CLASSPOP!
PRIVACY POLICY
FOR USE IN THE EUROPEAN UNION (“EU”), EUROPEAN ECONOMIC AREA (“EEA”), UNITED KINGDOM (“UK”), AND SWITZERLAND
(Last revised on July 25, 2024)
This Privacy Policy (“Policy”) is for all users in the EU, EEA, UK, and Switzerland. To review the Policy for users in other parts of the world, please see below:
US: Privacy Policy
Canada: Privacy Policy
Rest of the World: Privacy Policy
1. GENERAL
This Privacy Policy (“Policy”) describes how Classpop, Inc. (“Company,” “Classpop!,” “we,” or “us”) collects, uses, and shares personal information of consumer users of this website, www.classpop.com (the “Site”). This Policy also applies to any of our other websites that post this Policy. This Policy does not apply to websites that post different privacy statements or policies. Capitalized terms used herein but undefined have the meaning given to them in our Terms of Use. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration below (Section 3.6).
1.1 DATA RECORDING AND PROCESSING ON THIS SITE
The data on this website is processed by the Site Operator,
Classpop, Inc.
80 SW 8th St, Suite 2000
Miami, FL 33130
USA
Classpop, Inc.
80 SW 8th St, Suite 2000
Miami, FL 33130
USA
1.2 HOW DO WE RECORD AND PROCESS YOUR DATA?
We collect your data as a result of your sharing of your data with us and process them as follows.
Information You Give Us
- When you create an account to log in to our network, we may collect personal information from you, such as your first and last names, email addresses, usernames, and passwords.
- When you post content (text, images, photographs, messages, comments, or any other kind of content that is not your email address) on our Site, the information contained in your posting will be stored on our servers, and other users may be able to see it, along with your first name and first initial of your last name, profile photo and any other information that you choose to make public on your public profile page (“Profile”). Other users with whom you are connected via Facebook or the Services may also be able to see your full last name.
- If you host an Event (such as a class), we may collect the address of the location where the event will be held, along with your phone number, in order to share this information with the attendees of your event. For example, if you, as a host, will be hosting a class, we may share the address where your dinner class will be held, along with your phone number, with those Guests who will be attending the event so that they can contact you and attend the event. Likewise, if you are a Guest who will be hosting an event, we may share your phone number and the address of your event with the Vendor (e.g., chef, florist, artist, photography instructor, etc.) if you book the Vendor to provide services at your own venue, e.g., for a chef to cook for you at your own venue.
- If you register as a Vendor (e.g., chef, florist, artist, photography instructor, etc.) on the Site, we may collect certain information about your credentials, references, and/or other information you provide to us in connection with the registration process and may share it with Guests who will be hosting an event.
- We also collect payment information, including your name, credit/debit card information, and billing information, in order to make payments to the Hosts of Events you attend.
- We may collect personal information from you, such as your name, email address, postal address, phone number, and any other information you provide us when you create or book an Event and/or register for a Member Account. We may share this information with a Host or Guests, as applicable.
- If you provide feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.
- When you post comments, reviews, testimonials, or ratings on our Site (“Reviews”), the information contained in your posting will be stored on our servers, and other users will be able to see it. This information may also be shared with Facebook for posting on your Facebook wall or timeline.
- When you participate in one of our surveys, we may collect additional profile information about you to the extent permitted by law.
- If you participate in a sweepstakes, contest, or giveaway on our Site, we may ask you for your email address and/or home phone number (to notify you if you win or not). We may also ask for your first and last names and sometimes post office addresses to verify your identity. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules for each sweepstakes and contest that you enter.
- We may also collect personal information at other points on our Site that state that personal information is being collected.
- Other data might be collected by our IT systems automatically and after you consent to its recording during your website visit, as applicable. This data compromises primarily technical information (e.g., web browser, operating system, or time the Site was accessed).
1.3 WHAT ARE THE PURPOSES WE USE YOUR DATA?
We use your data for the purposes stated under Section 1.2 above (“How Do We Record and Process Your Data?”) and for the general performance of the services provided to you. Some information is generated to permit the error-free provision of the Site and for the enhancement of our Site or the services. Other data may be used to analyze your user patterns, as further described below.
1.4 WHAT RIGHTS DO YOU HAVE AS FAR AS YOUR INFORMATION IS CONCERNED?
You have the right to receive information about the source, recipients, and purposes of your stored personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data be rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing unless we are permitted to further process your data based on other legal grounds. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to file a complaint with the competent supervising agency.
Please do not hesitate to contact us at any time if you have questions about this or any other data protection-related issues.
Please do not hesitate to contact us at any time if you have questions about this or any other data protection-related issues.
1.5 ADVERTISING
This Site is affiliated with CMI Marketing, Inc., d/b/a Raptive ("Raptive") for the purposes of placing advertising on the Site, and Raptive will collect and use certain data for advertising purposes. To learn more about Raptive’s data usage and the data that is collected and processed, click here.
