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Data protection

1. DATA PROTECTION AT A GLANCE

GENERAL INFORMATION

The following information provides a simple overview of what happens to your personal data when you visit our website and / or use the trackle service. Personal data are all data with which you can be personally identified. Detailed information on the subject of data protection can be found in our data protection declaration listed below this text.

DATA COLLECTION ON OUR WEBSITE

Who is responsible for data collection on this website?

The data processing on this website is carried out by the website operator. You can find their contact details in the imprint of this website.

How do we collect your data?

On the one hand, your data is collected when you provide it to us. This can e.g. be data that you enter in the newsletter form.

Other data are automatically recorded by our IT systems when you visit the website. This is mainly technical data (e.g. Internet browser, operating system or time of the page was viewed). This data is collected automatically as soon as you enter our website.

What do we use your data for?

Some of the data is collected in order to ensure that the website is error-free. Other data can be used to analyze your user behavior.

What rights do you have with regard to your data?

You have the right to receive information about the origin, recipient and purpose of your stored personal data free of charge at any time. You also have the right to request the correction, blocking or deletion of this data. You can contact us at any time at the address given in the legal notice if you have any further questions about data protection. You also have the right to lodge a complaint with the competent supervisory authority.

THIRD-PARTY ANALYSIS TOOLS AND TOOLS

When you visit our website, your surfing behavior can be statistically evaluated. This is mainly done with cookies and so-called analysis programs. Your surfing behavior is usually analyzed anonymously; surfing behavior cannot be traced back to you. You can object to this analysis or prevent it by not using certain tools. You can find detailed information on this in the following data protection declaration.

You can object to this analysis. We will inform you about the possibilities of objection in this data protection declaration.

2. GENERAL NOTES AND MANDATORY INFORMATION

PRIVACY

As the operator of this website, trackle GmbH takes the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this data protection declaration.

When you use this website, various personal data are collected. Personal data are data with which you can be personally identified. This data protection declaration explains which data we collect and what we use it for. It also explains how and for what purpose this is done.

We would like to point out that data transmission over the Internet (e.g. when communicating by email) can have security gaps. A complete protection of the data against access by third parties is not possible.

NOTE ON THE RESPONSIBLE BODY

The responsible body for data processing on this website is:

trackle GmbH
Bertha-von-Suttner-Platz 1-7
53111 Bonn

Telephone: 0228 90278777
Email: info@trackle.de

The responsible body is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data (e.g. names, email addresses, etc.).

REVOCATION OF YOUR CONSENT TO DATA PROCESSING

Many data processing operations are only possible with your express consent. You can withdraw your consent at any time. An informal e-mail to us is sufficient. The legality of the data processing carried out before the revocation remains unaffected by the revocation.

RIGHT TO COMPLAIN WITH THE COMPETENT SUPERVISORY AUTHORITY

In the event of data protection violations, the person concerned has the right to lodge a complaint with the competent supervisory authority. The competent supervisory authority for data protection issues is the state data protection officer of the federal state in which our company is based. A list of data protection officers and their contact details can be found at the following link: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.

RIGHT TO DATA PORTABILITY

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

SSL or TLS ENCRYPTION

For security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator, this site uses an SSL or. TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http: //” to “https: //” and by the lock symbol in your browser line.

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

ENCRYPTED PAYMENT TRANSACTIONS ON THIS WEBSITE

If there is an obligation to provide us with your payment data (e.g. account number for direct debit authorization) after the conclusion of a paid contract, this data is required for payment processing.

Payment transactions using common means of payment (Visa / MasterCard) are made exclusively via an encrypted SSL or TLS connection. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http: //" to "https: //" and by the lock symbol in your browser line.

With encrypted communication, your payment data that you transmit to us cannot be read by third parties.

INFORMATION, BLOCKING, DELETION

Within the framework of the applicable statutory provisions, you have the right to free information about your stored personal data, their origin and recipient and the purpose of the data processing and, if necessary, a right to correct, block or delete this data. You can contact us at any time at the address given in the legal notice if you have any further questions on the subject of personal data.

OBJECTION TO ADVERTISING MAILS

We hereby object to the use of the contact data published in the context of the imprint obligation for sending unsolicited advertising and information materials. The operators of the pages expressly reserve the right to take legal action in the event of unsolicited sending of advertising information, such as spam e-mails.

3. DATA PROTECTION OFFICER

LEGALLY REQUIRED DATA PROTECTION OFFICER

We have appointed a data protection officer for our company.

