Privacy policy

Below, we provide information about the collection of personal data when you use our website. Personal data includes any data that can be linked to you personally, such as your name, address, email addresses, and user behavior. We have implemented comprehensive technical and operational safeguards to protect your data from accidental or intentional manipulation, loss, destruction, or access by unauthorized persons. Our security procedures are regularly reviewed and adapted to technological advancements.

1. DATA CONTROLLER

The data controller pursuant to Art. 4(7) of the GDPR is:
trackle GmbH
Bertha-von-Suttner-Platz 1-7
53111 Bonn
Phone: 0228 90278777
Email: info@trackle.de
(see our Legal Notice)

2. CONTACT INFORMATION FOR THE DATA PROTECTION OFFICER

You can contact our Data Protection Officer at:
Mr. Maximilian Mertin
c/o intersoft consulting services AG
Beim Strohhause 17
20097 Hamburg
mmertin@intersoft-consulting.de

3. PURPOSE AND LEGAL BASIS FOR PROCESSING

Personal data is collected only if you voluntarily provide it to us, such as when taking out insurance through our website or when filling out the contact form. We use this data exclusively for the purpose for which you provided it. Use for other purposes occurs only after explicit notification or after obtaining your consent, in accordance with Article 6(1)(a) of the GDPR. In certain cases, personal data is processed on the basis of a legitimate interest pursuant to Article 6(1)(f) of the GDPR (see Section 4).

4. PROCESSING BASED ON A LEGITIMATE INTEREST PURSUANT TO ART. 6(1)(f) OF THE GDPR

Personal data is processed on the basis of Art. 6(1)(f) of the GDPR in the following cases:

4.1. COLLECTION OF PERSONAL DATA WHEN VISITING OUR WEBSITE

When you use the website solely for informational purposes, we collect only the personal data that your browser transmits to our server. If you wish to view our website, we collect the following data, which is technically necessary for us to display our website to you and to ensure its stability and security:

Browser type and version
Operating system used
Referrer URL
Hostname of the accessing computer
Time of the server request
IP address

Our legitimate interest lies in the proper display of our website and in ensuring its stability and security.

4.2. USE OF COOKIES

What are cookies? Cookies are pieces of data stored on your computer by a website you visit, which enable your browser to be identified upon subsequent visits. Cookies transmit information to the entity that sets the cookie. Cookies can store various types of information, such as your language setting, the duration of your visit to our website, or the data you enter there. This prevents you, for example, from having to re-enter required form data every time you use the site. The information stored in cookies can also be used to identify preferences and tailor content to your areas of interest.

There are different types of cookies: Session cookies are data that are stored temporarily in the browser’s cache and deleted when you close your browser. Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie. With this type of cookie, the information may also be stored in text files on your computer. However, you can delete these cookies at any time via your browser settings.

First-party cookies are set by the website you are currently visiting. Only this website is permitted to read information from these cookies. Third-party cookies are set by organizations that do not operate the website you are visiting. These cookies are used, for example, by marketing companies.

The legal basis for the processing of personal data via cookies and their retention period may vary. If you have given us your consent, the legal basis is Article 6(1)(a) of the GDPR. If data processing is based on our legitimate interests, the legal basis is Article 6(1)(f) of the GDPR. The stated purpose then corresponds to our legitimate interest.

We use cookies to ensure the proper operation of the website, to provide basic functionality, to measure reach, and—with your consent—to tailor our services to your preferred areas of interest. To do this, we use both session cookies and persistent cookies.

You can delete cookies already stored on your device at any time. If you wish to prevent cookies from being stored, you can do so via the settings in your web browser. Instructions for common browsers can be found here: Internet Explorer, Firefox, Google Chrome, Google Chrome (mobile), Microsoft Edge, Safari, Safari (mobile). Alternatively, you can install so-called ad blockers. Please note that certain features of our website may not function properly if you have disabled cookies.

4.3. WEBSITE ANALYSIS

For the purposes of analyzing and optimizing our websites, we use various services, which are described below. This allows us, for example, to analyze how many users visit our site, what information is most in demand, or how users find our site. Among other things, we collect data on which website a user came from (known as the “referrer”), which subpages of the website were accessed, and how often and for how long a subpage was viewed. This helps us design and improve our offerings to make them more user-friendly. The data collected in this process is not used to personally identify individual users.

Google Analytics 4

If you have given your consent, we use Google Analytics, a web analytics service provided by Google LLC. The responsible service provider in the EU is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

Google Analytics uses cookies that enable an analysis of your use of our websites. The information collected via cookies about your use of this website is generally transmitted to a Google server in the United States and stored there.

We use Google Signals. This allows Google Analytics to collect additional information about users who have enabled personalized ads (interests and demographic data), and ads can be delivered to these users in cross-device remarketing campaigns.

We use the “anonymizeIP” function (so-called IP masking): Because IP anonymization is enabled on this website, your IP address is truncated by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the United States and truncated there. The IP address transmitted by your browser as part of Google Analytics is not combined with other data held by Google.

During your visit to the website, the following data, among other things, is collected:

The pages you visit, your “click path”
Achievement of “website goals” (conversions, e.g., newsletter sign-ups, downloads)
Your user behavior (e.g., clicks, time spent on the site, bounce rates)
Your approximate location (region)
Your IP address (in truncated form)
Technical information about your browser and the devices you use (e.g., language settings, screen resolution)
Your internet service provider
The referrer URL (the website or advertising channel through which you arrived at this website).