1.6 CHILDREN’S PRIVACY
Our Services are intended for a general audience. We do not direct our Services to children under sixteen (16), nor do we knowingly solicit or collect any Personal Information from children under the age of sixteen (16). If you are a parent or legal guardian and think that your child has given us data you can contact us in writing or by email. Please mark your inquiries as “Children’s Privacy Information Request.” If we learn that a minor has provided Personal Information through our Services, we will use reasonable efforts to remove such information from our files.
2. HOSTING
2.1 EXTERNAL HOSTING
This Site is hosted by an external service provider (Hosting Provider). Personal data collected on this Site is stored on the servers of the Hosting Provider. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a website.
The Hosting Provider is used for the purpose of fulfilling our contract with our potential and existing customers (EEA/UK: Art. 6(1) (b) GDPR) and in the interest of secure, fast, and efficient provision of our online services by a professional provider (EEA/UK: Art. 6(1) (f) GDPR).
Our Hosting Provider will only process your data to the extent necessary to fulfill its performance obligations and to follow our instructions with respect to such data.
We are using the following Hosting Provider:
Amazon Web Services, Inc.,
410 Terry Avenue North
Seattle, WA 98109-5210
Amazon Web Services, Inc.,
410 Terry Avenue North
Seattle, WA 98109-5210
3. GENERAL AND MANDATORY INFORMATION
3.1 DATA PROTECTION
We and this Site take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the applicable statutory data protection regulations and this Policy.
Although we are a company registered and domiciled in Miami, USA, we will collect and process your personal data under the European and UK rules of the General Data Protection Regulation (“GDPR”) and, with respect to Switzerland, under the Swiss Data Protection Act.
Whenever you use this Site, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Policy explains which data we collect as well as the purposes we use this data for. It also explains how and for which purpose the information is collected.
We herewith advise you that data transmission via the Internet (e.g., through email communications) may be prone to security gaps. It is not possible to completely protect data against unsolicited and harmful third-party access.
3.2 INFORMATION ABOUT THE RESPONSIBLE PARTY (THE “CONTROLLER” UNDER THE GDPR)
The data processing controller on this Site is:
Classpop, Inc.
80 SW 8th St, Suite 2000
Miami, FL 33130
USA
email: customerservice@classpop.com
The controller is an entity that single-handedly or jointly with third parties makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).
Classpop, Inc.
80 SW 8th St, Suite 2000
Miami, FL 33130
USA
email: customerservice@classpop.com
The controller is an entity that single-handedly or jointly with third parties makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).
3.3 STORAGE DURATION
Unless a more specific storage period is specified in this Policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing or processing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.
3.4 INFORMATION ON DATA TRANSFER TO THE USA AND OTHER NON-EU COUNTRIES
Among other things, we are domiciled in the United States, a country that does not have a European data protection perspective nor a data protection regime adequate with the data protection rules of the EU. If you communicate with us or the Site, your personal data is subject to the relevant federal and state laws, which may permit the transfer of your data to third parties. U.S. companies might be forced, under very specific circumstances, to disclose certain personal data to security agencies, and you might have only limited options to defend the protection of your personal data before courts. With respect to data transfer into the US, we rely on the EU Standard Contractual Clauses as further described below.
3.5 REVOCATION OF YOUR AGREEMENT TO THE PROCESSING OF DATA
It might be that you will, on our request, expressly consent to the processing of your personal data. You may revoke any such consent you have given us at any time. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.
3.6 RIGHT TO OBJECT TO THE COLLECTION OF YOUR DATA IN SPECIAL CASES; RIGHT TO OBJECT TO DIRECT ADVERTISING (EE/UK: ART. 21 GDPR)
In the event that data is processed based on Art. 6(1)(e) or (f) GDPR, you have the right to at any time object to the processing of your personal data based on grounds arising from your unique situation. This also applies to any profiling based on these provisions. To determine the legal basis on which any processing of data is based, please consult this Data Protection Declaration. If you object, we will no longer process your affected personal data unless we are able to present compelling grounds for the processing of your data that outweigh your interests, rights, and freedoms or if the purpose of the processing is the claiming, exercising, or defense of legal claims (objection pursuant to Art. 21(1) GDPR).
If we process your personal data for direct advertising, you have the right to object to the processing of your affected personal data for the purposes of such advertising at any time. This also applies to profiling to the extent that it is affiliated with such direct advertising. If you object, your personal data will subsequently no longer be used for direct advertising purposes (objection pursuant to Art. 21(2) GDPR).
Upon exercising your rights, we cannot exclude that we cannot perform the services that you have ordered or expected.
3.7 RIGHT TO FILE COMPLAINTS WITH THE COMPETENT SUPERVISORY AGENCY
In the event of GDPR or Swiss DPA violations, data subjects are entitled to file a complaint with a supervisory agency, in particular the member state where they usually maintain their domicile, place of work, or place where the alleged violation occurred. The right to file a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.
3.8 RIGHT TO DATA PORTABILITY
You have the right to demand that we hand over any data we automatically process based on your consent in a commonly used, machine-readable format in order to fulfill a contract or to a third party. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.
