍


9.3.4 Duration of storage


‍‍The data will be deleted as soon as they are no longer needed for our recording purposes.‍‍‍


9.3.5 Right to objection and erasure


‍‍The user can prevent the storage of cookies on his hard drive and the display of WebBeacons by making the appropriate settings in the browser.‍‍‍For more information about Google AdSense, please refer to the link below: https://www.google.de/intl/de/adsense/start/‍‍‍


9.4 Google Remarketing


‍‍9.4.1 Description and scope of data processing


‍‍We use Google Remarketing. ‍Data processing for the European Economic Area and for Switzerland is carried out by:‍‍‍Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.‍‍‍

Google Remarketing works by setting a cookie on the user. This cookie use gives Google the opportunity to recognize the user if they visit a website that also uses Google Remarketing.‍

As a result, Google will be notified of the user's IP address or browsing behaviour.‍‍‍


9.4.2 Legal basis of data processing


‍‍Data processing is based on your consent in accordance with Art. 6 para. 1 s. 1 lit. a) GDPR. ‍‍


‍9.4.3 Purpose of data processing


‍‍By using Google Remarketing, we may display advertisements to users that have previously logged into our website. Google Remarketing ultimately enables user-directed personalized advertising.‍‍‍


9.4.4 Duration of storage


‍‍The data will be deleted as soon as they are no longer needed for our recording purposes.‍‍‍


9.4.5 Right to objection and erasure


‍‍The prevention (as well as the erasure) of the cookie setting can be achieved under the appropriate settings in the Internet browser.‍

The user can object to user-related advertising by Google at any time. For this we refer to: https://policies.google.com/?hl=en ‍‍‍10 Service providers from third countries
‍‍In order to be able to provide our services, we use the support of service providers from third party countries (non-EU countries). In order to ensure the protection of your personal data in this case, we conclude processing contracts with each - carefully selected - service provider. All of our processors provide sufficient guarantees to implement appropriate technical and organizational measures. Our third country data processors are either located in a country with an adequate level of data protection (Art. 45 GDPR) or provide appropriate safeguards (Art 46 GDPR). ‍‍‍Adequate level of protection: The provider comes from a country whose level of data protection has been recognized by the EU Commission. 

For more information, see: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en ‍‍‍

EU standard contract clauses: Our provider has submitted to the EU standard contractual clauses to ensure secure data transfer. For more information, see: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX%3A32021D0914&locale=en ‍‍‍

Binding Corporate Rules: Article 47 of the GDPR provides the possibility of ensuring data protection when transferring data to a third country via Binding Corporate Rules. These are examined and approved by the data security authorities within the framework of the consistency mechanism pursuant to Art. 63 GDPR. ‍‍‍Consent: In addition, a data transfer to a third country without an adequate level of protection will only take place if you have given us your consent in accordance with Art. 49 sec. 1 lit. a) GDPR for this purpose.‍‍‍


11 Your rights


‍‍You have the following rights with respect to the personal data concerning you: ‍‍‍


11.1 Right to withdraw a given consent (Art. 7 GDPR)


‍‍If you have given your consent to the processing of your data, you can withdraw it at any time. This will affect the admissibility of processing your personal data by us for the time after you have withdrawn your consent. To withdraw your consent, contact us personally or in written form.‍‍‍


11.2 Right of access (Art. 15 GDPR)


‍‍You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to your personal data and the following information:‍


• the purpose of processing;‍

• the categories of personal data concerned;‍

• the recipients or the categories of recipient to whom your personal data have been or will be disclosed, in particular recipients in countries outside of the EU or international organisations; ‍

• where possible, the envisaged period for which your personal data will be stored, or, if not possible, the criteria used to determine that period;‍

• all available information on the source of your personal data;

• the existence of automated decision-making, including profiling, referred to Art. 22 para. 1 and 4 GDPR and, in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.‍‍‍In the case of such a request, you must provide enough information about your identity to proof that the request concerns your own personal data.‍‍‍


11.3 Right to rectification and erasure (Art. 16, 17 GDPR)


‍‍You have the right to obtain from us without undue delay the rectification and completion of inaccurate personal data concerning yourself.‍

You may also request the erasure of your personal data if any of the following applies to you:‍‍‍


• the personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed;‍

• you withdraw consent on which the processing is based according to Art. 6 para. 1 s.1 lit. a) or Art. 9 para. 2 lit. a) GDPR, and where there is no other legal ground of processing;‍

• you object to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for the processing, or the you object to the processing pursuant to Art. 21 para. 2 GDPR;‍

• the personal data have been unlawfully processed;‍

• the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which we are subject;‍

• the personal data have been collected in relation to the offer of information society services referred to in Art. 8 para. 1.‍‍‍Where we made the personal data public and are obliged to erase the personal data pursuant to Art. 17 para. 1 GDPR, we, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.‍‍‍


These rights shall not apply to the extent that processing is necessary:‍‍‍


• for exercising the right of freedom of expression and information;‍

• for compliance with a legal obligation which requires processing by Union or Member State law to which we are subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;‍

• for reasons of public interest in the area of public health in accordance of Art. 9 para. 2 lit. h) and i) as well as Art. 9 para. 3 GDPR;‍

• for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 para. 1 GDPR, in so far as the right referred to above is likely to render impossible or seriously impair the achievement of the objectives of that processing, or‍

• for the establishment, exercise or defence of legal claims.‍‍‍


11.4 Right to restriction of processing (Art. 18 GDPR)


‍‍You shall have the right to obtain from us restriction of processing where one of the following applies:‍‍‍


• the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;‍


• the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;‍


• we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;‍


• you have objected to processing pursuant to Art. 21 para. 1 GDPR pending the verification whether our legitimate grounds override yours.‍‍