Purposes of Processing

On behalf of the operator of this website, Google will use this information to evaluate your (pseudonymous) use of the website and to compile reports on website activity. The reports provided by Google Analytics are used to analyze the performance of our website and the success of our marketing campaigns.

If consent has been granted, information is also transmitted to Google regarding whether and which consents have been granted (Advanced Google Consent Mode).

Recipients

The recipient of the data is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, acting as a data processor. We have entered into a data processing agreement with Google for this purpose. Google LLC, headquartered in California, USA, and, where applicable, U.S. government authorities may access the data stored by Google. On July 10, 2023, the European Commission adopted its adequacy decision for the United States. Google LLC is certified under the EU-U.S. Privacy Framework. Since Google’s servers are distributed worldwide and a transfer to third countries (such as Singapore) cannot be completely ruled out, we have also entered into the EU Standard Contractual Clauses with the provider.

Retention Period

The data we send that is linked to cookies is automatically deleted after 14 months. Data that has reached the end of its retention period is automatically deleted once a month.

To prevent Analytics from tracking you across different devices, you must opt out on all devices you use. Clicking here will set the opt-out cookie: <a href="javascript:gaOptout()"><strong>Disable Google Analytics</strong></a></p>

For more information on the Google Analytics Terms of Service and Google’s privacy policy, please visit https://marketingplatform.google.com/about/analytics/terms/de/ and https://policies.google.com/?hl=de.

Legal Basis and Right to Withdraw Consent The legal basis for this data processing is your consent, Article 6(1)(a) of the GDPR. You may withdraw your consent at any time with future effect by opening the privacy settings in the lower-left corner (“shield”) and adjusting the slider accordingly.

Facebook Connect

We offer you the option to register and log in using your Facebook account. If you register via Facebook, Facebook will ask for your consent to share certain data from your Facebook account with us. This may include your first name, last name, and email address to verify your identity and gender, as well as your general location, a link to your Facebook profile, your time zone, your date of birth, your profile picture, your “Likes,” and your friends list.

This data is collected by Facebook and transmitted to us in accordance with the provisions of Facebook’s Data Policy (https://de-de.facebook.com/privacy/explanation). You can control the information we receive from Facebook through the privacy settings in your Facebook account.

This data is used to set up, provide, and personalize your account.

If you register with us via Facebook, your account will automatically be linked to your Facebook account, and information about your activities on our websites may be shared on Facebook and published on your Timeline and in the News Feed for your friends.

Legal Basis and Right to Withdraw Consent

The legal basis for this data processing is your consent, Article 6(1)(a) of the GDPR. You may withdraw your consent at any time with future effect by opening the privacy settings in the lower-left corner (“lock”) and adjusting the slider accordingly.

Facebook Custom Audiences (Facebook Pixel)

As part of our usage-based online advertising, we use the Custom Audiences service provided by Facebook Inc. (1601 S. California Avenue, Palo Alto, CA 94304, USA). For this purpose, we use Facebook Ads Manager to define audiences of users based on specific characteristics, who will then be shown ads within the Facebook network. Facebook selects these users based on the profile information they have provided, as well as other data generated through their use of Facebook. If a user clicks on an ad and is subsequently redirected to our website, Facebook receives information via the Facebook Pixel embedded on our website that the user clicked on the ad banner. In general, a non-reversible and non-personally identifiable checksum (hash value) is generated from your usage data and transmitted to Facebook for analysis and marketing purposes. A Facebook cookie is set in the process. This cookie collects information about your activities on our website (e.g., browsing behavior, subpages visited, etc.). Your IP address is also stored and used for the geographic targeting of advertisements. We do not use Facebook Custom Audiences via the customer list or the “advanced matching” feature.

For more information about the purpose and scope of data collection and the further processing and use of the data by Facebook, as well as your options for protecting your privacy, please refer to Facebook’s Privacy Policy. You can adjust your settings regarding which ads are displayed to you on Facebook via this link and in your Facebook account settings.

For more information on data processing and retention periods, please contact the provider or visit https://www.facebook.com/about/privacy.

Logged-in users can disable the “Facebook Custom Audiences” feature at https://www.facebook.com/settings/?tab=ads#_.

You can also prevent the storage of cookies altogether by adjusting your browser settings accordingly. However, please note that in this case, you may not be able to use all features of our website to their full extent. For additional options to disable third-party cookies, visit www.networkadvertising.org/managing/opt_out.asp or the Digital Advertising Alliance Opt-Out Platform at http://optout.aboutads.info/?c=2&lang=en.

Legal Basis and Right to Withdraw Consent

TikTok Custom Audiences (TikTok Pixel)

If you have given your consent, trackle uses the so-called “TikTok Pixel” from the social network TikTok—operated by TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland (“TikTok”)—as part of usage-based online advertising. With the help of the TikTok Pixel, TikTok is able, on the one hand, to identify you as a visitor to our online service as a target audience for the display of ads (so-called “TikTok Ads”). Accordingly, we use the TikTok pixel to display the TikTok ads we place only to those TikTok users who have shown an interest in our online offering or who exhibit certain characteristics (e.g., interests in specific topics or products, determined based on the websites they have visited), which we transmit to TikTok (so-called “Custom Audiences”). We also use the TikTok pixel to ensure that our TikTok ads align with users’ potential interests and do not come across as intrusive. Using the TikTok pixel, we can further track the effectiveness of TikTok ads for statistical and market research purposes by seeing whether users were redirected to our website after clicking on a TikTok ad (so-called “conversion”).

