Privacy Policy

Privacy Policy

Table of Contents

  1. Your Data Subject Rights
  2. Collection of General Information when visiting our Website
  3. Cookies
  4. Technically necessary Cookies
  5. Technically not necessary Cookies
  6. Registration on our Website
  7. Provision of Paid Services via Stripe
  8. Use of Make
  9. Use of Google Sheets
  10. Use of Telegram
  11. Comment Function
  12. Newsletter
  13. Contact Form
  14. Google Analytics
  15. Use of Script Libraries (Google Webfonts)
  16. Embedded YouTube videos
  17. Social Plugins
  18. SSL Encryption
  19. Information about your Right to Object according to Art. 21 GDPR
  20. Changes to our Privacy Policy
  21. Questions to the Data Protection Officer

The responsible person in terms of data protection laws, in particular the EU General Data Protection Regulation (GDPR), is:

Daniel Frank Babik
c/o RA Axel Hellinger
Rosenstrasse 35
53111 Bonn
Germany

1. Your Data Subject Rights

You can exercise the following rights at any time using the contact details provided by our data protection officer:

  • Information about your data stored by us and its processing (Art. 15 GDPR),
  • Correction of incorrect personal data (Art. 16 GDPR),
  • Deletion of your data stored by us (Art. 17 GDPR),
  • Restriction of data processing if we are not yet allowed to delete your data due to legal obligations (Art. 18 GDPR),
  • Objection to the processing of your data by us (Art. 21 GDPR) and
  • Data portability, provided that you have consented to the data processing or have concluded a contract with us (Art. 20 GDPR).

If you have given us consent, you can revoke it at any time with effect for the future.

You may at any time lodge a complaint with a supervisory authority, e.g. the competent supervisory authority in the federal state of your residence or the authority responsible for us as the controller.

A list of supervisory authorities (for the non-public sector) with address can be found at: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.

2. Collection of General Information when visiting our Website

2.1. Nature and Purpose of Processing:

When you access our website, i.e., when you do not register or otherwise submit information, information of a general nature is automatically collected. This information (server log files) includes, for example, the type of web browser, the operating system used, the domain name of your Internet service provider, your IP address and the like.

In particular, they are processed for the following purposes:

  • Ensuring a smooth connection establishment of the website,
  • Ensuring a smooth use of our website,
  • Evaluating system security and stability, and
  • To optimize our website.

We do not use your data to draw conclusions about you personally. Information of this kind will be statistically evaluated anonymously by us, if necessary, in order to optimize our website and the technology behind it.

2.2. Legal Basis and Legitimate Interest:

The processing is carried out in accordance with Art. 6(1) lit. f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website.

2.3. Recipients:

Recipients of the data may be technical service providers who act as order processors for the operation and maintenance of our website.

2.4. Storage Period:

The data is deleted as soon as it is no longer required for the purpose for which it was collected. This is generally the case for data used to provide the website when the respective session has ended.

In the case of storage of data in log files, this is the case after 14 days at the latest. Storage beyond this period is possible. In this case, the IP addresses of the users are anonymized, so that an assignment of the calling client is no longer possible.

2.5. Provision Mandatory or Required:

The provision of the aforementioned personal data is not required by law or contract. However, without the IP address, the service and functionality of our website is not guaranteed. In addition, individual services and services may not be available or may be limited. For this reason, an objection is excluded.

3. Cookies

Like many other websites, we also use so-called “cookies”. Cookies are small text files that are stored on your end device (laptop, tablet, smartphone or similar) when you visit our website.

You can delete individual cookies or the entire cookie inventory. In addition, you will receive information and instructions on how to delete these cookies or block their storage in advance. Depending on the provider of your browser, you can find the necessary information under the following links:

4. Technically necessary Cookies

4.1. Type and Purpose of Processing:

We use cookies to make our website more user-friendly. Some elements of our website require that the calling browser can be identified even after a page change.

The purpose of using technically necessary cookies is to simplify the use of websites for users. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognized even after a page change.

We require cookies for the following applications:

  • Shopping cart
  • Adoption of language settings
4.2. Legal Basis and Legitimate Interest:

The processing is carried out in accordance with Art. 6(1) lit. f GDPR on the basis of our legitimate interest in a user-friendly design of our website.

4.3. Recipients:

Recipients of the data may be technical service providers who act as order processors for the operation and maintenance of our website.