3.9 ENCRYPTED PAYMENT TRANSACTIONS ON THIS SITE
If you are under an obligation to share your payment information (e.g., account number if you give us the authority to debit your bank account) with us after you have entered into a fee-based contract with us, this information is required to process payments.
Payment transactions using common modes of paying (Visa/MasterCard, debit to your bank account via PayPal, for example) are processed exclusively via encrypted SSL or TLS connections. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.
If the communication with us is encrypted, third parties will not be able to read the payment information you share with us.
3.10 INFORMATION ABOUT, RECTIFICATION AND ERASURE OF DATA
Within the scope of the applicable law, you have the right to demand information about your stored personal data, their source and recipients, and the purpose of the processing of your data at any time. You may also have a right to have your data rectified or eradicated.
3.11 RIGHT TO DEMAND PROCESSING RESTRICTIONS
You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:
- In the event that you should dispute the correctness of your data stored by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
- If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data.
- If we no longer need your personal data and you need it to exercise, defend, or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
- If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction on the processing of your personal data.
4. COLLECTION OF DATA ON THIS SITE
Note: Referrals to the GDPR apply to the EU/EEA and the UK. With respect to Switzerland, the Swiss Data Protection Act (DPA) provides for similar provisions.
4.1 COOKIES
Our Sites and pages use what the industry refers to as “cookies.” Cookies are small text files that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies), or they are permanently stored on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain stored on your device until you actively delete them or your web browser automatically removes them.
In some cases, it is possible that third-party cookies are stored on your device once you enter our Site (third-party cookies). These cookies enable you or us to take advantage of certain services offered by the third party (e.g., cookies for the processing of payment services).
Cookies have various functions. Many are technically essential since certain website functions (e.g., the shopping cart function or the display of videos) would not work without them. The purpose of other cookies may be to analyze user patterns or display promotional messages.
Cookies, which are required for the performance of electronic communication transactions (required cookies) or for the provision of certain functions you want to use (functional cookies) or those that are necessary for the optimization of the Site (e.g., cookies that provide measurable insights into the web audience), are stored based on Art. 6(1) (f) GDPR, unless a different legal basis is cited. The operator of the Site has a legitimate interest in the storage of cookies to ensure the technically error-free and optimized provision of the operator’s services. If your consent to the storage of the cookies has been requested, the respective cookies are stored exclusively on the basis of the consent obtained (Art. 6(1) (a) GDPR). Any such consent may be revoked at any time.
You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this Site may be limited.
In the event that third-party cookies are used or if cookies are used for analytical purposes, we will notify you separately in conjunction with this Policy and, if applicable, ask for your consent.
4.2 SERVER LOG FILES
The provider of this Site and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises the following:
This data is recorded based on Art. 6(1) (f) GDPR. The Site operator has a legitimate interest in the technically error-free depiction and the optimization of the operator’s Site. In order to achieve this, server log files must be recorded.
- The type and version of browser used
- The operating system used
- Referrer URL
- The hostname of the accessing computer
- The time of the server inquiry
- The IP address
This data is recorded based on Art. 6(1) (f) GDPR. The Site operator has a legitimate interest in the technically error-free depiction and the optimization of the operator’s Site. In order to achieve this, server log files must be recorded.
4.3 PERFORMANCE OF SERVICES
If you request a service, we may record and process the data you provide to us for the purpose of rendering those services to you. The processing of this data is based on Art. 6(1) (b) GDPR (performance of a contract or data necessary for a pre-contractual relationship).
4.4 PROCESSING FOR THE ENHANCEMENT OF OUR SITE AND SERVICES
To the extent permitted by law, we may use your data and information for the enhancement of our Site and services. This processing is based on Art. 6(1) (f) GDPR (processing on legitimate grounds).
4.5 CONTACT FORM
If you submit inquiries to us via our contact form, the information provided in the contact form, as well as any contact information provided therein, will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.
The processing of this data is based on Art. 6(1) (b) GDPR, if your request is related to the performance of a contract or if it is necessary for a pre-contractual relationship. In all other cases, the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1) (f) GDPR) or on your agreement (Art. 6(1) (a) GDPR) if this has been requested.
The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data, or if the purpose for which the information is being stored no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions, in particular retention periods.
4.6 REQUEST BY EMAIL, TELEPHONE, OR FAX
If you contact us by email, telephone, or fax, your request, including all resulting personal data, will be stored and processed by us for the purpose of processing your request. This data is processed based on Art. 6(1) (b) GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6(1) (f) GDPR) or on the basis of your consent (Art. 6(1) (a) GDPR) if it has been obtained.
The data you send to us via contact requests remain with us until you request us to delete or revoke your consent to the storage or if the purpose for the data storage lapses (e.g., you complete your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.
4.7 REGISTRATION ON THIS SITE
You have the option to register on this Site to be able to use additional website functions. We shall use the data you enter only for the purpose of using the respective offer or service you have registered for. The required information we request at the time of registration must be entered in full. Otherwise, we shall reject the registration.