For more information about the purpose and scope of data collection and the further processing and use of the data by TikTok, please refer to TikTok’s Privacy Policy.

Legal Basis and Option to Withdraw Consent

The legal basis for this data processing is your consent, Art. 6(1)(a) GDPR. You may withdraw your consent at any time with future effect by opening the privacy settings in the lower-left corner (“lock”) and adjusting the slider accordingly.

Consent (and option to withdraw)

This marketing activity may not take place without the user’s consent. Therefore, it must be integrated into the Consent Manager on the homepage.

Data Processing Agreement

TikTok acts as a data processor for trackle (analytics, measurements, etc.). Data processing in the sense of data protection law occurs in cases where one company is primarily commissioned by another company to process personal data (for example, external payroll accounting, newsletter distribution, or the use of Google Analytics). In such cases, a corresponding contract must be entered into with the service provider. This contract governs how the service provider is permitted to handle the data entrusted to it by the client. Most companies in the field of online marketing and tracking automatically offer this to their customers through their customer portal.

Google Tag Manager

For the sake of transparency, we would like to point out that we use Google Tag Manager. This is a tag management system for managing JavaScript and HTML tags, which is used to implement tracking and analytics tools. The service provider is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland.

Google Tag Manager itself does not collect any personal data. Tag Manager makes it easier for us to integrate and manage our tags. Tags are small pieces of code used, among other things, to measure traffic and visitor behavior, track the impact of online advertising and social media channels, set up remarketing and targeting, and test and optimize websites. If you have opted out, this opt-out will be honored by Google Tag Manager. For more information about Google Tag Manager, see:

www.google.com/intl/de/tagmanager/use-policy.html
https://www.google.com/intl/de/tagmanager/faq.html
https://safety.google/privacy/privacy-controls/

Mable Tracking

If you have given your consent, trackle uses Mable Tracking (Mable GmbH, Bahnhofplatz 12, 76137 Karlsruhe) for usage-based online advertising. This digital tracking tool collects conversion data to optimize advertising campaigns. This includes purchases, abandoned carts, and other relevant actions. Cookies are used for this purpose. The following data may be collected:

IP address
User-Agent
Order number
Product name, ID, and variant
Quantity (of products)
Location data (country, state, ZIP code, city)
Click IDs (FBCLID, GCLID, ...)
Browser IDs (e.g., FBP)
External IDs (e.g., session ID)
User behavior on the website
Name
Email address
Phone number

The collected data is sent via the Conversion API to the algorithms of the respective advertising platforms (Meta Platforms, TikTok, Google, etc.). Please note that this service may transfer data outside the European Union and the European Economic Area to a country that does not provide an adequate level of data protection. The data will be deleted once the purpose for which it was collected no longer applies.

Legal Basis and Right to Withdraw Consent

The legal basis for this data processing is your consent, pursuant to Article 6(1)(a) of the GDPR. You may withdraw your consent at any time with future effect by opening the privacy settings in the lower-left corner (“lock”) and adjusting the slider accordingly.

Microsoft Advertising

If you have given your consent, trackle uses Microsoft Advertising for usage-based online advertising. The responsible service provider in the EU is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland.

Microsoft Advertising is an online advertising platform that enables companies to promote their products and services through search engine advertising. To do this, Microsoft Advertising uses cookies and web beacons.

The following data is processed during use:

IP address
Microsoft click ID
Microsoft cookie
Browser language
Page title
Referrer URL
Ads clicked
UET
GUID generated by the UET tag
Screen color depth
Screen resolution

Please note that this service may transfer data outside the European Union and the European Economic Area to a country that does not provide an adequate level of data protection. If the data is transferred to the United States, there is a risk that your data may be processed by U.S. authorities for monitoring and surveillance purposes, without you necessarily having any legal recourse.

For more information on Microsoft Advertising, see:

https://privacy.microsoft.com/en-gb/privacystatement

The legal basis for this data processing and the option to withdraw consent is your consent, Art. 6(1)(a) of the GDPR. You may withdraw your consent at any time with future effect by opening the privacy settings in the lower left corner (“lock”) and adjusting the slider accordingly.

Matomo

If you have given your consent, trackle uses the open-source web analytics service Matomo, provided by InnoCraft Ltd, 7 Waterloo Quay, PO625, 6140 Wellington, New Zealand. InnoCraft’s representative in the EU and the point of contact for companies in the EU/EEA is ePrivacy Holding GmbH, Große Bleichen 21, 20354 Hamburg.

We use Matomo to statistically analyze the user behavior of our website visitors in order to optimize the website’s functionality and stability, as well as for marketing purposes.

When using Matomo, we employ cookies that are stored in the website visitor’s browser and assign unique identifiers to the visitor’s device (tracking cookie ID). In this way, in conjunction with other data—such as the IP address—we can associate specific usage behavior on the website with the device containing the cookie. When using Matomo, we also utilize Matomo’s so-called IP masking: This means that when using Matomo, we remove the last X or Y components (1) from every visitor IP address transmitted to us in order to protect users’ privacy. As a result, we cannot identify you as a user.

