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Privacy policy

Preamble

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as “data”) that we process, for which purposes, and to what extent. This privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and, in particular, on our websites, in mobile applications, and within external online presences, such as our social media profiles (collectively referred to as “online offering”).

The terms used are not gender-specific.

Table of Contents

Controller

Sofiia Atlantova
akademika Filatova street, house 10a, apartment 21
01042 Kyiv
Ukraine

Email Address: This email address is being protected from spambots. You need JavaScript enabled to view it.

Overview of Processing

The following overview summarizes the types of data processed and the purposes of their processing, and refers to the affected persons.

Types of Data Processed

  • Master data.
  • Contact data.
  • Content data.
  • Usage data.
  • Meta, communication, and procedural data.
  • Log data.

Categories of Data Subjects

  • Communication partners.
  • Users.

Purposes of Processing

  • Communication.
  • Security measures.
  • Organizational and administrative procedures.
  • Feedback.
  • Provision of our online offering and user-friendliness.
  • Information technology infrastructure.

Relevant Legal Bases

Relevant legal bases according to the GDPR: Below is an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations in your or our country of residence or establishment may apply. Should more specific legal bases be decisive in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 para. 1 sentence 1 lit. a GDPR) – The data subject has given his or her consent to the processing of his or her personal data for one or more specific purposes.
  • Contractual necessity and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR) – The processing is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract.
  • Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR) – The processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject requiring protection of personal data.

National Data Protection Regulations in Germany: In addition to the GDPR, national data protection regulations in Germany apply. This includes, in particular, the Federal Data Protection Act (Bundesdatenschutzgesetz – BDSG). The BDSG contains, among other things, special provisions regarding the right to information, the right to deletion, the right to object, the processing of special categories of personal data, processing for other purposes, and the transfer as well as automated decision-making in individual cases including profiling. Furthermore, state data protection laws of the individual federal states may also apply.

Security Measures

In accordance with legal requirements and taking into account the state of the art, the costs of implementation, the nature, scope, circumstances and purposes of processing as well as the varying probabilities and severity of the risks to the rights and freedoms of natural persons, we take appropriate technical and organizational measures to ensure a level of security appropriate to the risk.

These measures include in particular the safeguarding of the confidentiality, integrity, and availability of data through the control of physical and electronic access to the data as well as to the processes involving access, input, transmission, ensuring availability, and their segregation. In addition, we have implemented procedures to ensure the exercise of data subjects’ rights, the deletion of data, and responses to data threats. We also consider the protection of personal data already during the development or selection of hardware, software, and procedures according to the principle of data protection by design and by default.

Securing online connections using TLS/SSL encryption technology (HTTPS): In order to protect the data of users transmitted via our online services from unauthorized access, we use TLS/SSL encryption technology. Secure Sockets Layer (SSL) and Transport Layer Security (TLS) are the cornerstones of secure data transmission on the internet. These technologies encrypt the information transmitted between the website or app and the user's browser (or between two servers), thereby protecting the data from unauthorized access. TLS, as the more advanced and secure version of SSL, ensures that all data transmissions meet the highest security standards. When a website is secured by an SSL/TLS certificate, this is signaled by the display of HTTPS in the URL. This serves as an indicator to users that their data is being securely and encryptedly transmitted.

Transfer of Personal Data

In the course of our processing of personal data, it occurs that such data is transmitted or disclosed to other entities, companies, legally independent organizational units, or persons. The recipients of such data may, for example, include service providers commissioned with IT-related tasks, or providers of services and content integrated into a website. In such cases, we comply with the statutory requirements and, in particular, conclude corresponding contracts or agreements with the recipients of your data that serve to protect your data.

International Data Transfers

Data Processing in Third Countries: Insofar as we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)), or if processing takes place as part of the use of third-party services or the disclosure or transfer of data to other persons, entities, or companies, this is done only in accordance with the statutory requirements. If the level of data protection in the third country has been recognized by means of an adequacy decision (Art. 45 GDPR), this serves as the basis for the data transfer. Otherwise, data transfers only take place if the level of data protection is secured by other means, in particular through standard contractual clauses (Art. 46 para. 2 lit. c GDPR), explicit consent, or in the case of contractual or legally required transfers (Art. 49 para. 1 GDPR). In addition, we inform you of the bases for third-country transfers by the individual third-country providers, whereby the adequacy decisions take precedence as the basis. Information on third-country transfers and existing adequacy decisions can be found in the information offering of the EU Commission: https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection_en?prefLang=de. Within the framework of the so-called “Data Privacy Framework” (DPF), the EU Commission has also recognized the level of data protection as secure for certain companies from the USA on 10 July 2023 as part of the adequacy decision. The list of certified companies as well as further information on the DPF can be found on the website of the US Department of Commerce at https://www.dataprivacyframework.gov/ (in English). We will inform you in the context of the data protection notices which of our service providers are certified under the Data Privacy Framework.