4.4. Provision Mandatory or Required:

The provision of the aforementioned personal data is not required by law or contract. However, without this data, the service and functionality of our website cannot be guaranteed. In addition, individual services and services may not be available or may be limited.

4.5. Objection:

Please read the information about your right to object according to Art. 21 GDPR below.

5. Technically not necessary Cookies

Furthermore, we use cookies to better tailor the offer on our website to the interests of our visitors or to generally improve it on the basis of statistical evaluations.

Please refer to the information below on the display, tracking, remarketing and web analysis technologies used to find out which providers set cookies.

5.1. Legal Basis:

The legal basis for these processing operations is in each case your consent, Art. 6(1) lit. a GDPR.

5.2. Recipients:

Recipients of the data may be technical service providers who act as order processors for the operation and maintenance of our website.

For further recipients, please refer to the information below on the display, tracking, remarketing and web analysis technologies used.

5.3. Third Country Transfer:

Please refer to the listings of the individual display, tracking, remarketing and web analytics providers for information on this.

5.4. Provision Mandatory or Required:

Of course, you can also view our website without cookies in principle. Web browsers are regularly set to accept cookies. In general, you can deactivate the use of cookies at any time via your browser settings (see Revocation of consent).

Please note that individual functions of our website may not work if you have disabled the use of cookies.

5.5. Revocation of Consent:

You can revoke your consent at any time via our cookie consent tool: Revoke consent.

5.6. Profiling:

To what extent we analyze the behavior of website visitors with pseudonymized user profiles, please refer to the information below on the display, tracking, remarketing and web analysis technologies used.

6. Registration on our Website

6.1. Nature and Purpose of Processing:

For registration on our website, we require some personal data, which is transmitted to us via an input mask.

At the time of registration, the following data is also collected:

  • IP address or a timestamp

Your registration is necessary for the provision of certain content and services on our website.

6.2. Legal Basis:

The processing of the data entered during registration is based on the user’s consent (Art. 6(1) lit. a GDPR).

6.3. Recipients:

Recipients of the data may be technical service providers who act as order processors for the operation and maintenance of our website.

6.4. Storage Period:

Data will only be processed in this context as long as the corresponding consent has been given.

6.5. Provision Mandatory or Required:

The provision of your personal data is voluntary, based solely on your consent. Without the provision of your personal data, we cannot grant you access to our offered content.

7. Provision of Paid Services via Stripe

7.1. Type and Purpose of Processing:

We offer the option of processing the payment transaction via the payment service provider Stripe Inc, ℅ Legal Process, 510 Townsend St., San Francisco, CA 94103 (“Stripe”). This corresponds to our legitimate interest in offering an efficient and secure payment method (Art. 6(1) lit. f GDPR). The European address is: Stripe Payments Europe, Limited (SPEL), 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland. In this context, we pass on the following data to Stripe insofar as it is necessary for the fulfillment of the contract (Art. 6(1) lit. b GDPR):

Name of the cardholder, e-mail address, customer number, order number, bank details, credit card details, credit card expiry date, credit security code (CSC), date and time of the transaction, transaction amount, name of the provider, location.

7.2. Legal Basis:

The processing of the data specified in this section is not required by law or contract. We cannot process a payment via Stripe without the transmission of your personal data. Stripe assumes a dual role as controller and processor for data processing activities. As a controller, Stripe uses your transmitted data to fulfill regulatory obligations. This corresponds to Stripe’s legitimate interest (pursuant to Art. 6(1) lit. f GDPR) and serves the execution of the contract (pursuant to Art. 6(1) lit. b GDPR). We have no influence on this process.

Stripe acts as a processor in order to complete transactions within the payment networks. Within the framework of the order processing relationship, Stripe acts exclusively in accordance with our instructions and has been contractually obliged to comply with data protection regulations within the meaning of Art. 28 GDPR.

Stripe has implemented compliance measures for international data transfers. These apply to all global activities where Stripe processes personal data of natural persons in the EU. These measures are based on the EU Standard Contractual Clauses (SCCs).

You can find further information on objection and removal options towards Stripe at: https://stripe.com/privacy-center/legal.

7.3. Recipients:

Recipients of the data may be processors.

7.4. Storage Period:

Your data will be stored by us until payment processing is completed. This also includes the period required for the processing of refunds, receivables management and fraud prevention.

7.5. Provision Prescribed or Required:

The provision of your personal data is voluntary. Without the provision of your personal data, we cannot grant you access to the content and services we offer.