The usage information collected in the cookie (including your truncated IP address) is transmitted to our server and stored for usage analysis purposes. We host Matomo exclusively on our own servers. This means that no data is transmitted via Matomo to servers outside our control.

You can prevent cookies from being set by adjusting your browser settings accordingly; however, in this case, you may not be able to use all features of this website to their full extent.

We store the analytics data only for as long as required for the purpose of data processing, but for no longer than 1 year.

The legal basis and option to withdraw consent for this data processing is your consent, pursuant to Article 6(1)(a) of the GDPR or Section 25(1) of the TDDDG for access to information. You may withdraw your consent at any time with future effect by opening the privacy settings in the lower-left corner (“lock”) and adjusting the slider accordingly.

For more information on data protection with Matomo, please visit:

https://matomo.org/guide/manage-matomo/privacy/
https://matomo.org/privacy.

Klar! Insights - Attribution

We use the services of Klar Insights GmbH, Clemensstr. 2, 80803 Munich, Germany, a SaaS provider of business intelligence solutions for e-commerce companies. Klar Insights GmbH collects, processes, and stores data on this website and its subpages (user and session IDs, email addresses, IP addresses, and online identifiers such as cookie IDs and device IDs) on our behalf for the purposes of audience measurement and statistical analysis. To this end, we have entered into a data processing agreement with Klar Insights GmbH.

The collection of personal data is based on the legal basis of consent pursuant to Art. 6(1)(a) of the GDPR. If the user grants consent, the data to be processed is collected on a user-specific basis in accordance with § 25(1), sentence 1 of the TDDDG.

The following cookies are used for the various types of data collection mentioned above to ensure the respective type of collection:

september_id
september_has_consent
september_do_not_track (in case of objection)

To object to the use of Klar! Insights in general, please use this link. This will set a cookie named “september_do_not_track” from the domain “http://trackle.info”. Please do not delete this cookie, as otherwise we cannot guarantee that you will not be tracked by Klar.

Information on data protection and data usage by Klar can be found on the following website: https://app.getklar.com/legal/data-protection

4.4 ADVERTISING

We use cookies for marketing purposes to target our users with interest-based advertising. In addition, we use cookies to limit the frequency with which an advertisement is displayed and to measure the effectiveness of our advertising campaigns. This information may also be shared with third parties, such as ad networks. The legal basis for this is Article 6(1)(a) of the GDPR.

DoubleClick by Google

If you have given your consent, the online marketing tool DoubleClick by Google is used on this website. The responsible service provider in the EU is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

DoubleClick uses cookies to display ads relevant to users, to improve campaign performance reports, or to prevent users from seeing the same ads multiple times. To do this, Google uses a cookie ID to track which ads are displayed in which browser. This prevents the same ad from being displayed multiple times. In addition, DoubleClick can use cookie IDs to track so-called conversions related to ads. This is the case, for example, when a user sees a DoubleClick ad and later visits the advertiser’s website using the same browser and makes a purchase there.

When you visit a page that uses DoubleClick and where the DoubleClick script is enabled, your browser automatically establishes a direct connection to Google’s server. Through the integration of DoubleClick, Google receives the information that you have visited the relevant part of our website or clicked on one of our ads. If you are registered with a Google service, Google can associate the visit with your account.

You can prevent data collection through this tracking method in several ways:

a. By adjusting your browser settings accordingly. Blocking third-party cookies will prevent you from seeing third-party ads.
b. By disabling cookies for conversion tracking, you can prevent interest-based ads from being displayed to you. To do this, you must block cookies from the domain “www.googleadservices.com” in your browser.
c. You can set an opt-out cookie at https://www.google.de/settings/ads. However, this setting will be deleted if you clear all your cookies.
d. By disabling interest-based ads from providers participating in the “About Ads” self-regulatory campaign via the link http://www.aboutads.info/choices; note that this setting will be deleted if you clear your cookies; d) by permanently disabling cookies in your browser via the link https://www.google.com/settings/ads/plugin. Please note that in this case, you may not be able to fully use all features of our website.

For more information about DoubleClick by Google, visit https://www.google.de/doubleclick and https://support.google.com/adsense/answer/2839090, and for general information about Google's privacy practices, visit https://www.google.de/intl/de/policies/privacy. Alternatively, you can visit the Network Advertising Initiative (NAI) website at https://www.networkadvertising.org.

Legal Basis and Right to Withdraw Consent

Google Analytics Audiences

If you have given your consent, this website uses Google Analytics Audience (GA Audience), an advertising and conversion tracking service. The responsible service provider in the EU is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

GA Audience uses cookies that are stored on your computer and other mobile devices (e.g., smartphones, tablets, etc.) and enable an analysis of how these devices are used. Some of this data is analyzed across devices. Google Audience has access to the cookies created through the use of Google AdWords and Google Analytics. The following data is processed during use:

User agent
Location information
Referrer URL
IP address
Page depth
Session duration
Date and time of the visit
Usage data

You can find further information on data protection when using GA Audience at the following link: https://support.google.com/analytics/answer/2700409?hl=en&ref_topic=2611283

Legal Basis and Right to Withdraw Consent

The legal basis for this data processing is your consent, Art. 6(1)(a) of the GDPR. You may withdraw your consent at any time with future effect by opening the privacy settings in the lower-left corner (“lock”) and adjusting the slider accordingly.