We shall use the email address provided during the registration process to notify you of any important changes to the scope of our portfolio or in the event of technical modifications.
We shall process the data entered during the registration process based on your consent (Art. 6(1) (a) GDPR).
We will store the data recorded during the registration process as long as you are registered on this Site. Subsequently, such data will be deleted without prejudice to mandatory statutory retention obligations.
4.8 REGISTRATION WITH GOOGLE
Instead of registering directly on this Site, you can register with Google. This service is provided by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
To register with Google, you must enter your Google name and password. Google will identify you and confirm your identity on our Site.
When you register and sign in with Google, we may be able to use certain information in your account to complete your profile with us. You decide whether you want this information to be used and, if so, which information it is within the framework of your Google security settings, which you can find here: https://myaccount.google.com/security and https://myaccount.google.com/permissions.
The data processing associated with Google’s registration is based on our legitimate interest in making the registration process as simple as possible for our users (Art. 6(1) (f) GDPR). Since the use of the registration function is voluntary and the users themselves can decide on the respective access options, no conflicting predominant rights of the data subjects are apparent.
4.9 REGISTRATION WITH FACEBOOK CONNECT
You can register using Facebook Connect instead of directly on this Site. The provider of this service is Meta Platforms (“Meta”) Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Meta’s statement the collected data will be transferred to the USA and other third-party countries too.
If you decide to register via Facebook Connect and click on the “Login with Facebook” or ”Connect with Facebook” button, you will be automatically connected to the Facebook platform. There, you can log in using your username and password. As a result, your Facebook profile will be linked to this Site or the services. This link gives us access to the data you have stored with Facebook. This data comprises primarily the following:
- Facebook name
- Facebook profile photo and cover photo
- Facebook cover photo
- E-mail address stored with Facebook
- Facebook-ID
- Facebook friends list
- Facebook Likes (“Likes” information)
- Date of birth
- Gender
- Country
- Language
The registration via Facebook Connect and the affiliated data processing transactions are implemented based on your consent (Art. 6(1) (a) GDPR). You may revoke this consent at any time, which shall affect all future transactions thereafter.
Insofar as personal data is collected on our Site with the help of the tool described here and forwarded to Meta, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Meta. The processing by Meta that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found at: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook tool and for the privacy-secure implementation of the tool on our Site. Meta is responsible for the data security of Facebook products. You can assert data subject rights (e.g., requests for information) regarding data processed by Meta directly with Meta. If you assert the data subject rights with us, we are obliged to forward them to Meta.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum, https://de-de.facebook.com/help/566994660333381 and https://www.facebook.com/policy.php.
For more information, please consult the Facebook Terms of Use and Meta’s Privacy Policy. To access this information, use these links: https://www.facebook.com/about/privacy/ and https://www.facebook.com/legal/terms/.
4.10 THE COMMENT FUNCTION ON THIS SITE
When you use the comment function on this Site, information on the time the comment was generated and, if you are not posting anonymously, the username you have selected will be stored in addition to your comments.
4.11 THE CHAT FUNCTION ON THIS SITE
When you use the chat function on this Site, information on the time your chat was generated and, if you are not posting anonymously, the username you have selected will be stored in addition to your comments.
4.12 STORAGE OF THE IP ADDRESS
Our comment and chat function stores the IP addresses of all users who enter comments. Given that we do not review the comments prior to publishing them, we need this information in order to take action against the author in the event of rights violations, such as defamation.
4.13 STORAGE PERIOD FOR COMMENTS AND CHATS
Comments and any affiliated information will be stored by us and remain on this Site until the content of the comment or chat has been deleted in its entirety or if the comments/chats had to be deleted for legal reasons (e.g., insulting comments).
4.14 LEGAL BASIS
Comments and chats are stored based on your contractual relation with us (Art. Sec. 6(1) (b) GDPR or your consent (Art. 6(1) (a) GDPR). You have the right to revoke your consent (if any) at any time. To do so, all you are required to do is send us an informal notification via email. This is without prejudice to the lawfulness of any data collection that occurred prior to your revocation.
5. SOCIAL MEDIA
5.1 FACEBOOK PLUG-INS (LIKE & SHARE BUTTON)
We have integrated plug-ins of the social network Facebook on this Site. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Meta’s statement, the collected data will be transferred to the USA and other third-party countries, too.
You will be able to recognize Facebook plug-ins by the Facebook logo or the “Like” button on this Site. An overview of the Facebook plug-ins is available under the following link: https://developers.facebook.com/docs/plugins/.
Whenever you visit this Site and its pages, the plug-in will establish a direct connection between your browser and Meta’s server. As a result, Meta will receive the information that you have visited this Site with your plug-in. However, if you click the Facebook “Like” button while you are logged into your Facebook account, you can link the content of this Site and its pages with your Facebook profile. As a result, Meta will be able to allocate the visit to this Site and its pages to your Facebook user account. We have to point out that we, as the provider of the Site, do not have any knowledge of the transferred data and its use by Meta. For more detailed information, please consult the Meta’s Data Privacy Declaration at https://www.facebook.com/privacy/explanation.