‍Where processing has been restricted under the aforementioned conditions, such personal data shall, except for storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.‍

If the limitation of the processing is restricted, you will be informed by us before the restriction is lifted.‍‍‍


11.5 Right to information (Art. 19 GDPR)


‍‍If you have asserted us your right to rectification, erasure or restriction of data processing, we will inform all recipients of your personal data to correct, delete or restrict the processing of data, unless this proves impossible or involves disproportionate effort.‍You also have the right to know which recipients have received your personal data.‍‍‍


11.6 Right to data portability (Art. 20 GDPR)


‍‍You have the right to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format. Also, you have the right to transmit those data to another controller, where‍


• the processing is based on consent pursuant of Art. 6 para. 1 s.1 lit. a) GDPR or of Art. 9 para. 2 lit. a) GDPR or is based on a contract pursuant of Art. 6 para. 1 s. 1 lit. b) DS-GVO; and‍


• the processing is carried out by automated means.‍‍


‍In exercising your right to data portability, you have the right to obtain that personal data transmitted directly from us to another controller, as far as technically feasible. The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority that has been delegated to us.‍‍‍


11.7 Right to object (Art. 21 GDPR)


‍‍Where we based the processing of your personal data on a legitimate interest (Art. 6 para. 1 s. 1 lit. f) GDPR), you may object to the processing. The same applies if the data processing is based on Art. 6 para. 1 s. 1 lit. e).‍

In this case, we ask you to explain the reasons why we should not process your personal data. Based on this we will terminate or adapt the data processing or show you our legitimate reasons why we continue the data processing.‍‍‍


11.8 Right to lodge a complaint with supervisory authority (Art. 77 GDPR)


‍‍Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you is against the infringes of the GDPR.‍‍‍

The supervisory authority to which the complaint has been submitted shall inform you of the status and results of the complaint, including the possibility of a judicial remedy according to Article 78 GDPR.‍‍‍


12 How you perceive these rights


‍‍To exercise these rights, please contact our data protection officer:‍‍‍


Kemal Webersohn from Webersohn & Scholtz GmbH ‍

ajsmart@ws-datenschutz.com  ‍‍‍

or by mail:‍‍‍

WS Datenschutz GmbH

Dircksenstraße 51 D-10178 Berlin‍‍‍


13 Subject to change


‍‍We reserve the right to change this privacy policy in compliance with legal requirements.‍


‍May 2024‍

‍Any collection, processing and use (hereinafter "use") of data is solely for the purpose of providing our services. Our services have been designed to use as little personal information as possible. For that matter, "personal data" is understood as all individual details about a person or factual circumstances of an identifiable natural person (so-called "affected person"). The following statements on data protection describe what types of data are collected when accessing our website, what happens with these data and how you may object to data usage.1 General information on data processing  
‍‍

‍1.1 Person Responsible (Controller)‍


Responsible within the meaning of the EU General Data Protection Regulation (GDPR) and the new Federal Data Protection Act (BDSG) is:

AJ&Smart GmbH

Address: Köpenicker Str 10a, 10997 Berlin

Phone: +49 (0)30 23599923

Email: ajsmart@ws-datenschutz.com

Homepage: https://www.ajsmart.com/ 


1.2 Name and address of the Data Security Officer 


The data protection officer is:


Kemal Webersohn of WS Datenschutz GmbH


If you have questions about data protection, you can contact WS Datenschutz GmbH at the following email address: ajsmart@ws-datenschutz.de


WS Datenschutz GmbH

Dircksenstraße 51 D-10178 Berlin

https://webersohnundscholtz.de  


1.3 Protection of your data


We have taken technical and organizational measures to ensure that the requirements of the EU General Data Protection Regulation (GDPR) are met by us, as well as, by external service providers working for us.If we work with other companies to provide our services, such as email and server providers, this will only be done after an extensive selection process. In this selection process, each individual service provider is carefully selected for its suitability in terms of technical and organizational data protection skills. This selection procedure will be documented in writing and an agreement on the order processing of data (data processing agreement) will only be concluded if the third party complies with the requirements of Art. 28 GDPR.

Your information will be stored on specially protected servers. Access to it is only possible for a few specially authorized persons. Our website is SSL/TLS encrypted, as can be seen by the https:// at the start of our URL. This also involves e-mail communications, which is encoded via SSL certificate.


1.4 Erasure of personal data


We process personal data only if necessary. As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.


2 Use of data on this website and in logfiles


‍‍2.1 Scope of processing personal data

 
‍‍When visiting our website, our web servers temporarily store every access in a log file. The following data is collected and stored until automated erasure:‍‍‍


• IP-address of the requesting computer‍

• Date and time of access‍

• Name and URL of the retrieved file‍

• Transmitted amount of data‍

• Message if the retrieval was successful‍

• Detection data of the browser and operating system used‍

• Website from which access is made‍

• Name of your Internet access provider ‍‍‍


We or our partners may process additional data occasionally. You will find information about this below.‍‍‍


2.2 Legal basis for processing personal data

 
‍‍The legal basis for the temporary storage of the data and log files is Art. 6 para. 1 s. 1 lit. f) GDPR. Our legitimate interest is to make our website accessible for you.‍‍‍


2.3 Purpose of data processing


‍‍The processing of this data serves: the purpose of enabling the use of the website (connection establishment), system security, the technical administration of the network infrastructure, as well as to optimize the website. The IP address is evaluated only in case of attacks on our network infrastructure or the network infrastructure of our internet provider.‍‍


‍2.4 Duration of storage


‍‍As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out. This happens as soon as you close our website. Our hosting service might use data for statistical purposes. Any personal data will be anonymized for this. Our hosting service will delete this data after a period of 6 month.‍‍‍