Google Marketing and Remarketing Services

We use the marketing and remarketing services (hereinafter “Google Marketing Services”) provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, to optimize and operate our online offering in a cost-effective manner. The data controller for users in the EU, the EEA, and Switzerland is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland.

Google Marketing Services allow us to display ads for our website in a more targeted manner, so that we present you only with ads that are likely to match your interests. For example, if you see ads for our services on other websites, this is referred to as “remarketing.” For these purposes, when you visit our website or other websites where Google Marketing Services are active, Google immediately executes a Google code, and so-called (re)marketing tags (invisible graphics or code, also known as “web beacons”) are embedded in the website. With their help, an individual cookie—that is, a small file—is stored on your device (comparable technologies may also be used instead of cookies).

The cookies may be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com, or googleadservices.com. This file records which websites you have visited, what content you are interested in, and which offers you have clicked on, as well as technical information about your browser and operating system, referring websites, the time of your visit, and other details regarding your use of the online service. Your IP address is also collected; however, we note in connection with Google Analytics that the IP address is truncated within member states of the European Union or in other signatory states to the Agreement on the European Economic Area, and is only transmitted in full to a Google server in the United States—and truncated there—in exceptional cases.

The IP address is not combined with your data from other Google services. Google may also combine the information mentioned above with information from other sources. When you subsequently visit other websites, you may be shown ads tailored to your interests.

We process your data pseudonymously within the framework of Google Marketing Services. This means that Google does not, for example, store or process your name or email address, but rather processes the relevant data on a cookie-based basis within pseudonymous user profiles. The information collected by Google Marketing Services about users is transmitted to Google and stored on Google’s servers in the United States.

The Google marketing services we use include, among others, the online advertising program “Google Ads” (formerly “Google AdWords”). In the case of Google Ads, each Ads customer receives a different “conversion cookie.” Cookies cannot therefore be tracked across the websites of Ads customers. The information collected via the cookie is used to generate conversion statistics for Ads customers who have opted in to conversion tracking. Ads customers are informed of the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that could be used to personally identify users.

To the extent that data is processed outside the EEA, where there is no level of data protection equivalent to the European standard, we have entered into EU Standard Contractual Clauses with the service provider to ensure an adequate level of data protection.

For more information on Google’s use of data for marketing purposes, please visit the overview page: https://www.google.com/policies/technologies/ads. Google’s Privacy Policy is available at https://www.google.com/policies/privacy.

Legal Basis and Right to Withdraw Consent

Pinterest Conversion Tracking

We use conversion tracking technology from the social network Pinterest (Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland) on our website. This technology enables us to display ads and offers relevant to our website visitors—who have already shown interest in our website and our content/offers and are Pinterest members—on Pinterest as well. To this end, a so-called conversion tracking pixel from Pinterest is embedded on our pages; when you visit our website, this pixel notifies Pinterest that you have visited our website and which parts of our offerings you were interested in. For example, if you showed interest in our subscriptions on our website, you may see an ad for our subscriptions on Pinterest.

You can opt out of the collection of data for displaying interest-based ads on Pinterest at any time in your Pinterest account settings at https://www.pinterest.de/settings (there, under “Personalization,” uncheck the box labeled “Use information from our partners to better tailor recommendations and ads on Pinterest to you”) or at https://help.pinterest.com/de/article/personalization-and-data#info-ad (uncheck the box under “Turn off personalization”).

For more information on data protection at Pinterest Europe Limited, please visit: https://policy.pinterest.com/de/privacy-policy.

Legal Basis and Right to Withdraw Consent

4.5 USE OF SOCIAL PLUGINS AND EMBEDDED GOOGLE YOUTUBE FUNCTIONS

We use services from YouTube, a video content provider owned by Google LLC, on our website. The responsible service provider in the EU is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). This is intended to improve our online offering.

This always requires that the providers of this content (hereinafter referred to as “third-party providers”) collect the users’ IP addresses. Without the IP address, they would not be able to send the content to the respective user’s browser. The IP address is therefore necessary for displaying this content. We make every effort to use only content whose respective providers use the IP address solely for the purpose of delivering the content. However, we have no control over whether third-party providers store the IP address, for example, for statistical purposes. To the extent that we are aware of this, we inform users accordingly.

Legal Basis and Right to Withdraw Consent

Google reCaptcha

We use reCaptcha v2 on our websites. reCaptcha is a service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. The data controller for users in the EU, the EEA, and Switzerland is Google Ireland Limited, Google Building, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland.

reCaptcha is used to prevent abusive automated submissions in web forms and thus to protect the host’s technical systems.

When you visit one of our websites that incorporates reCaptcha, a connection is established with Google’s servers. A reCaptcha cookie is set. Your IP address is transmitted to Google.
In addition, reCaptcha collects the following data using “fingerprinting”:

browser plugins used
cookies set by Google in the last 6 months
number of mouse clicks and taps you have made on this screen
CSS information for the page you are viewing
JavaScript objects
the date
the browser language

You can prevent the storage of cookies and fingerprinting by selecting the appropriate technical settings in your browser software; however, please note that in this case, you may not be able to use all features of this website to their full extent.