If you do not want Meta to be able to allocate your visit to this Site and its pages to your Facebook user account, please log out of your Facebook account while you are on this Site.
The use of the Facebook plug-in is based on Art. 6 (1) (f) GDPR. The Site operator has a legitimate interest in being as visible as possible on social media. If your consent has been granted, the data will be processed exclusively based on Art. 6(1) (a) GDPR. Any such consent may be revoked at any time.
Insofar as personal data is collected on our Site with the help of the tool described here and forwarded to Meta, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Meta. The processing by Meta that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found at: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook tool and for the privacy-secure implementation of the tool on our Site. Meta is responsible for the data security of Meta products. You can assert data subject rights (e.g., requests for information) regarding data processed by Meta directly with Meta. If you assert the data subject rights with us, we are obliged to forward them to Meta.
Data transmission to the US is based on the EU-U.S. Data Privacy Framework and the European Commission’s related adequacy decision. Details can be found here: https://www.facebook.com/policy.php.
5.2 X (FORMERLY TWITTER)
We have integrated functions of the social media platform X (“Twitter”) into this Site. These functions are provided by X Corp., 1355 Market Street, Suite 900, San Francisco, CA 94103 U.S.A. While you use Twitter and the “Re-Tweet” function, websites you visit are linked to your Twitter account and disclosed to other users. During this process, data is transferred to Twitter as well. We must point out that we, the providers of the Site and its pages, do not know anything about the content of the data transferred and the use of this information by Twitter. For more details, please consult Twitter’s Data Privacy Declaration at: https://twitter.com/en/privacy.
The use of Twitter plug-ins is based on Art. 6 (1) (f) GDPR. The Site operator has a legitimate interest in being as visible as possible on social media. If your consent has been granted, the data will be processed exclusively based on Art. 6 (1) (a) GDPR. Any such consent may be revoked at any time.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://gdpr.twitter.com/en/controller-to-controller-transfers.html.
You have the option to reset your data protection settings on Twitter under the account settings at https://twitter.com/account/settings.
5.3 INSTAGRAM PLUG-IN
We have integrated functions of the public media platform Instagram into this Site. These functions are being offered by Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
If you are logged into your Instagram account, you may click the Instagram button to link contents from this Site to your Instagram profile. This enables Instagram to allocate your visit to this Site to your user account. We have to point out that we as the provider of the Site and its pages do not have any knowledge of the content of the data transferred and its use by Instagram.
Data is stored and analyzed based on Art. 6 (1) (f) GDPR. The Site operator has a legitimate interest in the highest possible visibility on social media. If your consent has been granted, the data will be processed exclusively based on Art. 6(1)(a) GDPR. Any such consent may be revoked at any time.
Insofar as personal data is collected on our Site with the help of the tool described here and forwarded to Meta, Facebook, or Instagram, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Meta, Facebook, or Instagram. The processing by Meta, Facebook, or Instagram that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found at: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing privacy information when using the Meta, Facebook, or Instagram tool and for the privacy-secure implementation of the tool on our Site. Meta is responsible for the data security of Facebook or Instagram products. You can assert data subject rights (e.g., requests for information) regarding data processed by Meta, Facebook, or Instagram directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Meta.
Data transmission to the US is based on the EU-US Data Privacy Framework. Details can be found here: https://privacycenter.instagram.com/policies/data_privacy_framework/.
For more information on this subject, please consult Instagram’s Data Privacy Declaration at: https://instagram.com/about/legal/privacy/.
5.4 LINKEDIN PLUG-IN
This Site uses functions of the LinkedIn network. The provider is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.
Any time you access a page of this Site that contains functions of LinkedIn, a connection to LinkedIn’s servers is established. LinkedIn is notified that you have visited this Site with your IP address. If you click on LinkedIn’s “Recommend” button and are logged into your LinkedIn account at the time, LinkedIn will be in a position to allocate your visit to this Site to your user account. We have to point out that we, as the provider of the websites, do not have any knowledge of the content of the transferred data and its use by LinkedIn.
The use of the LinkedIn plug-in is based on Art. 6 (1) (f) GDPR. The operator of the Site has a legitimate interest in being as visible as possible on social media. If your consent has been granted, the data will be processed exclusively based on Art. 6 (1) (a) GDPR. Any such consent may be revoked at any time.
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission and the EU-US Data Privacy Framework. Details can be found here: https://www.linkedin.com/help/linkedin/answer/a1343190?hcppcid=search.
For further information on this subject, please consult LinkedIn’s Data Privacy Declaration at: https://www.linkedin.com/legal/privacy-policy.
5.5 PINTEREST PLUG-IN
We use social plug-ins of the social network Pinterest on this Site. The network is operated by Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland.
If you access a site or page that contains such a plug-in, your browser will establish a direct connection with Pinterest’s servers. During this process, the plug-in transfers log data to Pinterest’s servers in the United States. The log data may possibly include your IP address, the address of the websites you visited, which also contain Pinterest functions. The information also includes the type and settings of your browser, the data and time of the inquiry, and how you use Pinterest and cookies.