General Information on Storage and Deletion

We delete the personal data that we process in accordance with the statutory provisions, as soon as the underlying consents are withdrawn or there are no further legal grounds for processing. This applies in cases where the original purpose of processing is no longer applicable or the data is no longer needed. Exceptions to this rule exist when statutory obligations or special interests require longer retention or archiving of the data.

In particular, data that must be retained for commercial or tax reasons, or whose storage is necessary for legal proceedings or to protect the rights of other natural or legal persons, must be archived accordingly.

Our data protection notices contain additional information on the retention and deletion of data that specifically apply to certain processing procedures.

When several statements are made regarding the retention period or deletion deadlines of data, the longest period shall always apply.

If a period does not explicitly begin on a specific date and is at least one year, it will automatically start at the end of the calendar year in which the triggering event occurred. In the case of ongoing contractual relationships during which data is stored, the triggering event is the time when the termination (or another end of the legal relationship) takes effect.

Data that is no longer stored for the originally intended purpose but is retained due to statutory requirements or other reasons is processed exclusively for the reasons that justify its retention.

Further Information on Processing Procedures, Methods, and Services:

  • Retention and Deletion of Data: The following general periods apply for the retention and archiving according to German law:
    • 10 years – Retention period for books and records, annual financial statements, inventories, management reports, opening balances, as well as the work instructions and other organizational documents required to understand them (§ 147 para. 1 no. 1 in conjunction with para. 3 AO, § 14b para. 1 UStG, § 257 para. 1 no. 1 in conjunction with para. 4 HGB).
    • 8 years – Accounting documents, such as invoices and cost receipts (§ 147 para. 1 no. 4 and 4a in conjunction with para. 3 sentence 1 AO as well as § 257 para. 1 no. 4 in conjunction with para. 4 HGB).
    • 6 years – Other business documents: received commercial or business letters, copies of dispatched commercial or business letters, other documents insofar as they are relevant for taxation, e.g. timesheets, operating account sheets, calculation documents, price listings, as well as payroll records, insofar as they are not already accounting documents, and cash receipt records (§ 147 para. 1 nos. 2, 3, 5 in conjunction with para. 3 AO, § 257 para. 1 nos. 2 and 3 in conjunction with para. 4 HGB).
    • 3 years – Data that is required to take into account potential warranty and compensation claims or similar contractual claims and rights, and to process related inquiries, based on previous business experiences and usual industry practices, are stored for the duration of the regular statutory limitation period of three years (§§ 195, 199 BGB).

Rights of Data Subjects

Rights of data subjects under the GDPR: As a data subject, you are entitled to various rights under the GDPR, in particular those arising from Articles 15 to 21 of the GDPR:

  • Right to Object: You have the right, for reasons arising from your particular situation, to object at any time to the processing of your personal data carried out on the basis of Art. 6 para. 1 lit. e or f GDPR; this also applies to profiling based on these provisions. If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for such purposes; this also applies to profiling insofar as it is related to such direct marketing.
  • Right to Withdraw Consent: You have the right to withdraw any consent you have given at any time.
  • Right of Access: You have the right to obtain confirmation as to whether or not data concerning you is being processed, and, if so, to access such data as well as further information and a copy of the data in accordance with legal requirements.
  • Right to Rectification: In accordance with legal requirements, you have the right to have incomplete data concerning you completed or to have inaccurate data corrected.
  • Right to Erasure and Restriction of Processing: Subject to legal requirements, you have the right to request that data concerning you be deleted without delay or, alternatively, to request that the processing of your data be restricted.
  • Right to Data Portability: You have the right to receive the data concerning you that you have provided to us in a structured, commonly used and machine-readable format, or to have such data transmitted directly to another controller, in accordance with legal requirements.
  • Right to Lodge a Complaint with a Supervisory Authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work, or the place of the alleged infringement, if you consider that the processing of your personal data infringes the GDPR.