8. Use of Make

8.1. Type and Purpose of Processing:

We use the automation platform Make (Make.com) to process data related to subscription, onboarding, and offboarding processes. This includes automating the addition and removal of users from our Telegram groups and managing subscriptions.

For this purpose, the following personal data is processed in Make:

  • Date and time of interaction
  • Username
  • Email
  • Telegram User ID
  • Stripe Customer ID & Subscription ID

Processing is based on our legitimate interest in efficient and secure automation of these processes (Art. 6(1) lit. f GDPR) and for the fulfillment of contractual obligations (Art. 6(1) lit. b GDPR).

8.2. Legal Basis:

The processing of the data mentioned in this section is necessary for the execution of our services. Without this data, automated management of subscriptions, onboarding, and offboarding is not possible.

Make has implemented compliance measures for international data transfers, which are based on the EU Standard Contractual Clauses (SCCs).

Further information on Make’s data processing can be found at: https://www.make.com/en/privacy-and-gdpr.

8.3. Recipients:

The recipient of the data is Make as a data processor.

8.4. Storage Period:

Data is stored as long as it is required for automation. Once the purpose ceases, it is deleted unless legal retention obligations apply.

8.5. Provision Prescribed or Required:

Providing this data is voluntary. However, without it, automation of subscriptions, onboarding, and offboarding cannot be performed.

9. Use of Google Sheets

9.1. Type and Purpose of Processing:

To store and manage the data processed in Make, we use Google Sheets, a cloud service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

The following data may be stored in Google Sheets:

  • Date and time of interaction
  • Email
  • Telegram User ID
  • Stripe Customer ID & Subscription ID

This processing is based on our legitimate interest in structured data management (Art. 6(1) lit. f GDPR) and for contract fulfillment (Art. 6(1) lit. b GDPR).

9.2. Legal Basis:

Processing is necessary for subscription and offboarding management. Google processes the data under the EU Standard Contractual Clauses (SCCs).

Further information on Google’s data processing can be found at: https://policies.google.com/privacy.

9.3. Recipients:

The recipient of the data is Google Ireland Limited.

9.4. Storage Period:

Data is deleted as soon as it is no longer necessary for the purpose of storage.

9.5. Provision Prescribed or Required:

Providing this data is voluntary. However, without it, subscription and offboarding management cannot be performed.

10. Use of Telegram

10.1. Type and Purpose of Processing:

We use the Telegram messenger service, provided by Telegram FZ-LLC, for provision of the private content groups, communication with users and automation of subscriptions, onboarding, and offboarding processes.

The following data may be processed:

  • Date and time of interaction
  • Username
  • Email
  • Telegram User ID
  • Stripe Customer ID & Subscription ID
  • A limited number of bot command messages

Our Telegram bots act as administrators in our private Telegram groups. They respond to specific events as part of automation, such as sending invitation links, removing users after their subscription expires, or handling other on- and offboarding processes.

Processing is based on our legitimate interest in automating user management (Art. 6(1) lit. f GDPR) and for the fulfillment of contractual obligations (Art. 6(1) lit. b GDPR).

10.2. Legal Basis:

Processing is necessary for the use of our Telegram groups and bots. Telegram is subject to its own privacy policy, which can be found here: https://telegram.org/privacy/eu.

10.3. Recipients:

The recipient of the data is Telegram FZ-LLC.

10.4. Storage Period:

Data is stored in Telegram as long as it is necessary for communication. Users can remove their data by deleting messages or leaving groups.

10.5. Provision Prescribed or Required:

Providing this data is voluntary. However, without it, access to our Telegram services cannot be granted.

11. Comment Function

11.1. Nature and Purpose of Processing:

When users leave comments on our website, in addition to these details, the time of their creation and the user name previously selected by the website visitor are also stored. This serves our security, as we can be prosecuted for unlawful content on our website, even if it was created by users.

11.2. Legal Basis:

The processing of data entered as comments is based on a legitimate interest (Art. 6(1) lit. f GDPR).

By providing the comment function, we would like to enable you to interact in an uncomplicated manner. The information you provide will be stored for the purpose of processing the request and for possible follow-up questions.

11.3. Recipients:

Recipients of the data are, if applicable, order processors.

11.4. Storage Period:

The data is deleted as soon as it is no longer required for the purpose of collection. This is generally the case when communication with the user has been completed and the company can infer from the circumstances that the matter in question has been conclusively clarified. We reserve the right to delete without giving reasons and without prior or subsequent information.