2.5 Right of objection and erasure


‍‍In addition to the right to information, you also have a right of correction regarding the personal data stored about you, a right of deletion, a right of blocking and a right of transfer of your data.‍‍‍Furthermore, you can object to this processing at any time by contacting us or the 1&1 data protection officer. If you wish to exercise any of these rights, you can contact the 1&1 data protection officer at the address (see no. 2.6) or send an e-mail to datenschutz@ionos.de. ‍‍‍


2.6 Hosting provider
‍‍

Our website uses the services of the hosting provider 1&1. Data processing is carried out by: 

1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur.‍‍‍

For additional information, please see 1&1's privacy policy: https://www.ionos.de/terms-gtc/terms-privacy/


3 Use of cookies


‍‍3.1 Description and scope of data processing 


‍‍Our website uses cookies. This means that when using the website, cookies are stored on your computer. Cookies are small text files which are assigned to the browser you are using and which are stored on your hard drive. Through this information flows to us or the party who set the cookie. Cookies cannot run programs on or transmit viruses to your computer. They are used to analyze the use of our website in anonymized or pseudonymized form and to enable personalized advertisements on this website. The following data may be transmitted:‍‍


‍• Frequency of website visits‍

• Which functions of the website are used by you‍

• Your cookie-settings‍

• Language settings‍

• Items in shopping basket‍

• Used search terms‍‍‍


Upon entering our website, a cookie banner informs you about the use of cookies on this website and asks for your consent to the use of cookies. Also, you are pointed to the data privacy statement of this website.‍For more information, please refer to our cookie policy: Link


‍‍‍‍3.2 Legal basis for data processing


‍‍The legal basis for the processing of data by cookies, which do not only serve the functionality of our website, is Art. 6 para. 1 s. 1 lit. a) GDPR.‍‍‍ The legal basis for the processing of data for cookies, which serve only the functionality of this website, is Art. 6 para. 1 s. 1 lit. f) GDPR.‍‍‍


3.3 Purpose of data processing


‍‍Our legitimate interests are to provide you with a working website connection and to ensure a comfortable use of this website. Also, we need to process your personal data to solve occurring safety and security issues, as well as to ensure system stability.‍

The data processing takes place to make a statistical evaluation of our website possible.‍‍‍


3.4 Duration of storage 


‍‍This website uses the following types of cookies. The extend and function of each are being explained below:‍‍‍


• Transient cookies (see a)‍

• Persistent cookies (see b)‍‍‍


a) Transient cookies are automatically deleted when you close the browser. This is especially true for session cookies which store your session ID, with which various requests from your browser can be assigned to your session. This will allow your computer to be recognized when you return to our website. Session cookies are deleted when you log out or close the browser.‍‍‍


b) Persistent cookies are automatically deleted after a specified period, which may differ depending on the cookie.‍‍‍


3.5 Right to objection and erasure 


‍‍You have the possibility to revoke your consent to the data processing by means of cookies, which do not only serve the functionality of the website. In addition, we do not set cookies until you have agreed to set cookies when you visit the site. In this way, you can prevent data processing via cookies on our website. You can also delete the cookies in your browser's security settings at any time. Please note that you may not be able to use all the features of this website. The setting of cookies can also be prevented at any time by appropriate settings in your internet browser.‍‍‍


3.6 Cookie-Script

Cookie Scipt serves the practical implementation of the GDPR and other data protection related law regarding the use of cookies on our website and the integration of analytics tools by means of consent. If you give your consent via the cookie banner, the following data will be processed:‍‍


‍• Your IP address‍

• Details of your consent‍

• URL of the consent website‍

• Date and time of consent‍

• Date and time of the last page access‍‍‍


The Processing of this data is based on Art. 6 para. 1 s.1 lit. c) GDPR.‍‍‍Data processing is performed by: Objectis Ltd., Laisves st. 60, LT-05120 Vilnius, Lithuania. ‍‍‍For more information about the data processing, please visit: https://cookie-script.com/legal/privacy-policy‍‍


‍4 Contact


‍‍4.1 Description and scope of data processing


‍‍Via our website it is possible to contact us via e-mail (support@ajsmart.com) or via contact form. This will require different data to answer the request, which will be automatically saved for processing.  ‍‍‍Contact form for enterprises looking for Innovation, Product Design or Training/ for teams looking to run product strategy or design sprints:‍‍‍The following data are required to process your request:‍‍


‍• Full name ‍

• E-mail address ‍

• Type of service‍‍‍


Furthermore, you can enter the following data optionally:‍‍‍

• Location ‍

• Company name ‍

• Description of company‍‍‍


Contact form for individuals looking for Online Courses: ‍‍‍

• Fist name‍

• E-mail address ‍

• Description of you ‍‍‍


Your data will not be passed on to third parties, unless you have given your consent. ‍‍‍


4.2 Legal basis for data processing


‍‍The legal basis depends on Art. 6 para. 1 s. 1 lit. b) GDPR.‍‍‍


4.3 Purpose of data processing


‍‍The processing of personal data from the input form is used solely handling the contact request.‍‍‍


4.4 Duration of storage


‍‍The data will be deleted as soon as we answer your request. There might occur rare cases when legal or contractual retention periods interfere with the erasure of your personal data. In this case your data will be deleted after these periods.‍‍‍


4.5 Right to objection and erasure


‍‍The user has the right to withdraw their consent to the processing of personal data at any time. If the user contacts us, they can object to storage of their personal data at any time. In such cases, the conversation cannot be continued. All personal data that has been stored in the course of the contact will be deleted.  ‍‍‍


4.6 Typeform


‍‍For the collection and transmission of data by means of contact forms, we use the service Typeform. Data processing is carried out by: 