Data are stored and analyzed according to Art. 6 (1)(f) GDPR. The Site operator has a legitimate interest in the highest possible visibility on social media. If your consent has been granted, the data will be processed exclusively based on Art. 6 (1) (a) GDPR. Any such consent may be revoked at any time.
For more information concerning Pinterest’s purpose, scope, and continued processing and use of data, as well as your affiliated rights and options to protect your private information, please consult Pinterest’s data privacy information at https://policy.pinterest.com/en/privacy-policy.
6. ANALYSIS TOOLS AND ADVERTISING
6.1 GOOGLE ANALYTICS
This Site uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives various user data, such as pages accessed, time spent on the page, the utilized operating system, and the user’s origin. Google may consolidate this data in a profile that is allocated to the respective user or the user’s device.
Furthermore, Google Analytics allows us to record your mouse and scroll movements and clicks, among other things. Google Analytics uses various modeling approaches to augment the collected data sets and uses machine learning technologies in data analysis.
Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing user behavior patterns (e.g., cookies or device fingerprinting). The website uses information recorded by Google and is, as a rule, transferred to a Google server in the United States, where it is stored.
This analysis tool is used according to Art. 6 (1) (f) GDPR. The Site operator has a legitimate interest in the analysis of user patterns to optimize both the services offered online and the operator’s advertising activities. If your consent is granted (e.g., an agreement to the storage of cookies), data processing takes place exclusively based on Art. 6 (1) (a) GDPR. Any such consent may be revoked at any time.
Data transmission to the US is based on the EU-U.S. and Swiss-U.S. Data Privacy Frameworks. Details can be found here: https://policies.google.com/privacy/frameworks?hl=en-US.
Browser plug-in
You can prevent Google from recording and processing your data by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.
Storage period
Data on the user or incident level stored by Google linked to cookies, user IDs or advertising IDs (e.g., DoubleClick cookies, Android advertising ID) will be anonymized or deleted after 14 months. For details, please click the following link: https://support.google.com/analytics/answer/7667196?hl=en.
Browser plug-in
You can prevent Google from recording and processing your data by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.
Storage period
Data on the user or incident level stored by Google linked to cookies, user IDs or advertising IDs (e.g., DoubleClick cookies, Android advertising ID) will be anonymized or deleted after 14 months. For details, please click the following link: https://support.google.com/analytics/answer/7667196?hl=en.
6.2 META PIXEL
This Site uses Meta Pixel’s visitor activity to measure conversion rates. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Meta’s statement the collected data will be transferred to the USA and other third-party countries too.
This tool allows the tracking of page visitors after they have been linked to the website of the provider after clicking on a Facebook ad. This makes it possible to analyze the effectiveness of Facebook ads for statistical and market research purposes and to optimize future advertising campaigns.
For us, as the operators of this Site, the collected data is anonymous. We are not in a position to arrive at any conclusions as to the identity of users. However, Meta archives the information and processes it so that it is possible to make a connection to the respective user profile, and Meta is in a position to use the data for its own promotional purposes in compliance with the Facebook Data Usage Policy. This enables Meta to display ads on Facebook pages as well as in locations outside of Facebook. We, as the operator of this Site, have no control over the use of such data.
The use of Meta Pixel is based on Art. 6 (1) (f) GDPR. The Site operator has a legitimate interest in effective advertising campaigns, which also include social media. If your consent is granted (e.g., an agreement to the storage of cookies), data processing takes place exclusively based on Art. 6 (1) (a) GDPR. Any such consent may be revoked at any time.
EU-U.S. Data Privacy Framework, and the European Commission’s related adequacy decision. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum. Insofar as personal data is collected on our Site with the help of the tool described here and forwarded to Meta, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Meta. The processing by Meta that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found at: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Meta tool and for the privacy-secure implementation of the tool on our Site. Meta is responsible for the data security of Meta products. You can assert data subject rights (e.g., requests for information) regarding data processed by Meta directly with Meta. If you assert the data subject rights with us, we are obliged to forward them to Meta.
In Meta’s Privacy Policy, you will find additional information about the protection of your privacy at: https://www.facebook.com/about/privacy/.
You also have the option to deactivate the remarketing function “Custom Audiences” in the ad settings section under https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you first have to log into Facebook.
If you do not have a Facebook account, you can deactivate any user-based advertising by Facebook on the website of the European Interactive Digital Advertising Alliance: http://www.youronlinechoices.com/de/praferenzmanagement/.
6.3 PINTEREST-TAG
We have integrated Pinterest-Tag into this Site. The provider is Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland.
The purpose of Pinterest-Tag is to record certain actions you perform on our Site. Subsequently, the data can be used to display promotions to you that meet your interests on our Site or on another Pinterest-Tag website.
For this purpose, Pinterest-Tag records, among other things, a Tag ID, your location, and the referrer URL. Furthermore, action-specific data, such as the order value, ordered quantity, order number, category of the purchased item, and video views, may be recorded.
