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Data protection

Privacy Policy

Below you will find information about the way we collect personal data while you use our website. Personal data are all data which can be related to you personally, e.g. your name, postal address, email addresses and user behaviour. We have taken extensive technical and operational precautions to protect your data from accidental or intentional manipulation, loss, destruction or access by unauthorised persons. Our security procedures are regularly reviewed and adapted to technological progress.

1. Data controller

Data controller pursuant to Art. 4(7) GDPR:
 trackle GmbH

Bertha-von-Suttner-Platz 1–7

53111 Bonn, Germany

Phone: +49 228 90278777

Email: info@trackle.de

(see our Legal Notice)

2. Contacting our Data Protection Officer

Our Data Protection Officer can be reached as follows:

Mr Maximilian Mertin

c/o intersoft consulting services AG

Beim Strohhause 17

20097 Hamburg, Germany

mmertin@intersoft-consulting.de[MM1] 

3. Purpose and legal basis of processing

We will only collect personal data if you choose to disclose them to us, such as when you take out an insurance policy through our website or fill out the contact form. We will only use such data for the purpose for which you have entered them. Your data will only be used for other purposes after we have expressly informed you or after we have obtained your consent – see Art. 6(1)(a) GDPR. In certain cases, we will collect personal data on the basis of a legitimate interest, pursuant to Art. 6(1)(f) GDPR (see clause 4).

 

4. Processing based on legitimate interest, pursuant to Art. 6(1)(f) GDPR.

In the following instances, personal data will be processed on the basis of Art. 6(1)(f) GDPR:

4.1. Collection of personal data when you visit our website

When you use our website for the sole purpose of obtaining information, we shall only collect personal data that your browser sends to our server. When you view our website, we shall collect the following data which we require for technical reasons, so that we can display our website to you and so that we can warrant its stability and security:

  •     Browser type and version
  •     Your operating system
  •     Referrer URL
  •     Hostname of computer accessing our website
  •     Time of server request
  •     IP address

We have a legitimate interest in the faultless presentation of our website and in ensuring its stability and security.

4.2. Use of cookies

What are cookies? Cookies are data that are stored on your computer by a website you visit and which enable your browser to associate your computer with that website again. Cookies send information to the entity that sets them. Cookies can store various details, such as your language preference, the duration of your visit to our website and the input you have made there. This means, for example, that you need not re-enter data into a form whenever you use it again. The information stored in cookies can also be used to identify preferences and target content based on areas of interest.

There are different types of cookies: Session cookies are sets of data that are only stored in memory on a temporary basis and are deleted when you close your browser. Persistent cookies are automatically deleted after a specified period of time, which can vary from one cookie to another. With this type of cookie, the information can also be stored in text files on your computer. However, you can delete such cookies through your browser settings at any time.

First-party cookies are set by the website you are visiting at that time. In such cases, only this website is allowed to read information from such cookies. Third-party cookies are set by organisations that do not run the website you are visiting. Such cookies are used, for instance, by marketing companies.

The legal basis for the possible processing of personal data via cookies and their storage periods may vary. If you have given us your consent, the legal basis is Art. 6(1)(a) GDPR. If data processing is based on our overriding legitimate interests, the legal basis is Art. 6(1)(f) GDPR. In such a case, the stated purpose matches our legitimate interest.

We use cookies to ensure the proper operation of our website, to provide basic functionality, to measure its reach and – with your consent – to tailor our services to your preferred areas of interest. We use both transient cookies and persistent cookies for this purpose.

Whenever cookies are stored on your device, you can delete them at any time. If you want to prevent cookies from being stored, you can do so via the settings in your internet browser. You can find instructions for common browsers here: Internet ExplorerFirefoxGoogle ChromeGoogle Chrome mobileMicrosoft EdgeSafariSafari mobile. Alternatively, you can install so-called ad blockers. Please note that some functions of our website may not work if you have disabled the use of cookies.

4.3. Website analysis

We use a variety of services for the purpose of analysing and optimising our website, as detailed below. This enables us, for example, to analyse how many users visit our site, which details are most in demand and how users discover our services. For example, we collect data about the website from which data subjects have accessed our website (so-called referrers), which subpages of our website have been accessed or how often and for how long a subpage has been viewed. This helps us to develop and improve our services for the benefit of our users. Any data collected in this process will not be used to identify individual users personally. 