TYPEFORM, S.L., Bac de Roda 163, 08018 Barcelona, Spain.‍‍‍

For additional information, please see Typeform privacy police: https://admin.typeform.com/to/dwk6gt


5 Newsletter


‍‍5.1 Description and scope of data processing


‍‍On our website visitors can subscribe to our newsletter. When subscribing to the newsletter, you will be asked to provide personal data for processing. This is the data that is requested in the newsletter registration form. Input fields marked with an "*" are mandatory fields:‍‍


‍• E-mail address.‍‍‍


Furthermore, you can enter the following data optionally:‍‍‍


• First name ‍‍‍


This data is necessary to send the newsletter to its recipients.‍

The newsletter will be sent via email only after the sign-up process is completed. In order to meet the requirements of the GDPR, we use DOI (Double Opt.-In). If you sign up for our newsletter, we will send a confirmation email to the address you provided us with. This email contains a confirmation link that you must click to complete the sign-up process. Following this procedure, the IP address, date and time of login are stored. This is done to prevent abuses. We won’t transfer the data to third parties.‍‍‍


5.2 Legal basis for data processing


‍‍This processing is legally based on Art. 6 para. 1 s.1 lit. a) GDPR, thus your consent.‍‍‍


5.3 Purpose of data processing


‍‍The newsletter has the functions of informing the affected parties about offers and news at a regular basis. ‍‍‍


5.4 Duration of storage


‍‍We process personal data only as long as necessary. As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.‍‍


‍5.5 Right to objection and erasure


‍‍The consent to receiving the newsletter can be revoked by you at any time. For this purpose, you can click the integrated link in each newsletter to unsubscribe. It is also possible to inform us about the revocation of the consent in any other way, e.g. via mail or email.‍‍‍


5.6 Click Funnels


‍‍5.6.1 Description and scope of data processing


‍‍The newsletter is sent by " ClickFunnels ", an online marketing platform. The data processing is carried out by: Etison LLC Click funnels, 3443 W. Bavaria St., Eagle, Idaho 83616, USA. ‍‍‍

The e-mail addresses of our newsletter recipients, as well as their other data described in this notice, are stored on Click funnels servers in the USA.  in the EU. Click funnel uses this information to send and evaluate the newsletters on our behalf. Click funnels does not use the data of our newsletter recipients and does not pass it on to third parties. The newsletters contain a so-called "web-beacon", i.e. a pixel-sized file that is retrieved from the Click funnels server when the newsletter is opened. In the course of this retrieval, information such as information about your system, your IP address and the time of the retrieval are collected. The statistical surveys also include the determination of whether the newsletters are opened, how often they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our nor Click funnels' intention to observe individual users. We trust in the reliability and IT and data security of Click funnels.‍‍‍


5.6.2 Legal basis for data processing


‍‍This data processing is legally based on our legitimate interests in efficiently and safely sending our newsletter, Art 6 para. 1 s. 1 lit. f) GDPR.‍‍‍5.6.3 Purpose of data processing
‍‍We use Click funnels as our shipping service provider to ensure effective address management and to keep in touch with you via the newsletter.‍‍‍


5.6.4 Duration of storage


‍‍According to Click funnels, Click funnels stores your personal data only as long as we use your personal data for newsletter delivery. Click funnels deletes your data when we delete you from our address file or delete our account there after a period of 30 days.‍‍‍


5.6.5 Right to objection and erasure


‍‍ You may object to the processing of your data by Click funnels. We will then review your justified objection and inform you whether and why we will continue the data processing. In addition, you are free at any time to use the "opt-out" link at the end of each e-mail, which will result in us deleting your e-mail address from our address file, which is why Click funnels will then also no longer process your personal data. However, this does not affect address files that Click funnels manages on behalf of other clients.‍‍‍


6 Online shopping


‍‍6.1 Description and scope of data processing


‍‍When you shop at our website and a delivery is arranged, we will process your first name and surname, address, telephone number and e-mail address to complete the purchase agreement and the delivery agreement with you.‍

In the case of parcel deliveries, we also pass on your name, address, telephone number and e-mail address to our contracted processors and service providers. ‍‍‍


6.2 Legal basis for data processing


‍‍The legal basis for this data processing is Art. 6 para. 1 s.1 lit. b) GDPR. We are processing your data for the fulfilment of purchase contracts and supply agreements.‍‍‍


6.3 Purpose of data processing


‍‍We process your data to close the contract, to handle the payment, for billing, to ensure on-time delivery and to inform you about that delivery.‍We provide your data to our contracted processors and service providers, so that they can process the delivery and, if necessary, communicate with you to announce and coordinate the delivery of your ordered goods.‍‍‍


6.4 Duration of storage


‍‍We process personal data only as long as necessary. As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.‍‍‍


6.5 Right to objection and erasure


‍‍The data processing is necessary in order to be able to process your purchase contract, which is why it cannot be waived. There is therefore no option to object.‍‍


‍6.6 PayPal


‍‍6.6.1 Description and scope of data processing 


‍‍We offer PayPal as a possible payment service. PayPal is a virtual means of payment. In order to use the payment service via PayPal, you must first register with PayPal. Responsible Person is:‍PayPal (Europe) S.à.r.l. & Cie. S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg.‍‍‍

If the user uses PayPal as a means of payment, personal data of the user will be transmitted to PayPal, to which he ultimately agrees. The personal data includes: ‍‍


• First and last name ‍

• Address ‍

• E-Mail address ‍

• IP-address ‍

• Telephone number ‍

• if necessary mobile number‍

• and other data, which are necessary for the final payment transaction.‍‍‍


In addition to the transfer of data to credit bureaus, it is also possible that PayPal may transfer the personal data to affiliated companies, including subcontractors, as far as this is necessary to fulfill the contractual obligations. The same applies to order processing.‍‍‍