Pinterest-Tag uses technologies that make the recognition of the user across sites possible so that the user patterns can be analyzed (e.g., cookies or device fingerprinting).
Pinterest-Tag is deployed based on Art. 6 (1) (f) GDPR. The Site operator has a legitimate interest in marketing activities that are as effective as possible. If your consent is granted, data processing will occur exclusively based on Art. 6 (1) (a) GDPR. Any such consent may be revoked at any time.
Pinterest is an enterprise that does business around the globe, so that data may also be transmitted into the United States. Based on Pinterest’s statements, this data transmission is based on the standard contractual clauses of the EU Commissions. For details, please visit https://policy.pinterest.com/en/privacy-policy.
For more Pinterest-Tag information, please visit https://help.pinterest.com/en/business/article/track-conversions-with-pinterest-tag.
6.4 SHAREASALE
This Site uses ShareASale’s which operates an affiliate marketing platform comprised of advertisers and publishers. The provider of this service is Awin, 2 Thomas More Square, London, E1W 1YN, United Kingtom. According to ShareASale’s privacy statement, the collected data will be transferred to the USA and other third-party countries too.
This tool uses end user data for the purpose of tracking and end user from a publisher to an advertiser. The main technologies used for tracking are cookies, journey tags and device fingerprinting.
The information collected typically includes anonymous identifiers, the referring URL, the date and time of the click, and other non-personally identifiable information.
The use of ShareASite is based on Art. 6 (1) (f) GDPR. The Site operator has a legitimate interest in affiliate marketing between publishers and advertisers. If your consent is granted (e.g., an agreement to the storage of cookies), data processing takes place exclusively based on Art. 6 (1) (a) GDPR. Any such consent may be revoked at any time.
EU-U.S. Data Privacy Framework, and the European Commission’s related adequacy decision. Details can be found here: https://www.awin.com/gb/privacy. Insofar as personal data is collected on our Site with the help of the tool described here and forwarded to ShareASale, we and Awin, 2 Thomas More Square, London, E1W 1YN, United Kingtom, are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Awin. The processing by Awin that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found at: https://www.awin.com/gb/privacy. According to this agreement, we are responsible for providing the privacy information when using the ShareASale tool and for the privacy-secure implementation of the tool on our Site. Awin is responsible for the data security of Awin products. You can assert data subject rights (e.g., requests for information) regarding data processed by Awin directly with Awin. If you assert the data subject rights with us, we are obliged to forward them to Awin.
In Awin’s Privacy Policy, you will find additional information about the protection of your privacy at: https://www.awin.com/gb/privacy.
6.5 OTHER PROVIDERS
Microsoft: We use Cookies from Microsoft Advertising (formerly “Bing Ads”) of Microsoft Corp., One Microsoft Way, Redmond, WA 98052-6399, USA, a function similar to Google Ads. Microsoft Advertising allows us to track user purchases and bookings. We want to show the services not only on Google’s search machine but also on Bing and via the “Microsoft Audience Network” other platforms with which Microsoft has agreements, such as LinkedIn. If you access our website via a Microsoft service or advertisement, Microsoft informs us about your usage on our website and your log-in duration. We do not receive personalized data from Microsoft. Microsoft may recognize your IP address and may use your data to enhance the performance of its services. You may deactivate Microsoft Advertising using your Browser’s cookie settings or via https://account.microsoft.com/privacy/ad-settings/signedout.
7. PLUG-INS AND TOOLS
7.1 YOUTUBE
This Site embeds videos from YouTube’s website. The website operator is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
If you visit a page on this Site into which YouTube has been embedded, a connection with YouTube’s servers will be established. As a result, the YouTube server will be notified of which of our pages you have visited.
Furthermore, YouTube will be able to place various cookies on your device or comparable technologies for recognition (e.g. device fingerprinting). In this way YouTube will be able to obtain information about this Site’s visitors. Among other things, this information will be used to generate video statistics with the aim of improving the site’s user-friendliness and to prevent attempts to commit fraud.
If you are logged into your YouTube account while you visit our site, you enable YouTube to allocate your browsing patterns directly to your personal profile. You can prevent this by logging out of your YouTube account.
The use of YouTube is based on our interest in presenting our online content in an appealing manner. Pursuant to Art. 6 (1) (f) GDPR, this is a legitimate interest. If your consent is granted, data processing takes place exclusively based on Art. 6 (1) (a) GDPR. Any such consent may be revoked at any time.
For more information on how YouTube handles user data, please consult the YouTube Data Privacy Policy under: https://policies.google.com/privacy?hl=en.
7.2 GOOGLE MAPS
This Site uses Google Maps, a mapping service provided by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
To enable the use of the Google Maps features, your IP address must be stored. As a rule, this information is transferred to one of Google’s servers in the United States, where it is stored. The operator of this Site has no control over the data transfer. In case Google Maps has been activated, Google has the option to use Google web fonts for the purpose of the uniform depiction of fonts. When you access Google Maps, your browser will load the required web fonts into your browser cache to correctly display text and fonts.