Google Universal Analytics

If you have given your consent, trackle uses Google Analytics, a web analysis service provided by Google LLC. The relevant service provider in the EU is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).
 
 Google Analytics uses cookies to analyse your use of our website. When cookies collect information concerning your use of our website, this information is generally sent to a server belonging to Google in the United States, where the information is then stored.

We use Google Signals. This allows Google Analytics to collect additional information about users who have enabled personalised ads (interests and demographics), and it also means that ads can be delivered to such users in cross-device remarketing campaigns.

We use the function ‘anonymizeIP’ (so-called IP masking): If you have activated IP anonymisation for this website, your IP address will not be sent without first being truncated by Google within the Member States of the European Union or other countries that are parties to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address sent to a Google server in the United States and truncated there. The IP address that is sent to Google Analytics by your browser is not merged by Google with any other data.

During your visit to our website, the following data are collected, among others:

  • The pages you have accessed, i.e. your “click path”.
  • Any “website destinations” you have reached (conversions, e.g. newsletter subscriptions, downloads)
  • Your user behaviour (e.g. clicks, duration of stay, bounce rates)
  • Your approximate location (region)
  • Your IP address (in truncated form)
  • Technical information about your browser and the end devices you use (e.g. language setting, screen resolution)
  • Your internet service provider
  • The referrer URL (i.e. the website or advertising medium through which you have reached our website)

Purposes of processing
 Google will use this information, as instructed by the operator of this website, with two aims: to analyse your (pseudonymous) use of our website and to compile reports on your site activities. The reports provided by Google Analytics serve the purpose of analysing the performance of our website and the success of our marketing campaigns.

Recipient
 The recipient of the data is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland as the processor. We have concluded a contract for commissioned data processing with Google for this purpose. All data stored by Google may be accessed by Google LLC, which is based in California, USA, and, where applicable, by US authorities.

Storage period
 Any data that we send and which are linked to cookies are automatically erased after 14 months. Any data that have come to the end of their retention period are automatically erased once a month.

In addition, if you wish to prevent Google from collecting data generated by cookies and relating to your use of our website (incl. your IP address), and if you wish to opt out of such data being processed by Google, you can proceed as follows:
 (a) refrain from giving your consent for the setting of cookies,
 (b) download and install the browser add-on provided 
HERE by Google Analytics for the purpose of disabling cookies.

You can also prevent the storage of cookies by selecting the appropriate setting in your browser software. However, if you configure your browser to reject all cookies, you may experience limited functionality on this and other websites. 
 
To prevent collection via Universal Analytics across multiple devices, you need to implement the opt-out on all the systems you use. 

You can find further details on the terms of use of Google Analytics and on Google’s privacy policy at https://marketingplatform.google.com/about/analytics/terms/us/ and at https://policies.google.com/?hl=en.

Legal basis and right to revoke:
 Data processing on this website is based on your consent, pursuant to Art. 6(1)(a) GDPR. You can revoke your consent at any time with effect for the future: open the data protection settings at the bottom left (“shield” icon) and move the slider in the relevant direction.

Facebook Connect

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

These data are collected by Facebook and sent to us under the terms of Facebook's data policy (https://www.facebook.com/privacy/explanation). You can control the information we receive from Facebook through the privacy settings in your Facebook account.

These data are used to create, provide and personalise your account.

If you sign on with us via Facebook, your account will automatically be connected to your Facebook account, and information about your activities on our websites may be shared on Facebook and published on your timeline and in your news feed, where it will be visible to friends.

Legal basis and right to revoke:
 Data processing on this website is based on your consent, pursuant to Art. 6(1)(a) GDPR. You can revoke your consent at any time with effect for the future: open the data protection settings at the bottom left (“shield” icon) and move the slider in the relevant direction.