Google’s Privacy Policy and Terms of Service can be found here: https://www.google.com/policies/privacy/ and here: https://policies.google.com/terms.

Legal Basis and Right to Withdraw Consent

Spotify/Spotify for Podcasters

Provided you have given your consent, we use services from Spotify, a provider of audio content for listening, on our website. The responsible service provider in the EU is Spotify AB, Regeringsgatan 19, SE-111 53 Stockholm, Sweden. This serves to improve our online offerings, particularly in terms of marketing, the provision of our online services, and user-friendliness.

As a result, when you visit our site via the plugin, a direct connection is established between your browser and the Spotify server. Spotify thereby receives the information that you have visited our site. If you click the Spotify button while logged into your Spotify account, you can link the content of our site to your Spotify profile. This allows Spotify to associate your visit to our site with your user account.

The following data is processed during use:

Browser information
Date and time of the visit
Device information
Geographic location
IP address
Search terms
URL
Usage data
User account information
Content accessed

For more information, please see Spotify’s Privacy Policy and Cookie Policy.

The legal basis for this data processing and the option to withdraw consent is your consent, Article 6(1)(a) of the GDPR. You may withdraw your consent at any time with future effect by opening the privacy settings in the lower-left corner (“lock”) and adjusting the slider accordingly.

5. APPLICATIONS

You can apply to our company online via email through our application portal at https://trackle.de/ueber-uns/jobs/. Please note that emails sent without encryption are not transmitted in a secure manner.

Your information will be used to process your application and to decide whether to establish an employment relationship. The legal basis for this is Section 26(1) in conjunction with Section 8, sentence 2 of the German Federal Data Protection Act (BDSG). Furthermore, your personal data may be processed to the extent necessary to defend against any legal claims asserted against us arising from the application process. The legal basis for this is Article 6(1)(f) of the GDPR. The stated purposes also constitute a legitimate interest in the processing.

If an employment relationship is established between you and us, we may, pursuant to Section 26(1) of the Federal Data Protection Act (BDSG), continue to process the personal data already received from you for purposes related to the employment relationship if this is necessary for the performance or termination of the employment relationship or for the exercise or fulfillment of the rights and obligations of the employee representative body arising from a law, a collective bargaining agreement, a company agreement, or a service agreement (collective agreement).

Your application data will not be processed beyond the scope described above.

Your personal data will be deleted no later than 6 months after the conclusion of the application process, provided that no other legitimate interests on our part preclude deletion or you have not given us consent for longer storage. Other legitimate interests in this sense include, for example, a burden of proof in proceedings under the General Equal Treatment Act (AGG).

6. REGISTRATION ON THIS WEBSITE

You have the option to register on our website and create a customer account.
For registration, we collect and store the following information from you:

First name
Last name
Email
Password

We use the so-called double opt-in procedure for registration, which means your registration is not complete until you have confirmed it by clicking the link in a confirmation email sent to you for this purpose. If you do not provide this confirmation, your registration will be automatically deleted from our database. Once registration is complete, you will receive personal, password-protected access and will be able to view and manage the data you have provided. Registration is voluntary but may be a prerequisite for using certain services we offer.

We store the data necessary to fulfill the contract—including, where applicable, payment method details—until you permanently delete your account. We also store any additional data you have provided for the duration of your use of the customer/user account, unless you delete it beforehand. You can manage and change all of this information in the secure customer area.

You can delete your customer account at any time. To do so, please send us an email at info@trackle.de. Upon deletion of the account, all personal data not subject to a statutory retention obligation or Article 17(3) of the GDPR will be deleted.

The legal basis for this data processing is Article 6(1)(a), (b), and (f) of the GDPR.

7. NEWSLETTER

General Information

You can subscribe to newsletters on our website, through which we will keep you informed about the latest news, offers, and discounts. The legal basis for sending the respective newsletter is your consent pursuant to Art. 6(1)(a) of the GDPR in conjunction with § 7(2)(3) of the UWG, or the statutory permission pursuant to § 7(3) of the UWG.

We use the so-called double opt-in procedure for subscribing to our newsletters. This means that after you subscribe, we will send an email to the email address you provided, asking you to confirm that you wish to receive the newsletter. If you do not confirm your subscription, your information will be automatically deleted after 3 days.

The information we receive is used to address you personally. After your confirmation, we store your email address for the purpose of sending you the newsletter until you revoke your consent. We also store your IP address as it was at the time of registration, the time of registration, and the confirmation for up to three years after registration (statute of limitations). The purpose of this procedure is to be able to verify your registration in case of doubt and, if necessary, to investigate any misuse of your personal data. The legal basis for logging the registration is our legitimate interest pursuant to Art. 6(1)(f) of the GDPR in verifying previously given consent; see also Art. 7(1) of the GDPR.

You may revoke your consent to receive the newsletter at any time and unsubscribe from it. You can revoke your consent by clicking the link provided in every newsletter email.

Klaviyo

We use "Klaviyo" as a marketing platform—a service provided by Klaviyo Inc., 225 Franklin St, Floor 10, Boston MA 02110, USA.
Klaviyo is marketing automation software that focuses on email data in the context of newsletter subscriptions. Klaviyo enables us to analyze and optimize marketing campaigns. A cookie is set for this purpose.