For the privacy policy of PayPal, please refer to the following link: https://www.paypal.com/de/webapps/mpp/ua/privacy-full‍‍‍


6.6.2 Legal basis of data processing


‍‍The legal basis for the data processing is Art. 6 para. 1 s. 1 lit. b) GDPR.‍‍‍


6.6.3 Purpose of data processing


‍‍The transmission of the data is necessary to prevent any possible misuse. We inform you that PayPal may transfer your personal information to credit bureaus. This is because PayPal reserves its right to verify the identity and creditworthiness of the user.‍‍‍


6.6.4 Duration of storage


‍‍We process personal data only as long as necessary. As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.‍‍‍


6.6.5 Right to objection and erasure


‍‍Data processing is mandatory in order to process your payment through PayPal, so it cannot be waived if you have chosen this payment method. Therefore, objecting is impossible or would lead to withdrawal from the contract.‍‍‍


6.7 Stripe


‍‍6.7.1 Description and scope of data processing 


‍‍We offer Stripe as a payment service. With Stripe, you can use payment information stored in your Stripe account to make purchases quickly and securely. To use the payment service through Stripe, prior registration is required. The data processing is carried out by:  Stripe Payments Europe Ltd (subsidiary of Stripe Inc., 510 Townsend Street, San Francisco, CA 94103, USA).‍‍‍

Data processing by Stripe is carried out only for bookings that require online payments. The information collected by Stripe includes: ‍‍‍


• Payment method‍

• Payment method information (e.g. credit or debit card number or bank account details)‍

• Purchase amount‍

• Date of purchase.‍‍‍


Different payment methods may require the collection of different categories of data. The payment method information Stripe collects depends on the payment method you choose.‍‍‍When you complete a transaction, Stripe may also receive: ‍‍‍


• Name‍

• Email address,‍

• Billing or shipping address ‍

• and in some cases your transaction history to authenticate you.‍‍‍


For more information, please see Stripe's privacy policy: https://stripe.com/en-lu/privacy‍   ‍


6.7.2 Legal basis for data processing


‍‍Our legal basis is based on Art. 6 para. 1 s. 1 lit. b) GDPR. ‍‍‍


6.7.3 Purpose of data processing


‍‍The transmission of the data is necessary to prevent any misuse. We inform you that Stripe may transmit the personal data to credit agencies. This is because Stripe reserves the right to check your identity and creditworthiness. ‍‍‍


6.7.4 Duration of storage


‍‍We will only store your data for as long as is necessary to process your payment and invoice you. If you are a Stripe user, Stripe will retain your personal data for as long as the services are provided to you. The data will then be deleted unless there are regulatory, contractual or legal retention obligations that prevent deletion.‍‍‍


6.7.5 Right to objection and erasure


‍‍The data processing is mandatory in order to be able to process your payment via Stripe, which is why it cannot be dispensed with if you have chosen this payment method. There is therefore no possibility to opt out.‍‍‍


7 Social media links

We have integrated social media platforms through into our services, which may result in the social media provider receiving data from you. If you click on the social media link, the website of the respective social media provider is loaded. By loading the website of the respective social media provider via our services, the respective reference data is transmitted to the respective social media provider. The social media provider thereby receives the information that you have visited us. ‍‍‍Note on data processing to the United States: If you click on a social media link, data about you may be processed by the respective provider in the United States. According to the European Court of Justice, the data protection standard in the United States is not adequate and there is a risk that your data will be processed by the U.S. authorities for control and monitoring purposes, possibly also without any legal remedy. Provided that you do not click on the links of the social media providers, no data transfer takes place.‍‍‍


Further information on data processing by the social media providers can be found here:‍‍‍

Facebook: https://de-de.facebook.com/help/pages/insights

https://de-de.facebook.com/about/privacy

https://de-de.facebook.com/full_data_use_policy

LinkedIn: https://www.linkedin.com/legal/privacy-policy

Twitter: https://twitter.com/privacy?lang=de‍

YouTube: https://www.google.de/intl/de/policies/privacy/‍

Instagram: https://help.instagram.com/155833707900388 

https://www.instagram.com/about/legal/privacy/‍‍‍8 

Tracking and analytics
‍‍For the continuous improvement of our website we use the following tracking and analytics tools. Below you can find information on which personal data is processed in each case and how you can reach the respective service providers:‍‍‍


8.1 Facebook Custom Audience / Facebook-Pixel


‍‍8.1.1 Description and data processing


‍‍Our website uses Meta’s Facebook Custom Audience or Facebook Pixel to measure conversions. Data processing is carried out by: Meta Platforms Ireland Limited, 1 Hacker Way, Menlo Park, CA 94025, USA.‍‍‍

With the help of the Facebook Pixel, we can analyze the behaviour of our website’s visitors. As a result, the effectiveness of Meta advertisements can be evaluated. Meta receives the following data:‍‍‍


• the redirect URL, ‍

• browser information,‍

• and the person's Facebook user ID if they have a Facebook account ‍‍‍


The data is stored and processed by Meta, so that a connection to the respective user profile is possible and Meta can use the data for its own advertising purposes, according to the Meta data usage directive. As a result, Meta can enable ads to be displayed on Facebook and outside of Facebook. This use of data cannot be influenced by us as the site operator. You can find Meta’s data privacy policy here: https://www.facebook.com/about/privacy/ ‍‍‍


8.1.2 Legal basis of data processing


‍‍The legal basis for processing data is your given consent, Art. 6 para. 1 s. 1 lit. a) GDPR. ‍‍‍