We use Google Maps to present our online content in an appealing manner and to make the locations disclosed on our Site easy to find. This constitutes a legitimate interest defined in Art. 6 (1) (f) GDPR. If your consent is granted, the data will be processed exclusively based on Art. 6 (1) (a) GDPR. Any such consent may be revoked at any time.
EU-U.S. and Swiss-U.S. Data Privacy Frameworks. Details can be found here: https://policies.google.com/privacy/frameworks?hl=en-US.
For more information on the handling of user data, please review Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en.
7.3 ZENDESK
We deploy to Zendesk, a Customer Relationship Management (CRM) system, to process user inquiries. The provider is Zendesk, Inc., 1019 Market Street, San Francisco, CA 94103 USA.
We use Zendesk to be able to respond to your inquiries promptly and efficiently. This constitutes a legitimate interest defined in Art. 6 (1) (f) GDPR.
In order to be able to submit inquiries, you must provide your email address and name.
The messages addressed to us remain with us until you request deletion or the data storage purpose no longer applies (e.g. after we have completed processing your request). Mandatory statutory provisions, in particular retention periods, remain unaffected.
Zendesk has Binding Corporate Rules (BCR) that have been approved by the Irish Data Protection Authority. These are binding corporate rules that legitimize the transfer of data within the company to third countries outside the EU and EEA. Details can be found here: https://www.zendesk.de/blog/update-privacy-shield-invalidation-european-court-justice/.
If you do not want to agree to our processing of your inquiries via Zendesk, you have the alternative option to communicate with us via email, telephone, or fax.
For more information, please consult Zendesk’s Data Privacy Declaration at: https://www.zendesk.com/company/customers-partners/privacy-policy/.
7.4 ZENDESK CHAT FUNCTIONS
Our Site offers you the opportunity to send us messages via a chat window. The chat functions are provided by Zendesk. Whenever you use this chat window, we do not only store your chat messages but also your IP address. You do not have to provide your name to engage in chats.
8. E-COMMERCE AND PAYMENT SERVICE PROVIDERS
8.1 PROCESSING OF DATA (CUSTOMER AND CONTRACT DATA)
We collect, process, and use personal data only to the extent necessary for the establishment, content organization, or change of any legal relationship (data inventory). These actions are taken on the basis of Art. 6 (1) (b) GDPR, which permits the processing of data for the fulfillment of a contract or pre-contractual actions. We collect, process, and use personal data concerning the use of this Site (usage data) only to the extent that this is necessary to make it possible for users to utilize the services and to bill for them.
The collected customer data will be eradicated upon completion of the order or the termination of the business relationship. This shall be without prejudice to any statutory retention mandates.
We share personal data with third parties only if it is necessary in conjunction with the handling of a contract, for instance, with the financial institution tasked with the processing of payments.
Any further transfer of data shall not occur or shall only occur if you have expressly consented to the transfer. Any sharing of your data with third parties in the absence of your express consent, for instance, for advertising purposes, shall not occur based on Art. 6 (1) (b) GDPR, which permits the processing of data for the fulfillment of a contract or for pre-contractual actions.
8.2 PAYMENT SERVICES
We integrate payment services of third-party companies on our Site. When you make a purchase from us, your payment data (e.g., name, payment amount, bank account details, credit card number) is processed by the payment service provider for the purpose of payment processing. For these transactions, the respective contractual and data protection provisions of the respective providers apply. The use of the payment service providers is based on Art. 6(1)(b) GDPR (contract processing) and in the interest of a smooth, convenient, and secure payment transaction (Art. 6 (1) (f) GDPR). Insofar as your consent is granted for certain actions, Art. 6 (1) (a) GDPR is the legal basis for data processing; consent may be revoked at any time in the future.
We use the following payment services/payment service providers within the scope of this Site:
a. PAYPAL
The provider of this payment service is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal”).
Data transmission to the US is based on binding corporate rules. Details can be found here: https://www.paypal.com/va/legalhub/privacy-full.
b. STRIPE
The provider for customers within the EU is Stripe Payments Europe, Ltd,1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland (hereinafter “Stripe”).
Data transmission to the US is based on the EU-US Data Privacy Framework and the Standard Contractual Clauses (SCC) of the European Commission. Details can be found in Stripe’s Privacy Policy at the following link: https://stripe.com/gb/privacy.
We use the following payment services/payment service providers within the scope of this Site:
a. PAYPAL
The provider of this payment service is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal”).
Data transmission to the US is based on binding corporate rules. Details can be found here: https://www.paypal.com/va/legalhub/privacy-full.
b. STRIPE
The provider for customers within the EU is Stripe Payments Europe, Ltd,1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland (hereinafter “Stripe”).
Data transmission to the US is based on the EU-US Data Privacy Framework and the Standard Contractual Clauses (SCC) of the European Commission. Details can be found in Stripe’s Privacy Policy at the following link: https://stripe.com/gb/privacy.
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