Facebook Custom Audiences (Facebook pixel)

We use the Custom Audiences service of Facebook Inc. as part of our usage-based online advertising (1601 S. California Avenue, Palo Alto, CA 94304, USA). For this purpose, we define target groups of users based on certain characteristics in the Facebook Ads Manager, who will subsequently be shown ads within the Facebook network. Users are selected by Facebook based on the profile details they provide and other data generated through their use of Facebook. When a user clicks on an advertisement and subsequently reaches our website, Facebook receives the information that the user has clicked on the advertising banner via the Facebook pixel embedded on our website. As a rule, a non-reversible and non-personal checksum (hash value) is generated from your usage data, which is then sent to Facebook for analysis and marketing purposes. A Facebook cookie is set in the process which collects information about your activities on our website (e.g. surfing behaviour, pages visited, etc.). In addition, your IP address is stored and used for the geographical targeting of advertising. We do not use Facebook Custom Audiences via the customer list, nor do we use the advanced matching function.

Please see Facebook’s privacy policy for further information on the purpose and scope of data collection and the further processing and use of the data by Facebook as well as settings options for protecting your privacy. Use this link and your Facebook account settings to specify which advertisements should be presented to you on Facebook.
 Further details on data processing and storage periods can be obtained from the provider or at 
https://www.facebook.com/about/privacy.
 You can disable the Facebook Custom Audiences function for logged-in users at https://www.facebook.com/settings/?tab=ads#_.

You can also prevent the storage of cookies altogether by selecting the appropriate setting in your browser software. Please note, however, that if you do so, you may not be able to use all the functions of our website in full. You can find further options for disabling third-party cookies at www.networkadvertising.org/managing/opt_out.asp and on the Digital Advertising Alliance’s opt-out platform, at http://optout.aboutads.info/?c=2&lang=en.

Legal basis and right to revoke:
 Data processing on this website is based on your consent, pursuant to Art. 6(1)(a) GDPR. You can revoke your consent at any time with effect for the future: open the data protection settings at the bottom left (“shield” icon) and move the slider in the relevant direction.

TikTok Custom Audiences (TikTok pixel)
 
 
If you have provided your consent, trackle will use the so-called “TikTok pixel” of the social network TikTok, which is operated by TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland (“TikTok”), for the purpose of usage-based online advertising. The TikTok pixel enables TikTok to identify you as a visitor of our website and therefore as part of the target group for the display of advertisements (so-called “TikTok ads”). Correspondingly, we use the TikTok pixel to present TikTok ads placed by us only to TikTok users who have also shown an interest in our website or who have certain characteristics (e.g. interest in certain topics or products identified on the basis of websites visited) which we then share with TikTok (so-called “custom audiences”). By using the TikTok pixel, we also want to ensure that our TikTok ads match the potential interest of users and are not a nuisance. Furthermore, the TikTok pixel allows us to track the effectiveness of TikTok ads for statistical and market research purposes by determining whether users have been referred to our website after clicking on a TikTok ad (known as “conversion”).


 Further details about the purpose and scope of data collection, further processing and the use of data by TikTok can be found in TikTok’s privacy policy.


 Legal basis and right to revoke:
 Data processing on this website is based on your consent, pursuant to Art. 6(1)(a) GDPR. You can revoke your consent at any time with effect for the future: open the data protection settings at the bottom left (“shield” icon) and move the slider in the relevant direction.
 

Consent and right to revoke
 This marketing activity is not permitted without the user’s consent. This is why such consent must be included in the Consent Manager on the homepage.
 

Contract for commissioned data processing
 TikTok acts as a processor for trackle (analyses, measurements, etc.). Commissioned data processing within the meaning of data protection law means that a company is commissioned by another company primarily to process personal data (including, for example, external payroll accounting, sending of newsletters or use of Google Analytics). In such cases, a suitable contract must be concluded with the service provider, specifying how it may handle the data it has received from its customer. Most online marketing/tracking companies offer this service to their customers automatically in the customer area.

Google Tag Manager

For the sake of transparency, we must point out that we use Google Tag Manager,   a system that manages JavaScript and HTML tags for the implementation of tracking and analysis tools. This service is provided by Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland.
 