8.1.3 Purpose of data processing


‍‍We process your data to continue the optimization of our website and our advertising activities.‍‍‍


8.1.4 Duration of storage


‍‍The data will be deleted as soon as they are no longer needed for our recording purposes.‍‍‍


8.1.5 Right to objection and erasure


‍‍You can deactivate the remarketing feature "Custom Audiences" in the Ads Settings section of Meta:‍‍‍ https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen, if you have a Facebook account. If you do not have a Facebook account, you can disable Meta’s usage-based advertising on the European Interactive Digital Advertising Alliance website:‍‍‍ http://www.youronlinechoices.com/de/praferenzmanagement/‍‍‍


8.2 Google Analytics


‍‍8.2.1 Description and scope of data processing


‍‍Our website uses Google Analytics. This is a service for analyzing access to websites of Google Inc. ("Google") and allows us to improve our website.  Data processing for the European Economic Area and for Switzerland is carried out by:

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.‍

Cookies enable us to analyze your use of our website. The information collected by a cookie are:‍‍‍


• IP address‍

• Access time ‍

• Access Duration‍‍‍


The information is transmitted to a Google server in the USA and stored there. The evaluation of your activities on our website is transmitted to us in the form of reports. Google may pass on the collected information to third parties, if required by law or if third parties process this data on behalf of Google. The Google tracking codes of our Internet offer use the function "_anonymizeIp ()", thus IP addresses are processed only shortened, in order to exclude a possible direct personal link to you. Under https://www.google.de/intl/de/policies/ as well as under http://www.google.com/analytics/terms/de.html you can find out more about the terms of use and privacy policy of Google Analytics.‍‍‍


8.2.2 Legal basis of data processing


‍‍The legal basis is your given consent, Art. 6 para 1 s. 1 lit. a) GDPR. ‍‍‍


8.2.3 Purpose of data processing


‍‍By processing the data, we can analyze how our website is used, so we can improve it for our users. ‍‍


‍8.2.4 Duration of storage


‍‍The data will be deleted after 50 months or will be deleted 50 months after your last website visit.‍‍‍


8.2.5 Right to objection and erasure


‍‍You can prevent the installation of cookies by Google Analytics in your browser settings. In this case, however, it may happen that you cannot fully use all features of our website. Also, trough browsers extensions e.g. http://tools.google.com/dlpage/gaoptout?hl=de Google Analytics can be disabled and controlled. ‍‍‍


8.3 Google Tag Manager


‍‍8.3.1 Description and scope of data processing


‍‍Google Tag Manager is a solution that allows us to manage so-called website tags via an interface (and thus, for example, integrate Google marketing services into our online offer). The Tag Manager serves as a "manager" of the implemented tags. This allows us to centrally manage integrated Google products or other analysis tools on our website. The tags embedded on the website are referred to as sections of code that make it possible to track your activities on our website. By using our website, users download the Google Tag Manager, which automatically results in the user's IP address being forwarded to Google With regard to the processing of personal data, please refer to the information on Google services. Data processing for the European Economic Area and Switzerland is carried out by: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.‍‍‍ You can access the usage guidelines of the Google Tag Manager here: https://www.google.com/intl/de/tagmanager/use-policy.html


8.3.2 Legal basis for data processing


‍‍The legal basis for the processing of personal data is your consent pursuant to Art. 6 para. 1 s. 1 lit. a) GDPR.‍‍‍


8.3.3 Purpose of data processing


‍‍Google Tag Manger simplifies the management and organization of the analysis tools used for the website. In order to integrate an analysis tool, JavaScript codes must be integrated into the website. By using Google Tag Manger, it is possible for us to manage these embedded codes from one place. ‍‍‍


8.3.4 Duration of storage


‍‍Since data storage is not carried out directly by Google Tag Manager, but the data is forwarded to the tracking tools, it is necessary to check with the individual embedded tracking tools how long the data is stored.‍‍‍


8.3.5 Right to objection and erasure


‍‍You have the option at any time to revoke a given consent to data processing with effect for the future. For this, you would have to contact the respective data protection officers of the tools. Further information regarding the management of your data can be found in the data protection statements of the tools used. ‍‍‍


9 Tools for advertisement and marketing


‍‍Tools are also included on our website to ensure that our website is displayed to you during an internet search, as a relevant search result or as an advertisement. Below, the programs used in connection with our website have been broken down for you:‍‍‍


9.1 Google Ad Manager (former Double Click)


‍‍9.1.1 Description and scope of data processing


‍‍We use Google Ad Manager. Data processing for the European Economic Area and for Switzerland is carried out by:‍Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.‍‍‍

Google Ad Manager uses information of your visits of this and other websites to generate advertisements of products and services that might interest you. For further information on the methods used or what you can do to prevent Google Ad Manager from using this information, please refer to the following link:‍‍‍ https://www.google.de/policies/technologies/ads/


9.1.2 Legal basis of data processing


‍‍Legal basis is Art. 6 para 1 s. 1 lit. a) GDPR. ‍‍‍


9.1.3 Purpose of data processing


‍‍We use Google Ad Manager to generate advertisements for our website visitors. Our interest is to cooperate with other companies to reach a broader audience.‍‍‍


9.1.4 Duration of storage


‍‍The data will be deleted as soon as they are no longer needed for our recording purposes.‍‍‍


9.1.5 Right to objection and erasure


‍‍The setting of cookies can be prevented by appropriate settings in your Internet browser at any time. The already set cookies can also be deleted in the settings of the Internet browser. We express our concern that preventing cookies from being set may mean that not all features are fully available.‍‍‍