Mr. Maxim Loick
trackle GmbH
Bertha-von-Suttner-Platz 1-7
53111 Bonn

Telephone: 0228 90278777
Email: maxim.loick@trackle.de

4. DATA COLLECTION ON OUR WEBSITE

COOKIES

Some of the websites use so-called cookies. Cookies do not harm your computer and do not contain viruses. Cookies serve to make our offer more user-friendly, more effective and safer. Cookies are small text files that are stored on your computer and saved by your browser.

Most of the cookies we use are so-called “session cookies”. They are automatically deleted after your visit. Other cookies remain stored on your device until you delete them. These cookies enable us to recognize your browser the next time you visit.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when you close the browser. If cookies are deactivated, the functionality of this website may be restricted.

Cookies that are required to carry out the electronic communication process or to provide certain functions you want (e.g. shopping cart function) are stored on the basis of Art. 6 Para. f GDPR saved. The website operator has a legitimate interest in storing cookies for the technically error-free and optimized provision of its services. If other cookies (e.g. cookies for analyzing your surfing behavior) are stored, these will be treated separately in this data protection declaration.

SERVER LOG FILES

The website provider automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

  • Browser type and browser version
  • operating system used
  • Referrer URL
  • Host name of the accessing computer
  • Time of the server request
  • IP address

This data is not combined with other data sources.

The basis for data processing is Art. 6 Para. 1 lit. f GDPR, which allows the processing of data for the performance of a contract or pre-contractual measures.

PROCESSING DATA (CUSTOMER AND CONTRACT DATA)

We collect, process and use personal data only insofar as they are necessary for the establishment, content design or change of the legal relationship (inventory data). This is done on the basis of Art. 6 Para. 1 lit. b GDPR, which allows the processing of data for the performance of a contract or pre-contractual measures. We collect, process and use personal data on the use of our website (usage data) only insofar as this is necessary to enable the user to use the service or to bill.

The customer data collected will be deleted after the order has been completed or the business relationship has ended. Statutory retention periods remain unaffected.

DATA TRANSFER ON CONTRACT FOR ONLINE SHOPS, DEALERS AND SHIPPING OF GOODS

We only transfer personal data to third parties if this is necessary in the context of contract processing, for example to the company entrusted with the delivery of the goods or the credit institution commissioned with the payment processing. A further transmission of the data does not take place or only if you have expressly consented to the transmission. Your data will not be passed on to third parties without your express consent, e.g. for advertising purposes.

The basis for data processing is Art. 6 Para. 1 lit. b GDPR, which allows the processing of data for the performance of a contract or pre-contractual measures.

DATA TRANSFER ON CONCLUSION OF CONTRACT FOR SERVICES AND DIGITAL CONTENT

We only transmit personal data to third parties if this is necessary in the context of contract processing, for example to the credit institute commissioned with processing payments.

A further transmission of the data does not take place or only if you have expressly consented to the transmission. Your data will not be passed on to third parties without your express consent, e.g. for advertising purposes.

The basis for data processing is Art. 6 Para. 1 lit. b GDPR, which allows the processing of data for the performance of a contract or pre-contractual measures.

5. GOOGLE TAG MANAGER & GOOGLE ANALYTICS & GOOGLE ADWORDS

GOOGLE TAG MANAGER

Google Tag Manager is a solution with which we can manage so-called website tags via an interface (and thus, for example, integrate Google Analytics and other Google marketing services into our online offer). The Tag Manager itself (which implements the tags) does not process any personal data from users. With regard to the processing of users' personal data, reference is made to the following information on Google services. Usage guidelines: https://www.google.com/intl/de/tagmanager/use-policy.html.

GOOGLE ANALYTICS

We use Google Analytics, a web analysis service provided by Google Ireland Limited, Gordon House, Barrow Street, on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. f. GDPR) , Dublin 4, Ireland (“Google”). Google uses cookies. The information generated by the cookie about the use of the online offer by the user is usually transferred to a Google server in the USA and stored there.

Google is certified under the Privacy Shield Agreement and thus offers a guarantee that it will comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with other services related to the use of this online offer and the internet. In doing so, pseudonymous user profiles can be created from the processed data.

We only use Google Analytics with activated IP anonymization. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. The full IP address is only transmitted to a Google server in the USA and shortened there in exceptional cases.

The IP address transmitted by the user's browser will not be merged with other Google data. Users can prevent the storage of cookies by setting their browser software accordingly; Users can also prevent Google from collecting the data generated by the cookie and relating to their use of the online offer and from processing this data by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.