 Google Tag Manager does not collect any personal data itself. Instead, it makes it easier for us to integrate and manage our own tags. Tags are small pieces of code that can be used, for instance, to measure traffic and visitor behaviour, track the impact of online advertising and social media, set up remarketing and audience targeting as well as test and optimise websites. If you have disabled this, your setting will be respected by Google Tag Manager. For further details on Google Tag Manager see:

https://marketingplatform.google.com/about/analytics/tag-manager/use-policy/
 https://support.google.com/tagmanager/?hl=en#topic=3441530
https://safety.google/privacy/privacy-controls/

 

4.4 Advertising

We use marketing cookies to provide our users with advertising based on their interests. We also use these cookies to limit the likelihood of some advertisements being presented and to measure the effectiveness of our advertising. Such information may also be shared with third parties, e.g. ad networks. The legal basis is Art. 6(1)(a) GDPR. 

DoubleClick by Google

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

DoubleClick uses cookies to present ads that are relevant to users, to improve reporting on campaign performance or to prevent users from seeing the same ads multiple times. Google uses a cookie ID to record which ads are shown in which browser, thus preventing the same advert from being shown multiple times. In addition, DoubleClick can use cookie IDs to record so-called conversions that relate to advertisements. This is the case, for instance, 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 access a page that uses DoubleClick and on which the DoubleClick script is allowed, your browser automatically establishes a direct connection with the Google server. The presence of DoubleClick means that Google is notified that you have called up a particular page on our website or that you have clicked on an advertisement of ours. If you are registered with a Google service, Google can associate your account with your visit to our website. 

Please note that this service may send data outside the European Union and the European Economic Area to a country without any adequate level of data protection. If data are sent to the United States, there is a risk that your data may be processed by US authorities for control and monitoring purposes, possibly without giving you any legal recourse. 

You can prevent the collection by this tracking method in a number of ways: (a) Through appropriate settings in your browser: if you do not wish to be shown third-party adverts, you need to suppress third-party cookies. (b) To stop being shown interest-based adverts, you need to disable conversion tracking cookies. To do so, you need to 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. This setting, however, will be deleted if you delete all your other cookies. (d) By disabling interest-related adverts of service providers forming part of the self-regulation campaign About Ads via the linkhttp://www.aboutads.info/choices, however, this setting is deleted when you delete your cookies. (d) Through the permanent deletion of cookies in your browser viahttps://www.google.com/settings/ads/plugin. Please note, however, that if you do so, you may not be able to use all the functions of our website in full.

Further details on DoubleClick by Google can be found at https://www.google.de/doubleclick and https://support.google.com/adsense/answer/2839090, and on Google’s privacy policy in general: 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 revoke:
 Data processing on this website is based on your consent, pursuant to Art. 6(1)(a) GDPR. You can revoke your consent at any time with effect for the future: open the data protection settings at the bottom left (“shield” icon) and move the slider in the relevant direction.

Google Analytics Audiences

Provided that you have given your consent, this website uses Google Analytics Audience (GA Audience), an advertising and conversion tracking service. The relevant 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 as well as on other mobile devices (e.g. smartphones, tablets, etc.) and which allow an analysis of the use of each device. Some of the data are analysed across devices. For this purpose, Google Audience is given access to the cookies created through the use of Google AdWords and Google Analytics. The following data are processed during use.

  • User agent
  • Location information
  • Referral URL
  • IP address 
  • Page depth
  • Length of session
  • Time and date of visit
  • Usage data

Please note that this service may send data outside the European Union and the European Economic Area to a country without any adequate level of data protection. If data are sent to the United States, there is a risk that your data may be processed by US authorities for control and monitoring purposes, possibly without giving you any legal recourse. Below you will find a list of the countries to which data are sent. This may happen for a variety of purposes, e.g. for storage or processing.

Further details about data protection when using GA Audience are available via the following link: https://support.google.com/analytics/answer/2700409?hl=en&ref_topic=2611283

Legal basis and right to revoke
 
Data processing on this website is based on your consent, pursuant to Art. 6(1)(a) GDPR. You can revoke your consent at any time with effect for the future: open the data protection settings at the bottom left (“shield” icon) and move the slider in the relevant direction.