9.2 Google Ads


‍‍9.2.1 Description and scope of data processing


‍‍We have integrated the services of Google Ads (formerly Google AdWords) on our website. Google Ads is an internet advertising service. We use Google Ads to gain relevance in the results of Google's search engine. Data processing for the European Economic Area and for Switzerland is carried out by: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.‍

If the user accesses our website through a Google ad, Google will set a so-called conversion cookie on the user's system. For the explanation of the cookies, please refer to the pass to the cookies. The conversion cookie is used to create and analyze web-use statistics.‍‍‍ The conversion cookie stores the IP address when visiting the website. This data is stored in the USA. It is possible that Google will share this information with third parties.  ‍‍‍For further privacy notices of Google refer to: https://policies.google.com/privacy?hl=en&gl=de‍‍‍


9.2.2 Legal basis of data processing


‍‍The legal basis is your consent pursuant to Art. 6 para. 1 s. 1 lit. a) GDPR. ‍‍‍


9.2.3 Purpose of data processing


‍‍In particular, we use Google Ads to gain relevance in the results of Google's search engine.These advertisements are carried out to reach a greater audience. ‍‍‍


9.2.4 Duration of storage


‍‍30 days after setting the conversion cookie the cookie loses its validity. This means that the user can no longer be identified. Within these 30 days both- us and Google can track which subpages have been accessed.‍‍‍


9.2.5 Right to objection and erasure


‍‍The setting of cookies can be prevented by appropriate settings in the user's Internet browser at any time. The already set cookies can also be deleted in the settings of the Internet browser. We express our concern that preventing cookies from being set may mean that not all features are fully available.‍The user may separately object to interest-based personalized advertising by Google. Please refer to the following link: www.google.de/settings/ads ‍‍‍


9.3 Google AdSense


‍‍9.3.1 Description and scope of data processing


‍‍We use Google AdSense on the website. This is an online service used for promotional purposes. Google AdSense allows the placement of advertisements on third party websites.  Data processing for the European Economic Area and for Switzerland is carried out by:‍‍‍Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.‍‍‍

Google AdSense places a cookie on the affected person. Regarding the clarification of “cookies”, see the passage on cookies above. The information stored by cookie can be recorded, collected and evaluated by Google Inc. or third parties. In addition, Google AdSense also uses so-called "WebBacons" (small invisible graphics) for the collection of information, through the use of which simple actions such as the visitor traffic on the website can be recorded, collected and evaluated.‍


The information generated by the cookie and / or WebBeacon about your use of this website is transmitted to a Google server in the USA and stored there. Google uses the information to evaluate your web behaviour with respect to the AdSense ads. Google may also transfer this information to third parties if required by law or as far as third parties process this data on behalf of Google. Your IP address will not be associated with other Google data stored by Google.‍‍‍For more information about Google AdSense, please refer to the following link: https://www.google.de/intl/de/adsense/start/‍‍‍


9.3.2 Legal basis of data processing


‍‍Legal basis is the Art. 6 para 1 s. 1 lit. a) GDPR. Our interest is to gain popularity by using these advertisements.‍‍‍


9.3.3 Purpose of data processing


‍‍The purpose of data processing is to reach a wider audience by using targeted advertisements.‍‍‍


9.3.4 Duration of storage


‍‍The data will be deleted as soon as they are no longer needed for our recording purposes.‍‍‍


9.3.5 Right to objection and erasure


‍‍The user can prevent the storage of cookies on his hard drive and the display of WebBeacons by making the appropriate settings in the browser.‍‍‍For more information about Google AdSense, please refer to the link below: https://www.google.de/intl/de/adsense/start/‍‍‍


9.4 Google Remarketing


‍‍9.4.1 Description and scope of data processing


‍‍We use Google Remarketing. ‍Data processing for the European Economic Area and for Switzerland is carried out by:‍‍‍Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.‍‍‍

Google Remarketing works by setting a cookie on the user. This cookie use gives Google the opportunity to recognize the user if they visit a website that also uses Google Remarketing.‍

As a result, Google will be notified of the user's IP address or browsing behaviour.‍‍‍


9.4.2 Legal basis of data processing


‍‍Data processing is based on your consent in accordance with Art. 6 para. 1 s. 1 lit. a) GDPR. ‍‍


‍9.4.3 Purpose of data processing


‍‍By using Google Remarketing, we may display advertisements to users that have previously logged into our website. Google Remarketing ultimately enables user-directed personalized advertising.‍‍‍


9.4.4 Duration of storage


‍‍The data will be deleted as soon as they are no longer needed for our recording purposes.‍‍‍


9.4.5 Right to objection and erasure


‍‍The prevention (as well as the erasure) of the cookie setting can be achieved under the appropriate settings in the Internet browser.‍

The user can object to user-related advertising by Google at any time. For this we refer to: https://policies.google.com/?hl=en ‍‍‍10 Service providers from third countries
‍‍In order to be able to provide our services, we use the support of service providers from third party countries (non-EU countries). In order to ensure the protection of your personal data in this case, we conclude processing contracts with each - carefully selected - service provider. All of our processors provide sufficient guarantees to implement appropriate technical and organizational measures. Our third country data processors are either located in a country with an adequate level of data protection (Art. 45 GDPR) or provide appropriate safeguards (Art 46 GDPR). ‍‍‍Adequate level of protection: The provider comes from a country whose level of data protection has been recognized by the EU Commission. 