In addition, device-specific information is collected, namely device type, operating system information, URLs, search terms, usage data, cookie information, IP address, and the date and time of the visit.

Processing in the USA is based on Standard Contractual Clauses (https://www.klaviyo.com/privacy/dpa), supplemented by specific security measures.

The data you provide to us for the purpose of receiving the newsletter is stored until you unsubscribe; once you unsubscribe, the data is deleted from both our servers and Klaviyo’s servers. Data stored by us for other purposes (e.g., email addresses for the member area) remains unaffected by this.

Please note that when we send the newsletter, we analyze your user behavior to determine whether and when the newsletter was opened. For this analysis, the emails sent contain "web beacons" or "tracking pixels" that are stored on our server and loaded when the newsletter is opened. Technical information such as browser type, the time of opening, and IP address is transmitted during this process. For these analyses, we link the aforementioned data and the web beacons to your email address and an individual ID. Links contained in the newsletter also include this ID, enabling us to analyze your click behavior. If you do not wish for your data to be analyzed by Klaviyo, you must unsubscribe from the newsletter. We provide a corresponding link for this purpose in every newsletter message. You may revoke this consent at any time by unsubscribing from the newsletter. The lawfulness of data processing operations already carried out remains unaffected by your revocation.

8. E-BOOK

You can obtain an e-book via our website. To do so, we require your email address and your name (optional). You will then receive the e-book as well as the latest news, offers, and discounts at the email address provided.

We use the so-called "double opt-in" procedure for newsletter subscriptions. This means that after you sign up, we send an email to the address provided, asking you to confirm that you wish to receive the newsletter. If you do not confirm your registration, your information will be automatically deleted after [number] days.

The information provided is used to address you personally. Following your confirmation, we store your email address for the purpose of sending the newsletter until you withdraw your consent. We also store the IP address used at the time of registration, the time of registration, and the confirmation for up to three years after registration (statute of limitations). The purpose of this procedure is to be able to prove your registration in the event of a dispute and, if necessary, to investigate any misuse of your personal data. The legal basis for logging the registration is our legitimate interest pursuant to Art. 6(1)(f) GDPR in being able to prove that consent was previously given; see also Art. 7(1) GDPR.

The legal basis for sending the e-book and the respective newsletter is your consent pursuant to Art. 6(1)(a) GDPR in conjunction with Section 7(2) No. 3 of the German Act Against Unfair Competition (UWG), or statutory permission pursuant to Section 7(3) UWG.

You may withdraw your consent to receive the newsletter and unsubscribe at any time. You can declare your withdrawal by clicking the link provided in every newsletter email.

9. DATA TRANSFER AND RECIPIENTS OR CATEGORIES OF RECIPIENTS

As a general rule, your data is not transferred to third parties unless we are legally obliged to do so, the transfer is necessary for the performance of the contractual relationship, or you have previously given your express consent to the transfer of your data.

External service providers and partner companies—such as online payment providers or the shipping company commissioned with delivery—receive your data only to the extent necessary to process your order. In such cases, however, the scope of the transferred data is limited to the necessary minimum. Where our service providers come into contact with your personal data and process it on our behalf and in accordance with our instructions, we ensure—within the framework of data processing agreements pursuant to Art. 28 GDPR—that they comply with data protection regulations to the same standard. Please also refer to the respective privacy policies of these providers. The respective service provider is responsible for the content of third-party services; however, we do verify—to the extent reasonably possible—that these services comply with legal requirements.

PayPal

On our website, we offer payment via PayPal, among other options. 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 select payment via PayPal, the payment data you enter will be transmitted to PayPal. The legal basis for this data processing is Art. 6(1)(b) of the GDPR.

Klarna

We offer payment via Klarna on our website, among other options. The provider of this payment service is Klarna Bank AB (publ.), Sveavägen 46, 11134 Stockholm (hereinafter referred to as “Klarna”). If you select payment via Klarna, the payment data you enter will be transmitted to Klarna. The legal basis for this data processing is Art. 6(1)(b) GDPR.

Stripe

We offer payment via Stripe, among other options, on our website. The provider of this payment service is Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA. If you select payment via Stripe (credit card), the payment details you enter are transmitted to Stripe. The legal basis for this data processing is Art. 6(1)(b) GDPR. We have entered into a data processing agreement with Stripe in which we oblige Stripe to protect our customers' data and not to disclose it to third parties. This agreement can be viewed at the following link: https://stripe.com/dpa/legal

Bold Subscription

When you sign up for a trackle subscription on our website, Bold Subscription is used to manage the subscription functionality. The provider of this service is Bold Innovation Group Ltd, 50 Fultz Boulevard, Winnipeg, MB, R3Y 0L6, Canada.
If you select the "trackleGo" product—and thus the recurring payment option—the payment details you enter are transmitted to Bold Subscription. The legal basis for this data processing is Art. 6(1)(b) of the GDPR. We have entered into a data processing agreement with Bold Innovation, in which we require Bold Innovation to protect our customers' data and not to disclose it to third parties. This agreement can be viewed at the following link: https://boldcommerce.com/legal#gdpr-compliance

Shopify

This website uses Shopify’s services to process purchasing transactions. The provider is Shopify International Limited, Victoria Buildings, 2nd Floor, 1-2 Haddington Road, Dublin 4, D04 XN32, Ireland (hereinafter referred to as "Shopify").