 

Google (re)marketing services

To optimise our website and to operate it economically, we use the marketing and remarketing services (hereinafter: “Google marketing services”) of the provider Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA. The relevant entity for users in the EU/EEA and Switzerland is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland.
 
 Google marketing services enable us to show advertisements on our website in a more targeted manner, so that you only see adverts which are likely to match your interests. If, for example, advertisements for our services are shown to you on other websites, this is called “remarketing”. When you access our website or other sites where Google marketing services are employed, a code is immediately implemented by Google and so-called (re)marketing tags (invisible images or code, so-called “web beacons”) are integrated into the site. They make it possible to save a specific cookie, i.e. a small file, to your device (although similar technologies may be in use instead of cookies).

Cookies can be set by a variety of domains, including by google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com and googleadservices.com. A cookie stores details of the websites you have accessed, what kind of content you are interested in, which offers you have clicked on and also technical details of your browser and operating system, referring websites, the time when you visited and other details of your site use. Furthermore, the cookie contains your IP address; however, as part of Google Analytics we inform you that the IP address has been truncated within an EU Member State or in some other country forming part of the European Economic Area and only in exceptional cases the full IP address sent to a Google server in the USA and truncated there.

The IP address is not linked with any of your data under any other Google services. The above-mentioned details may also be linked by Google with such details from other sources. If you subsequently visit other websites, you may be shown adverts that are specially geared towards your interests.
 
 We apply pseudonymisation when processing your data as part of Google marketing services, i.e. Google does not store or process, for instance, your name or email address, but it processes the relevant data in relation to the cookie within pseudonymised user profiles. The data that are collected by Google marketing services about you as a user are sent to Google and saved to Google servers in the United States.
 
 The Google Marketing Services we use include the online advertising program Google Ads, formerly Google AdWords). In the case of Google Ads, each Ads customer is given a different conversion cookie. This means that cookies cannot be traced via websites of Ads customers. Details obtained through conversion cookies serve the purpose of creating conversion statistics for Ads customers who have opted for conversion tracking. Ads customers are told the total number of users who have clicked on their adverts and who have been redirected to a page carrying a conversion tracking tag. However, they do not receive information that might enable them to identify any users in person.
 
 If data are processed outside the EEA, in countries without data protection at the same level as European standards, we have concluded EU standard contractual clauses with the relevant service provider, establishing a secure level of data protection.
 
 Further details on Google’s use of data for marketing purposes can be found on the summary page: 
https://www.google.com/policies/technologies/ads, and Google’s privacy policy can be accessed at https://www.google.com/policies/privacy.
 
Legal basis and right to revoke:
 Data processing on this website is based on your consent, pursuant to Art. 6(1)(a) GDPR. You can revoke your consent at any time with effect for the future: open the data protection settings at the bottom left (“shield” icon) and move the slider in the relevant direction.

Pinterest conversion tracking:

We use conversion tracking technology from the social media network Pinterest (Pinterest Europe Ltd., Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland) on our website. It means that any of our site visitors who are already interested in our website and our content/offers and who are also Pinterest members can see Pinterest advertising and offers that are of relevance to them. A so-called conversion tracking pixel from Pinterest has been placed on our website for this purpose, and when you visit our website, Pinterest is notified that you have accessed it and which parts of our site you are interested in. If, for instance, you showed interest in our subscriptions on our website, Pinterest may present you with an advertisement for our subscriptions.

You can opt out of the collection of your data for the display of interest-based advertising on Pinterest at any time through the relevant settings in your Pinterest account at https://www.pinterest.com/settings (go to “Settings”, then “Privacy and data”, “Personalisation”, where you need to disable “Use information from our partners to improve which recommendations and ads you see”) or https://help.pinterest.com/en-gb/article/personalization-and-data (where you need to disable the checkbox “Turn off personalisation”).

Further details on data protection at Pinterest Europe Ltd can be found here: https://policy.pinterest.com/en-gb/privacy-policy 

Legal basis and right to revoke:
 Data processing on this website is based on your consent, pursuant to Art. 6(1)(a) GDPR. You can revoke your consent at any time with effect for the future: open the data protection settings at the bottom left (“shield” icon) and move the slider in the relevant direction.