You can find further information on the use of data by Google, setting and objection options in Google's data protection declaration (https://policies.google.com/privacy) as well as in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated).

The personal data of users are deleted or anonymized after 14 months.

GOOGLE ADWORDS & GOOGLE CONVERSION TRACKING

This website uses Google AdWords. AdWords is an online advertising program from Google Inc., 1600 Amphitheater Parkway, Mountain View, CA 94043, United States (“Google”).


As part of Google AdWords, we use so-called conversion tracking on our shop.trackle.de website. If you click on an ad placed by Google, a cookie is set for conversion tracking. Cookies are small text files that the Internet browser stores on the user's computer. These cookies lose their validity after 30 days and are not used to personally identify users. If the user visits certain pages on this website and the cookie has not yet expired, we and Google can see that the user clicked on the ad and was redirected to this page.


Every Google AdWords customer receives a different cookie. The cookies cannot be tracked via the websites of AdWords customers. The information obtained using the conversion cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. Customers find out the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not contain any information with which users can be personally identified. If you do not want to participate in tracking, you can object to this use by deactivating the Google conversion tracking cookie in your internet browser under user settings. You will then not be included in the conversion tracking statistics.


The storage of “conversion cookies” is based on Art. 6 Para. 1 lit. f GDPR. The website operator has a legitimate interest in analyzing user behavior in order to optimize both its website and its advertising.


You can find more information on Google AdWords and Google Conversion Tracking in Google's data protection provisions: https://www.google.de/policies/privacy/.


You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when you close the browser. If cookies are deactivated, the functionality of this website may be restricted.


You can also configure your individual settings yourself at any time on the shop.trackle.de page. To do this, click on the data protection settings at the bottom left and make the appropriate adjustments.

6. FACEBOOK

Our website shop.trackle.de uses the so-called "Facebook pixel" of the social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland is used.


With the help of the Facebook pixel, Facebook is on the one hand able to determine the visitors to our online offer as a target group for the presentation of advertisements (so-called "Facebook ads"). Accordingly, we use the Facebook pixel to display the Facebook ads placed by us only to those Facebook users who have also shown an interest in our online offer or who have certain characteristics (e.g. interests in certain topics or products that are based on the visited Websites) that we transmit to Facebook (so-called "Custom Audiences").


With the help of the Facebook pixel, we can also understand the effectiveness of the Facebook ads for statistical and market research purposes by seeing whether users have been redirected to our website after clicking on a Facebook ad (so-called "conversion"). The Facebook pixel is directly integrated by Facebook when you visit our website and can save a so-called cookie on your device. If you then log in to Facebook or visit Facebook while logged in, the visit to our online offer will be noted in your profile. The data collected about you is anonymous to us, so it does not allow us to draw any conclusions about the identity of the user. However, the data is stored and processed by Facebook so that a connection to the respective user profile is possible and can be used by Facebook as well as for its own market research and advertising purposes. If we should transmit data to Facebook for comparison purposes, it will be encrypted locally on the browser and only then sent to Facebook via a secure https connection. This is done solely for the purpose of making a comparison with the data that is also encrypted by Facebook.


We also use the additional function "extended comparison" when using the Facebook pixel. Here, data for the formation of target groups ("Custom Audiences" or "Look Alike Audiences") are transmitted to Facebook in encrypted form.


Your consent to these tracking functions is automatically requested when you visit our shop at shop.trackle.de. If you do not agree to this tracking, you can switch off the tracking directly on our shop.trackle.de page. To do this, click on the data protection settings at the bottom left and make the appropriate modifications.

7. NEWSLETTER

NEWSLETTER DATA

If you would like to receive the newsletter offered on the website, we need an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter . Further data is not collected or is only collected on a voluntary basis. We use this data exclusively for sending the requested information and do not pass it on to third parties.

The processing of the data entered in the newsletter registration form takes place exclusively on the basis of your consent (Art. 6 Para. 1 lit. a GDPR). You can revoke your consent to the storage of the data, the e-mail address and their use for sending the newsletter at any time, for example via the "Unsubscribe" link in the newsletter. The legality of the data processing operations already carried out remains unaffected by the revocation.

The data you have stored with us for the purpose of receiving the newsletter will be stored by us until you unsubscribe from the newsletter and will be deleted after you unsubscribe from the newsletter. This does not affect data that we have stored for other purposes (e.g. email addresses for the members' area).

MAILCHIMP

This website uses the services of MailChimp to send newsletters. The provider is Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.