Provision of the Online Offering and Web Hosting

We process users’ data in order to be able to provide them with our online services. For this purpose, we process the user's IP address, which is necessary in order to transmit the content and functions of our online services to the user's browser or device.

  • Types of Data Processed: Usage data (e.g., page views and duration of stay, click paths, usage intensity and frequency, types of devices and operating systems used, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons); log data (e.g., logfiles regarding logins or the retrieval of data or access times).
  • Data Subjects: Users (e.g., website visitors, users of online services).
  • Purposes of Processing: Provision of our online offering and user-friendliness; information technology infrastructure (operation and provision of information systems and technical devices such as computers, servers, etc.); security measures.
  • Retention and Deletion: Deletion in accordance with the information provided in the section “General Information on Storage and Deletion”.
  • Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).

Additional Information on Processing Procedures, Methods, and Services:

  • Provision of Online Offering on Rented Server Space: For the provision of our online offering, we use server space, computing power, and software that we rent or otherwise obtain from an appropriate server provider (also referred to as “web hoster”); Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).
  • Collection of Access Data and Logfiles: Access to our online offering is logged in the form of so-called “server logfiles”. Server logfiles may include the address and name of the accessed webpages and files, the date and time of access, data volumes transmitted, notifications of successful access, the browser type and version, the user's operating system, the referrer URL (the previously visited page), and typically IP addresses as well as the requesting provider. The server logfiles may be used, on the one hand, for security purposes, e.g., to avoid overloading the servers (in particular in the case of abusive attacks, so-called DDoS attacks), and on the other hand, to ensure the load and stability of the servers; Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR). Deletion of Data: Logfile information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further retention is required for evidentiary purposes is exempted from deletion until the final clarification of the respective incident.

Use of Cookies

Under the term “cookies”, functions that store and read information on users’ devices are understood. Cookies may also be used for various purposes, such as ensuring functionality, security, and comfort of online offerings, as well as for generating visitor flow analyses. We use cookies in accordance with legal regulations. Where necessary, we obtain the users’ consent in advance. Where consent is not necessary, we rely on our legitimate interests. This applies when the storing and reading of information is essential to provide specifically requested content and functions. This includes, for example, the storage of settings as well as ensuring the functionality and security of our online offering. Consent can be withdrawn at any time. We clearly inform you about its scope and which cookies are used.

Note on Data Protection Legal Bases: Whether we process personal data using cookies depends on consent. If consent is given, it serves as the legal basis. Without consent, we rely on our legitimate interests, which are explained above in this section and in the context of the respective services and procedures.

Storage Duration: With regard to storage duration, the following types of cookies are distinguished:

  • Temporary Cookies (also: Session Cookies): Temporary cookies are deleted at the latest when a user leaves an online offering and closes their device (e.g., browser or mobile application).
  • Permanent Cookies: Permanent cookies remain stored even after the device is closed. For example, this allows the login status to be saved and preferred content to be displayed when the user revisits a website. Similarly, the user data collected through cookies can be used for reach measurement. In the absence of specific information on the type and duration of storage of cookies (e.g., as part of obtaining consent), users should assume that these are permanent and that the storage duration may be up to two years.

General Information on Withdrawal and Objection (Opt-out): Users can withdraw any consent they have given at any time and may also object to processing in accordance with legal requirements, including via the privacy settings of their browser.

  • Types of Data Processed: Meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
  • Data Subjects: Users (e.g., website visitors, users of online services).
  • Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR). Consent (Art. 6 para. 1 sentence 1 lit. a GDPR).

Additional Information on Processing Procedures, Methods, and Services:

  • Processing of Cookie Data Based on Consent: We employ a consent management solution, whereby users’ consent for the use of cookies or for the processing procedures and providers mentioned within the consent management solution is obtained. This procedure serves to obtain, record, manage, and withdraw consent, particularly with regard to the use of cookies and similar technologies used for storing, reading, and processing information on users’ devices. As part of this process, users’ consent for the use of cookies and the associated processing of information, including the specific processes and providers mentioned in the consent management procedure, is obtained. Users also have the opportunity to manage and withdraw their consent. The consent declarations are stored to avoid repeated requests and to provide proof of consent in accordance with legal requirements. Storage is carried out server-side and/or in a cookie (so-called opt-in cookie) or using comparable technologies to be able to assign the consent to a specific user or their device. Unless specific information is provided regarding the providers of consent management services, the following general information applies: The storage duration of consent is up to two years. Legal Bases: Consent (Art. 6 para. 1 sentence 1 lit. a GDPR).