You can also have your comment deleted by us at any time. To do so, please write an e-mail to the data protection officer listed below or to the person responsible for data protection and submit the link to your comment as well as, for identification purposes, the e-mail address used when creating the comment.

11.5. Provision Mandatory or Required:

The provision of your personal data is voluntary. Without the provision of your personal data, we cannot grant you access to our comment function.

12. Newsletter

With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.

We only send newsletters, emails and other electronic notifications with advertising information (hereinafter “newsletter”) with the consent of the recipient or with legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user’s consent. Otherwise, our newsletters contain information about our services and us.

12.1. Type and Purpose of Processing:

Registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registering, you will receive an email asking you to confirm your registration. This confirmation is necessary so that no one can register with other people’s e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored by the mailing service provider are also logged.

To subscribe to the newsletter, it is sufficient to simply enter your email address, but an application for the whitelist, which is typically desired by people who subscribe to the associated newsletter, is only possible if all fields of the registration form are filled in correctly.

12.2. Legal Basis:

The newsletter and the performance measurement associated with it are sent on the basis of the recipient’s consent pursuant to Art. 6(1) lit. a, Art. 7 GDPR in conjunction with Sec. 7(2) no. 3 UWG or on the basis of legal permission pursuant to Sec. 7(3) UWG.

The logging of the registration process is based on our legitimate interests pursuant to Art. 6(1) lit. f GDPR. We are interested in using a user-friendly and secure newsletter system that serves both our business interests and the expectations of users and also allows us to provide proof of consent.

12.3. Recipients:

Recipients of the data may be processors.

12.4. Storage Period:

The data will only be processed in this context for as long as the corresponding consent is available. After that, it will be deleted. An exception exists as explained under “Withdrawal of consent”.

12.5. Provision Prescribed or Required:

The provision of your personal data is voluntary, solely on the basis of your consent. Unfortunately, we cannot send you our newsletter without your consent.

12.6. Withdrawal of Consent:

You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to unsubscribe from the newsletter at the end of each newsletter. We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them for the purpose of sending the newsletter in order to be able to prove that consent was previously given. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time. Unsubscribing can be requested via the link contained in every email or by contacting the data protection officer or the person responsible for data protection listed in this privacy policy.

12.7. Dispatch Service Provider:

The newsletter can be sent by the mailing service provider MailPoet – a product of Wysija SARL, 6 rue Dieudé, 13006, Marseille, France (“MailPoet”). You can view the privacy policy of the shipping service provider here: https://www.mailpoet.com/privacy-notice/. The mailing service provider is used on the basis of our legitimate interests pursuant to Art. 6(1) lit. f GDPR and an order processing contract pursuant to Art. 28(3) sentence 1 GDPR.

The mailing service provider MailPoet may use the data of the recipients in pseudonymous form, i.e. without assignment to a user, to optimize or improve its own services, e.g. to technically optimize the dispatch and presentation of the newsletter or for statistical purposes. However, the mailing service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.

12.8. Performance Measurement:

The newsletters contain a so-called “web-beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a mailing service provider, from their server. As part of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and time of retrieval, is initially collected.

This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined with the help of the IP address) or the access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor, if used, that of the mailing service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

13. Contact Form

13.1. Nature and Purpose of Processing:

The data you enter will be stored for the purpose of individual communication with you. For this purpose, it is necessary to provide a valid e-mail address and your name. This is used for the assignment of the request and the subsequent response to the same. The provision of further data is optional.

13.2. Legal Basis:

The processing of the data entered in the contact form is based on a legitimate interest (Art. 6(1) lit. f GDPR).

By providing the contact form, we would like to enable you to contact us in an uncomplicated manner. The information you provide will be stored for the purpose of processing the request and for possible follow-up questions.

If you contact us to request a quote, the data entered in the contact form will be processed to carry out pre-contractual measures (Art. 6(1) lit. b GDPR).

13.3. Recipients:

Recipients of the data are, if applicable, order processors.

13.4. Storage Period:

Data will be deleted no later than 6 months after processing the request.

If there is a contractual relationship, we are subject to the statutory retention periods under the German Commercial Code (HGB) and delete your data after these periods have expired.

13.5. Provision Mandatory or Required:

The provision of your personal data is voluntary. However, we can only process your request if you provide us with your name, e-mail address and the reason for the request.