Shopify is a service used to set up and manage online shop systems, among other things. When you enter data for the purpose of processing a purchase contract and shipping (e.g., email address), this data is stored on Shopify’s servers, including locations outside the EU. Shopify’s privacy policy can be viewed here: https://www.shopify.com/legal/privacy and here: https://www.shopify.com/legal/dpa. Data collected by Shopify for the performance of the contract is only passed on to third parties if necessary for contract processing, particularly in the following cases:

Address data to shipping companies for delivery purposes
Payment data to financial institutions for payment processing
Payment data to debt collection agencies in the event of the assignment of claims

The legal basis for this data processing is Art. 6(1)(b) GDPR.

Freshdesk Support & Chat

If you contact our support team via the email address info@trackle.de or via Facebook Messenger, your inquiries are routed to our helpdesk tool. The service provider is Freshworks Inc. (1250 Bayhill Drive, Suite 315, San Bruno, CA 94066, USA).

We also use live chat software to communicate with website visitors and provide optimal support. Cookies are set during this process. When the service is used, your IP address is stored in addition to any information you enter.

Legal basis and right to withdraw consent

The legal basis for this data processing is your consent (Art. 6(1)(a) GDPR). You may withdraw your consent at any time with effect for the future by opening the privacy settings at the bottom left (indicated by a "lock" icon) and adjusting the toggle accordingly.

If you enter and submit data for the purpose of processing a support request via email or Facebook Messenger (e.g., email address, your name), this data is stored on Freshdesk servers, including locations outside the EU.

Freshdesk’s privacy policy can be viewed here and here (Privacy Notice and Data Security Addendum). You have the option to withdraw your consent to data processing at any time. A withdrawal of consent does not affect the validity of data processing operations that took place in the past.

Legal basis and right to withdraw consent

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 submit data for the purpose of processing a support request via the questionnaire (e.g. email address, your name), it 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. More information about data protection from Jotform can be found here.

Legal basis and possibility of revocation

Your consent is required for this data processing, Art. 6 Para. 1 lit. a) GDPR. You can revoke your consent at any time with effect for the future by opening the data protection settings at the bottom left ("lock") and using the control there accordingly.

Webinaris

To better present our products, we use the technology provided by Webinaris, a service of Webinaris GmbH (Bussardstr. 5, 82166 Gräfelfing). When you register for or participate in online webinars, your first name, last name, email address, and IP address are processed. The legal basis for this data processing is Art. 6(1)(b) of the GDPR.

10. DURATION OF STORAGE

Personal data collected by us will be deleted once the purpose of processing no longer applies or upon the expiration of statutory retention periods.

11. INFORMATION REGARDING OBLIGATIONS OF THE DATA SUBJECT TO PROVIDE DATA

You are under no statutory or contractual obligation to provide data when using our website.

12. EXISTENCE OF AUTOMATED DECISION-MAKING, INCLUDING PROFILING

Automated decision-making, including profiling, pursuant to Art. 22 GDPR does not take place.

13. YOUR RIGHTS

You have the following rights vis-à-vis us regarding the personal data concerning you:

13.1. General rights

You have the right to access, rectification, erasure, restriction of processing, objection to processing, and data portability. Where processing is based on your consent, you have the right to withdraw such consent with effect for the future.

13.2. Rights regarding data processing based on legitimate interests

Pursuant to Art. 21(1) GDPR, you have the right to object at any time—on grounds relating to your particular situation—to the processing of personal data concerning you that is carried out based on Art. 6(1)(e) GDPR (data processing in the public interest) or Art. 6(1)(f) GDPR (data processing for the purposes of legitimate interests); this also applies to profiling based on these provisions. In the event of such an objection, 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 if the processing serves the establishment, exercise, or defense of legal claims.

13.3. Rights regarding direct marketing

Where we process your personal data for the purpose of direct marketing, you have the right, pursuant to Art. 21(2) GDPR, to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.

In the event of your objection to processing for direct marketing purposes, we will no longer process your personal data for these purposes.

13.4. Right to lodge a complaint with a supervisory authority

You also have the right to lodge a complaint with a competent data protection supervisory authority regarding our processing of your personal data.

14. CONTACTING US VIA E-MAIL OR CONTACT FORM

When you contact us via e-mail or a contact form, the data you provide (your e-mail address and name) is stored by us in order to answer your questions. Where we request information via our contact form that is not required for establishing contact, we have always marked such fields as optional. This information helps us to better understand your inquiry and process your request more effectively. Providing this information is entirely voluntary and based on your consent (Art. 6 para. 1 lit. a GDPR). Where this information relates to communication channels (e.g., e-mail address, telephone number), you also consent to us contacting you via that channel to address your request. You may, of course, revoke this consent at any time with effect for the future.

We delete the data arising in this context once storage is no longer necessary, or restrict processing if statutory retention obligations apply.

15. DATA SECURITY

We have implemented extensive technical and operational safeguards to protect your data against accidental or intentional manipulation, loss, destruction, or access by unauthorized persons. Our security procedures are regularly reviewed and updated in line with technological advancements.

16. DATA TRANSFER AND INTENDED DATA TRANSFER TO A THIRD COUNTRY OR INTERNATIONAL ORGANIZATION

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