4.5 Use of social plugins and embedded functions

Google YouTube

On our website, we use services from YouTube, a provider of video content from Google LLC. The relevant service provider in the EU is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). This serves to improve our online offering.

However, such an improvement is only possible if such content providers (hereinafter: “third-party providers”) can be recognize the users’ IP addresses. Unless they have the relevant IP address, they cannot send content to the browser of the relevant user. The IP address is therefore necessary in order to display such content. We endeavour to limit ourselves to content whose providers use IP addresses only for the delivery of their content. However, we have no control over whether third-party providers might save IP addresses, for instance, for statistical purposes. In cases where we are aware of such use, we will notify users accordingly. 

Legal basis and right to revoke:
 Data processing on this website is based on your consent, pursuant to Art. 6(1)(a) GDPR. You can revoke your consent at any time with effect for the future: open the data protection settings at the bottom left (“shield” icon) and move the slider in the relevant direction.

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 relevant entity for users in the EU/EEA and Switzerland is Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland.
 reCAPTCHA serves to prevent the misuse of automated entries on web forms and thus to protect the technical systems of the hoster.
 When you call up one of our websites that contains reCAPTCHA, a connection is established to Google servers. A reCAPTCHA cookie is set, and your IP address is sent to Google.
 In addition, reCAPTCHA collects the following data via “fingerprinting”:

– Browser plugins used
 – Cookies set by Google in the last 6 months
 – Number of mouse clicks and touches performed on this screen
 – CSS information for the page you are viewing
 – JavaScript objects
 – Date
 – Browser language

You can prevent the storage of cookies and fingerprinting by choosing the relevant technical settings in your browser software; however, please note that if you do this, you may not be able to use all the functions of this website.
 If data are processed outside the EEA, in countries without data protection at the same level as European standards, we have concluded EU standard contractual clauses with the relevant service provider, establishing a secure level of data protection.

You can find Google’s privacy policy and terms of use here: https://www.google.com/policies/privacy/ and here: https://policies.google.com/terms.   

Legal basis and right to revoke:
 Data processing on this website is based on your consent, pursuant to Art. 6(1)(a) GDPR. You can revoke your consent at any time with effect for the future: open the data protection settings at the bottom left (“shield” icon) and move the slider in the relevant direction.

5. Job applications

You can apply to our company online by email via our application portal at https://trackle.de/ueber-uns/jobs/. However, please remember that unencrypted emails will not be protected when they are sent.

Your details will be used for the processing of your application and to help us decide whether to employ you. The legal basis is section 26(1) in conjunction with (8) sentence 2 of the German Data Protection Act (Bundesdatenschutzgesetz, BDSG). Furthermore, your personal data may be processed where this is required for any defence against legally asserted claims towards us arising from the application process. The legal basis is Art. 6(1)(f) GDPR. The purposes specified here are also the legitimate interest which we have in data processing.

If an employment relationship is established between you and us, we may process the personal data which we have received from you for the purposes of the employment relationship; we may do so in accordance with section 26(1) BDSG and where this is necessary for carrying out or terminating the employment contract or to exercise or satisfy rights and obligations of employees’ representation laid down by law or by collective agreements or other agreements between the employer and staff council.

Your application details will not be processed beyond the use described above.

Your personal data will be erased upon completion of the application process and no later than after 6 months, unless there are other legitimate interests on our part preventing erasure or unless you have given us permission to store your data for longer. Other legitimate interests include, for example, a burden of proof in proceedings under the German General Act on Equal Treatment (Allgemeines Gleichbehandlungsgesetz, AGG).

6. Registrations on this website 

Our website enables you to register and set up a customer account.
 We collect and store the following data from you for registration purposes:

  • First name
  • Surname
  • Email
  • Password


 We use a double opt-in procedure for registration, i.e. your registration is not complete until you have confirmed your registration by clicking on the link in a confirmation email sent to you for this purpose. If we do not receive your confirmation to this effect, your registration will be automatically deleted from our database. Once you have registered, you will receive personal, password-protected access and can view and manage the data you have provided. Although registration is voluntary, it may be a requirement for using some of our services.