14. Google Analytics

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on users’ computers, to help the website analyze how users use the site. The information generated by the cookie about the use of this website by users is usually transmitted to a Google server in the USA and stored there.

In the event that IP anonymization is activated on this website, however, Google will truncate the user’s IP address beforehand within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. IP anonymization is active on this website. On behalf of the operator of this website, Google will use this information for the purpose of evaluating the use of the website by users, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator.

The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google. Users may refuse the use of cookies by selecting the appropriate settings on their browser, however please note that if you do this you may not be able to use the full functionality of this website. Users can also prevent the collection of data generated by the cookie and related to their use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

15. Use of Script Libraries (Google Webfonts)

In order to display our content correctly and graphically appealing across browsers, we use “Google Web Fonts” of Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; hereinafter “Google”) on this website to display fonts.

Further information on Google Web Fonts can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://www.google.com/policies/privacy/.

16. Embedded YouTube Videos

We embed YouTube videos on our website. The operator of the corresponding plugins is YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA (hereinafter “YouTube”). YouTube, LLC is a subsidiary of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter “Google”). When you visit a page with the YouTube plugin, a connection to YouTube servers is established. In the process, YouTube is informed which pages you are visiting. If you are logged into your YouTube account, YouTube can assign your surfing behavior to you personally. You can prevent this by logging out of your YouTube account beforehand.

If a YouTube video is started, the provider uses cookies that collect information about user behavior.

For more information on the purpose and scope of data collection and processing by YouTube, please refer to the provider’s privacy policy, where you will also find further information on your rights in this regard and settings options for protecting your privacy (https://policies.google.com/privacy).

16.1. Revocation of Consent:

No option for a simple opt-out or blocking of data transmission is currently offered by the provider. If you wish to prevent tracking of your activities on our website, please revoke your consent for the relevant cookie category or all technically unnecessary cookies and data transfers in the cookie consent tool. In this case, however, you may not be able to use our website or may only be able to use it to a limited extent.

17. Social Plugins

17.1. Nature and Purpose of Processing:

We offer you the option of using so-called “social media buttons” on our website. To protect your data, we rely on the “Shariff” solution for implementation. This means that these buttons are only integrated on the website as a graphic that contains a link to the corresponding website of the button provider. By clicking on the graphic, you are thus redirected to the services of the respective provider. Only then will your data be sent to the respective providers. Unless you click on the graphic, no exchange of any kind takes place between you and the providers of the social media buttons. Information about the collection and use of your data in the social networks can be found in the respective terms of use of the corresponding providers. You can find more information about the Shariff solution here: http://www.heise.de/ct/artikel/Shariff-Social-Media-Buttons-mit-Datenschutz-2467514.html

We have integrated the social media buttons of the following companies on our website:

17.2. Legal Basis and Data Transfer:

The legal basis for the integration of social plugins is our legitimate interest in providing an attractive online presence and facilitating interaction with social networks (Art. 6 (1) lit. f GDPR). If users actively click on the buttons and data is transferred to the respective providers, the processing is based on the user’s consent (Art. 6 (1) lit. a GDPR).

Some of these providers (e.g., X, YouTube, and Telegram) may process data in third countries (e.g., the USA). We have no influence on the data processing by these providers. Users should check the privacy policies of the respective platforms for more details.

18. SSL Encryption

To protect the security of your data during transmission, we use state-of-the-art encryption methods (e.g. SSL) via HTTPS.

19. Information about your Right to Object according to Art. 21 GDPR

19.1. Individual Right of Objection

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data relating to you which is carried out on the basis of Art. 6(1) lit. f GDPR (data processing on the basis of a balance of interests); this also applies to profiling based on this provision within the meaning of Art. 4(4) GDPR.

If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

19.2. Recipients of an Objection

Daniel Frank Babik
c/o RA Axel Hellinger
Rosenstrasse 35
53111 Bonn
Germany

E-mail:

20. Changes to our Privacy Policy

We reserve the right to adapt this data protection declaration so that it always complies with the current legal requirements or in order to implement changes to our services in the data protection declaration, e.g. when introducing new services. The new data protection statement will then apply to your next visit.

21. Questions to the Data Protection Officer

If you have any questions about data protection, please write us an email or contact the person responsible for data protection in our organization directly:

Daniel Frank Babik
c/o RA Axel Hellinger
Rosenstrasse 35
53111 Bonn
Germany

E-mail:

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