Contact and Inquiry Management

When you contact us (e.g., by post, via a contact form, email, telephone, or through social media) and within the context of existing user and business relationships, the details provided by the inquiring persons are processed to the extent necessary to respond to the contact inquiries and any measures requested.

  • Types of Data Processed: Master data (e.g., full name, residential address, contact information, customer number, etc.); contact data (e.g., postal and email addresses or telephone numbers); content data (e.g., textual or visual messages and posts, including related information such as authorship details or creation time); usage data (e.g., page views and duration, click paths, usage intensity and frequency, types of devices and operating systems, interactions with content and functions); meta, communication, and procedural data (e.g., IP addresses, timestamps, identification numbers, involved persons).
  • Data Subjects: Communication partners.
  • Purposes of Processing: Communication; organizational and administrative procedures; feedback (e.g., collecting feedback via an online form); provision of our online offering and user-friendliness.
  • Retention and Deletion: Deletion in accordance with the information provided in the section “General Information on Storage and Deletion”.
  • Legal Bases: Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR), contractual necessity and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR).

Additional Information on Processing Procedures, Methods, and Services:

  • Contact Form: When you contact us via our contact form, by email, or by other means of communication, we process the personal data you provide to us for the purpose of responding to and handling the respective inquiry. This generally includes details such as name, contact information, and, where provided, further information necessary for appropriate processing. We use these data solely for the purposes of contact and communication; Legal Bases: Contractual necessity and pre-contractual inquiries (Art. 6 para. 1 sentence 1 lit. b GDPR), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f GDPR).

Amendments and Updates

Please regularly review the content of our privacy policy. We will adjust the privacy policy as soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as any changes require an action from you (e.g., consent) or any other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy policy, please note that these addresses may change over time. We recommend verifying the details before contacting.

Definitions of Terms

This section provides an overview of the terms used in this privacy policy. Where the terms are defined by law, their legal definitions apply. The following explanations are intended primarily for understanding.

  • Master Data: Master data includes essential information necessary for the identification and management of contractual partners, user accounts, profiles, and similar allocations. This data may include personal and demographic details such as names, contact information (addresses, telephone numbers, email addresses), dates of birth, and specific identifiers (user IDs). Master data forms the basis for any formal interaction between persons and services, institutions, or systems by enabling clear assignment and communication.
  • Content Data: Content data includes information generated in the course of creating, editing, and publishing content of all kinds. This category of data may include texts, images, videos, audio files, and other multimedia content published on various platforms and media. Content data is not limited solely to the content itself, but also includes metadata that provides information about the content, such as tags, descriptions, author details, and publication dates.
  • Contact Data: Contact data comprises essential information that facilitates communication with persons or organizations. This includes, for example, telephone numbers, postal addresses, email addresses, as well as communication identifiers such as social media handles and instant messaging identifiers.
  • Meta, Communication, and Procedural Data: These categories include information about the manner in which data is processed, transmitted, and managed. Metadata, also known as data about data, includes information that describes the context, origin, and structure of other data. This may include details such as file size, creation date, document author, and change history. Communication data captures the exchange of information between users over various channels such as email, call records, social network messages, and chat conversations, including the involved parties, timestamps, and transmission paths. Procedural data describes processes and workflows within systems or organizations, including workflow documentation, transaction logs, and audit trails used for tracking and verifying operations.
  • Usage Data: Usage data refers to information that captures how users interact with digital products, services, or platforms. This data includes a wide range of information showing how users use applications, which functions they prefer, how long they stay on certain pages, and the paths they take while navigating an application. Usage data may also include frequency of use, activity timestamps, IP addresses, device information, and location data. It is particularly valuable for analyzing user behavior, optimizing user experiences, personalizing content, and improving products or services. Furthermore, usage data plays a crucial role in detecting trends, preferences, and potential issues within digital offerings.
  • Personal Data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier (e.g., cookie), or one or more specific factors that indicate the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Log Data: Log data consists of information about events or activities that have been recorded in a system or network. This data typically includes details such as timestamps, IP addresses, user actions, error messages, and other information regarding the use or operation of a system. Log data is often used for analyzing system issues, security monitoring, or generating performance reports.
  • Controller: The term “controller” refers to the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.