We will store any data of yours that are required for contractual fulfilment, including, if necessary, also details of your payment method, until you permanently delete your account. Furthermore, while you make use of your customer/user account, we will store any of the additional data you have provided, unless you delete them at an earlier stage. You can manage and edit all details in the protected customer area.

You can delete your customer account at any time[MM2] . All you need to do is send an email to info@trackle.de. When your account is deleted, all personal data will be erased provided that they are not subject to statutory provisions on retention or Art.17(3) GDPR.

The legal basis for such data processing is Art. 6(1)(a), (b) and (f) GDPR.

7. Newsletter

General information

You can subscribe to our newsletter on our website, which will keep you informed on our latest news, offers and discounts. The legal basis for sending you the relevant newsletter is your consent in accordance with Art. 6(1)(a) GDPR in conjunction with section 7(2) No. 3 of the German Act against Unfair Competition (Gesetz gegen den unlauteren Wettbewerb, UWG) and the legal permit pursuant to section 7(3) UWG.

We use a double opt-in procedure for subscriptions to our newsletters. This means that when you have subscribed, we will send you an email to the email address you provided, asking you to confirm that you wish to receive our newsletter. Unless you confirm your subscription, your details will automatically be deleted after3 days.

The information you share will enable us to address you in person. Once we have received your confirmation, we will store your email address for the purpose of sending you our newsletter until you cancel your subscription. We will also store your current IP address, the date and time of your registration and our confirmation; these details will be stored up to three years after your registration for subscription (period of limitation). The purpose of this procedure is to ensure that we can improve your registration in the event of doubt and investigate any fraudulent use of your personal data. The legal basis for logging your registration is our legitimate interest pursuant to Art. 6(1)(f) GDPR in proving prior consent – see also Art. 7(1) GDPR.

You can revoke your consent to the receipt of our newsletter and unsubscribe at any time. To cancel your subscription, you will need to click on the relevant link provided in each newsletter email.

Mailchimp

We use Mailchimp as a marketing platform, a service provided by Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.
Mailchimp is a service that allows, among other things, the organisation and analysis of the sending of newsletters. Any data that are required for the purpose of receiving the newsletter, such as your email address, are stored on Mailchimp’s servers in the United States. Mailchimp allows us to analyse our newsletter campaigns. If, for example, you open an email sent via Mailchimp, a file within that email (a so-called web beacon) links to the Mailchimp servers in the United States to determine whether a newsletter email has been opened and, where applicable, which links have been clicked. Mailchimp also records device-specific details, such as the date and time of access, IP address, browser type and your operating system. These details cannot be linked to you as the newsletter recipient. They only serve the purpose of analysing newsletter campaigns. The results of such analyses can be used to improve the tailoring of future newsletters to suit the interests of the recipients. Further details can be found in Mailchimp’s Standard Terms of Use, at https://mailchimp.com/legal/terms/.

Processing in the United States is based on standard contractual clauses (https://mailchimp.com/legal/data-processing-addendum) supplemented by special security provisions (https://mailchimp.com/help/Mailchimp-european-data-transfers/).

The data you give us for the purpose of receiving our newsletter will be stored until you unsubscribe; once you have done so, they will be erased from our servers and also from the Mailchimp servers. This does not affect, however, any data we have stored for other purposes (e.g. email addresses for the membership area).
 If you do not want your details to be analysed by Mailchimp, you will need to unsubscribe the newsletter. We provide a suitable link for this purpose whenever we send you a newsletter message. You can revoke your consent at any time by unsubscribing the newsletter. However, your cancellation will not affect the legitimacy of any data processing that has already taken place.

8. E-book

You can receive an e-book through our website. To send you the e-book, we will need your email address and name (optional). You will then receive the e-book as well as any latest news, offers and discounts at your email address. 

We use a double opt-in procedure for subscriptions to our newsletters. This means that when you have subscribed, we will send you an email to the email address you provided, asking you to confirm that you wish to receive our newsletter. Unless you confirm your subscription, your details will automatically be deleted after3 days.