For more information, see: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en ‍‍‍

EU standard contract clauses: Our provider has submitted to the EU standard contractual clauses to ensure secure data transfer. For more information, see: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX%3A32021D0914&locale=en ‍‍‍

Binding Corporate Rules: Article 47 of the GDPR provides the possibility of ensuring data protection when transferring data to a third country via Binding Corporate Rules. These are examined and approved by the data security authorities within the framework of the consistency mechanism pursuant to Art. 63 GDPR. ‍‍‍Consent: In addition, a data transfer to a third country without an adequate level of protection will only take place if you have given us your consent in accordance with Art. 49 sec. 1 lit. a) GDPR for this purpose.‍‍‍


11 Your rights


‍‍You have the following rights with respect to the personal data concerning you: ‍‍‍


11.1 Right to withdraw a given consent (Art. 7 GDPR)


‍‍If you have given your consent to the processing of your data, you can withdraw it at any time. This will affect the admissibility of processing your personal data by us for the time after you have withdrawn your consent. To withdraw your consent, contact us personally or in written form.‍‍‍


11.2 Right of access (Art. 15 GDPR)


‍‍You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to your personal data and the following information:‍


• the purpose of processing;‍

• the categories of personal data concerned;‍

• the recipients or the categories of recipient to whom your personal data have been or will be disclosed, in particular recipients in countries outside of the EU or international organisations; ‍

• where possible, the envisaged period for which your personal data will be stored, or, if not possible, the criteria used to determine that period;‍

• all available information on the source of your personal data;

• the existence of automated decision-making, including profiling, referred to Art. 22 para. 1 and 4 GDPR and, in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.‍‍‍In the case of such a request, you must provide enough information about your identity to proof that the request concerns your own personal data.‍‍‍


11.3 Right to rectification and erasure (Art. 16, 17 GDPR)


‍‍You have the right to obtain from us without undue delay the rectification and completion of inaccurate personal data concerning yourself.‍

You may also request the erasure of your personal data if any of the following applies to you:‍‍‍


• the personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed;‍

• you withdraw consent on which the processing is based according to Art. 6 para. 1 s.1 lit. a) or Art. 9 para. 2 lit. a) GDPR, and where there is no other legal ground of processing;‍

• you object to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for the processing, or the you object to the processing pursuant to Art. 21 para. 2 GDPR;‍

• the personal data have been unlawfully processed;‍

• the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which we are subject;‍

• the personal data have been collected in relation to the offer of information society services referred to in Art. 8 para. 1.‍‍‍Where we made the personal data public and are obliged to erase the personal data pursuant to Art. 17 para. 1 GDPR, we, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.‍‍‍


These rights shall not apply to the extent that processing is necessary:‍‍‍


• for exercising the right of freedom of expression and information;‍

• for compliance with a legal obligation which requires processing by Union or Member State law to which we are subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;‍

• for reasons of public interest in the area of public health in accordance of Art. 9 para. 2 lit. h) and i) as well as Art. 9 para. 3 GDPR;‍

• for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 para. 1 GDPR, in so far as the right referred to above is likely to render impossible or seriously impair the achievement of the objectives of that processing, or‍

• for the establishment, exercise or defence of legal claims.‍‍‍


11.4 Right to restriction of processing (Art. 18 GDPR)


‍‍You shall have the right to obtain from us restriction of processing where one of the following applies:‍‍‍


• the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;‍


• the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;‍


• we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;‍


• you have objected to processing pursuant to Art. 21 para. 1 GDPR pending the verification whether our legitimate grounds override yours.‍‍


‍Where processing has been restricted under the aforementioned conditions, such personal data shall, except for storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.‍

If the limitation of the processing is restricted, you will be informed by us before the restriction is lifted.‍‍‍


11.5 Right to information (Art. 19 GDPR)


‍‍If you have asserted us your right to rectification, erasure or restriction of data processing, we will inform all recipients of your personal data to correct, delete or restrict the processing of data, unless this proves impossible or involves disproportionate effort.‍You also have the right to know which recipients have received your personal data.‍‍‍


11.6 Right to data portability (Art. 20 GDPR)


‍‍You have the right to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format. Also, you have the right to transmit those data to another controller, where‍


• the processing is based on consent pursuant of Art. 6 para. 1 s.1 lit. a) GDPR or of Art. 9 para. 2 lit. a) GDPR or is based on a contract pursuant of Art. 6 para. 1 s. 1 lit. b) DS-GVO; and‍


• the processing is carried out by automated means.‍‍


‍In exercising your right to data portability, you have the right to obtain that personal data transmitted directly from us to another controller, as far as technically feasible. The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority that has been delegated to us.‍‍‍


11.7 Right to object (Art. 21 GDPR)


‍‍Where we based the processing of your personal data on a legitimate interest (Art. 6 para. 1 s. 1 lit. f) GDPR), you may object to the processing. The same applies if the data processing is based on Art. 6 para. 1 s. 1 lit. e).‍

In this case, we ask you to explain the reasons why we should not process your personal data. Based on this we will terminate or adapt the data processing or show you our legitimate reasons why we continue the data processing.‍‍‍


11.8 Right to lodge a complaint with supervisory authority (Art. 77 GDPR)


‍‍Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you is against the infringes of the GDPR.‍‍‍

The supervisory authority to which the complaint has been submitted shall inform you of the status and results of the complaint, including the possibility of a judicial remedy according to Article 78 GDPR.‍‍‍


12 How you perceive these rights


‍‍To exercise these rights, please contact our data protection officer:‍‍‍


Kemal Webersohn from Webersohn & Scholtz GmbH ‍

ajsmart@ws-datenschutz.com  ‍‍‍

or by mail:‍‍‍

WS Datenschutz GmbH

Dircksenstraße 51 D-10178 Berlin‍‍‍


13 Subject to change


‍‍We reserve the right to change this privacy policy in compliance with legal requirements.‍


‍May 2024‍

© 2024 AJ&Smart. All Rights Reserved.

© 2024 AJ&Smart. All Rights Reserved.

© 2024 AJ&Smart. All Rights Reserved.