MailChimp is a service with which, among other things, the dispatch of newsletters can be organized and analyzed. If you enter data for the purpose of subscribing to the newsletter (e.g. email address), it will be stored on MailChimp's servers in the USA.

MailChimp is certified according to the “EU-US Privacy Shield”. The “Privacy Shield” is an agreement between the European Union (EU) and the USA, which aims to ensure compliance with European data protection standards in the USA.

With the help of MailChimp we can analyze our newsletter campaigns. When you open an email sent with MailChimp, a file contained in the email (so-called web beacon) connects to MailChimp's servers in the USA. In this way it can be determined whether a newsletter message has been opened and which links have been clicked. Technical information is also recorded (e.g. time of access, IP address, browser type and operating system). This information cannot be assigned to the respective newsletter recipient. They are used exclusively for the statistical analysis of newsletter campaigns. The results of these analyzes can be used to better adapt future newsletters to the interests of the recipients.

If you do not want an analysis by MailChimp, you have to unsubscribe from the newsletter. We provide a link for this in every newsletter message. You can also unsubscribe from the newsletter directly on the website.

The data processing takes place on the basis of your consent (Art. 6 Paragraph 1 lit. You can revoke this consent at any time by unsubscribing from the newsletter. The legality of the data processing operations already carried out remains unaffected by the revocation.

The data you have stored with us for the purpose of receiving the newsletter will be stored by us until you unsubscribe from the newsletter and will be deleted from our servers as well as from the MailChimp servers after you unsubscribe from the newsletter. This does not affect data that we have stored for other purposes (e.g. email addresses for the members' area).

For more information, see the data protection provisions of MailChimp at: https://mailchimp.com/legal/terms/.

Conclusion of a data processing agreement

We have concluded a so-called "Data Processing Agreement" with MailChimp in which we oblige MailChimp to protect our customers' data and not to pass it on to third parties. This contract can be viewed at the following link: https://mailchimp.com/legal/data-processing-addendum/.

8. PAYMENT PROVIDER

PAYPAL

On our website we offer i.a. payment via 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”).

If you choose to pay via PayPal, the payment details you have entered will be transmitted to PayPal.

The transfer of your data to PayPal is based on Art. 6 Para. 1 lit. a GDPR (consent) and Art. 6 Para. 1 lit. b GDPR (processing to fulfill a contract). You have the option of withdrawing your consent to data processing at any time. A revocation does not affect the effectiveness of data processing operations in the past.

KLARNA

On our website we offer i.a. payment via Klarna. Klarna Bank AB (publ.) Is the provider of this payment service. Sveavägen 46, 11134 Stockholm (hereinafter “Klarna”).

If you choose payment via Klarna, the payment details you have entered will be transmitted to Klarna.

Your data is transmitted to Klarna on the basis of Art. 6 Para. 1 lit. a GDPR (consent) and Art. 6 Para. 1 lit. b GDPR (processing to fulfill a contract). You have the option of withdrawing your consent to data processing at any time. A revocation does not affect the effectiveness of data processing operations in the past.

STRIPE

On our website we offer, among other things payment via Stripe. The provider of this payment service is Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA.


If you choose to pay via Stripe (credit card), the payment details you have entered will be transmitted to Stripe. We have concluded a so-called "Data Processing Agreement" with Stripe, in which we oblige Stripe to protect our customers' data and not to pass it on to third parties. This contract can be viewed at the following link: https://stripe.com/dpa/legal


The transmission of your data to Stripe takes place on the basis of Art. 6 Para. 1 lit. a GDPR (consent) and Art. 6 Para. 1 lit. b GDPR (processing to fulfill a contract). You have the option of withdrawing your consent to data processing at any time. A revocation does not affect the effectiveness of data processing operations in the past.

9. SHOP PROVIDER

SHOPIFY

This website uses the services of Shopify for the handling of the shopping processes. The provider is Shopify Inc., a Canadian corporation at 150 Elgin Street, Suite 800, Ottawa, ON, K2P 1L4, Canada.

Shopify is a service with which, among other things, an online shop system can be set up and administered. If you enter data for the purpose of processing the sales contract and shipping (e.g. email address), these will also be stored on Shopify's servers outside the EU.

Shopify works under the guidelines of the EU-U.S. Privacy Shield Framework, the Swiss-U.S. Privacy Shield Framework, and Canada's Personal Information Protection and Electronic Documents Act (PIPEDA). These agreements are intended to ensure compliance with European data protection standards in the USA.

Shopify's privacy policy can be found here https://www.shopify.com/legal/privacy and here https://www.shopify.com/legal/dpa can be viewed. The data collected by Shopify to fulfill the contract will only be passed on to third parties if this is necessary for the execution of the contract, in particular in the following cases:

  • Address data to shipping companies for the purpose of delivery
  • Payment data to credit institutions for processing payments
  • Payment data to debt collection companies when assigning claims

10. SUPPORT DESK

FRESHDESK

If you contact our support team via the email address info@trackle.de or via Facebook Messenger, your inquiries will be redirected to our helpdesk tool. The provider is Freshworks INC, San Francisco, USA, 1250 Bayhill Drive, Suite 315, San Bruno, CA 94066.

If you enter and transmit data for the purpose of processing a support request by email or Facebook Messenger (e.g. email address, your name), these will also be stored on Freshdesk's servers outside the EU.

Freshdesk works under the guidelines of the EU-U.S. Privacy Shield Framework, the Swiss-U.S. Privacy Shield Framework (more information can be found here: https://www.privacyshield.gov/list. These agreements are intended to ensure compliance with European data protection standards in the USA.

Freshdesk's privacy policy can here and here can be viewed (Privacy Notice and Data Security Addendum). You have the option of withdrawing your consent to data processing at any time. A revocation does not affect the effectiveness of data processing operations in the past.

JOTFORM

If you contact our support team via the email address info@trackle.de or via Facebook Messenger, technical questions will be processed using questionnaires. The provider is Jotform Inc., San Francisco, USA, 111 Pine Street, Suite 1815, CA 94111.

If you enter and transmit data via the questionnaire for the purpose of processing a support request (e.g. email address, your name), these will be stored on JotForm's servers within the EU.

We have concluded a so-called "Data Processing Agreement" with Jotform, in which we oblige Jotform to protect our customers' data and not to pass it on to third parties. We have this contract. More information on data protection from Jotform is available at here visible.

You have the option of withdrawing your consent to data processing at any time. A revocation does not affect the effectiveness of data processing operations in the past.

11.  DATA COLLECTION IN THE COURSE OF TRACKLE CYCLE CONSULTING

The following personal data is processed for trackle cycle advice:
- Surname
- E-mail address
- Year of birth
- Information on the state of health


This necessary personal information is collected and stored by us exclusively for the preparation, processing and execution of the cycle consultation. The data can only be viewed and processed by authorized persons at trackle GmbH.


The questionnaire for preparing the trackle cycle consultation (trackleTalk) is processed by the provider Jotform Inc., San Francisco, USA, 111 Pine Street, Suite 1815, CA 94111.


If you enter and transmit data via the questionnaire for the purpose of processing the trackle cycle consultation (e.g. e-mail address, your name), these will be stored on JotForm's servers within the EU.


We have concluded a so-called "Data Processing Agreement" with Jotform, in which we oblige Jotform to protect our customers' data and not to pass it on to third parties. We have this contract. More information on data protection from Jotform can be found here.


You have the option of revoking your consent to data processing at any time without giving reasons by sending a message to info@trackle.de. A revocation does not affect the effectiveness of data processing operations in the past.

12. DATA COLLECTION WITHIN THE TRACKLE APPLICATION

APP, BACKEND, SENSOR

The use of the trackle service requires the storage and processing of health data (e.g. core body temperature and other cycle-related parameters). These data are recorded and stored in separate systems. The individual elements of the application are identified and linked exclusively using anonymized IDs. In addition, the data will not be passed on without the consent of the user.

In order to provide our services and to fulfill our legal obligations as a medical device manufacturer (e.g. in connection with recalls), we can assign individual devices to their buyers if necessary. This is done with reference to GDPR Article 6 (1) and MPG (Medical Devices Act), August 2002 edition, §29.
We ensure through strictly separate data storage that it is not possible for third parties to assign the data generated through the use of the trackle system to a buyer account.

13. ENCRYPTION, ENSURING THE INTEGRITY OF DATA

APP, BACKEND, SENSOR

The trackle system uses various cryptographic processes for reasons of security and to protect the transmission of confidential content, such as temperature data.

  • The connection between the sensor and the app is protected by the Bluetooth LE protocol.
  • The HTTP connection between the app and the backend is encrypted using the TLS method (TLS 1.2).
  • In addition, the integrity of the transmitted data is protected by an asymmetrical encryption process (public-private key process: ECC). Digital signatures prevent the data that you transmit from being changed unnoticed (content, sequence and completeness).

If you have any further questions about the security measures, please contact info@trackle.de at any time

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