The information you share will enable us to address you in person. Once we have received your confirmation, we will store your email address for the purpose of sending you our newsletter until you cancel your subscription. We will also store your current IP address, the date and time of your registration and our confirmation; these details will be stored up to three years after your registration for subscription (period of limitation). The purpose of this procedure is to ensure that we can improve your registration in the event of doubt and investigate any fraudulent use of your personal data. The legal basis for logging your registration is our legitimate interest pursuant to Art. 6(1)(f) GDPR in proving prior consent – see also Art. 7(1) GDPR.

The legal basis for sending you the e-book and the relevant newsletter is your consent in accordance with Art. 6(1)(a) GDPR in conjunction with section 7(2) No. 3 of the German Act against Unfair Competition (Gesetz gegen den unlauteren Wettbewerb, UWG) and the legal permit pursuant to section 7(3) UWG.

You can revoke your consent to the receipt of our newsletter and unsubscribe at any time. To cancel your subscription, you will need to click on the relevant link provided in each newsletter email.

9. Data transfer and recipients or categories of recipients

None of your data are transferred to third parties, unless we are legally obliged to do so or the transfer of data is necessary for the execution of the contractual relationship or you have previously expressly agreed to the transfer of your data. 

External service providers and partner companies such as online payment providers or the shipping company commissioned to deliver your order only receive your data if this is necessary to process your order. In such cases, however, the scope of the transmitted data is limited to the necessary minimum. If our service providers come into contact with your personal data and process them for us as instructed, we ensure as part of our commissioned data processing duties pursuant to Art. 28 GDPR that those service providers also comply with data protection legislation in the same way. Please also note the privacy policies of each service provider. Any content of third-party services is the responsibility of the relevant service provider, although we check their services for compliance with legal requirements to the extent that this is reasonable.

PayPal
 
On our website we offer, among other things, payment via PayPal. This payment service is provided by 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 such data processing is Art. 6(1)(b) GDPR.

Klarna
 
On our website we offer, among other things, payment via Klarna. This payment service is provided by Klarna Bank AB (publ.), Sveavägen 46, 11134 Stockholm, Sweden (hereinafter: “Klarna”). If you select payment via Klarna, the payment data you enter will be transmitted to Klarna. The legal basis for such data processing is Art. 6(1)(b) GDPR.

Stripe
 
On our website we offer, among other things, payment via Stripe. This payment service is provided by Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA. If you select payment via Stripe, the payment data you enter will be transmitted to Stripe. The legal basis for such data processing is Art. 6(1)(b) GDPR. We have concluded a data processing agreement with Stripe whereby Stripe is under an obligation to protect our customers’ data and not to disclose them to third parties. This contract can be viewed via the following link: https://stripe.com/dpa/legal

Bold Subscriptions
 
When you take out a trackle subscription on our website, we use Bold Subscriptions to map the subscription function.  This service is provided by Bold Innovation Group Ltd, 50 Fultz Boulevard, Winnipeg, MB, R3Y 0L6, Canada.
 If you select the trackleGo product and thus recurring payments, the payment data you enter will be sent to Bold Subscriptions. The legal basis for such data processing is Art. 6(1)(b) GDPR. We have concluded a data processing agreement with Bold Innovation whereby Bold Innovation is under an obligation to protect our customers’ data and not to disclose them to third parties. This contract can be viewed via the following link: 
https://boldcommerce.com/legal#gdpr-compliance

Shopify
 
This website uses the services of Shopify for the processing of shopping transactions. The service is provided by Shopify International Limited, Victoria Buildings, 2nd floor, 1–2 Haddington Road, Dublin 4, D04 XN32, Ireland, hereinafter: “Shopify”.
 Shopify is a service that allows, among other things, the development and management of an online shop system. When you enter data for the purpose of executing the purchase and shipping contract (e.g. email address), these data will be stored on Shopify servers, which may also be located outside the EU.
 Shopify’s data privacy policy can be viewed at 
https://www.shopify.com/legal/privacy and at https://www.shopify.com/legal/dpa. Data collected by Shopify for the purpose of contractual fulfilment will only be passed on to third parties where this is necessary for contractual performance, in particular in the following cases:

  • Address data to shipping companies for the purpose of delivery
  • Payment data to banks for the processing of payments
  • Payment data to collection companies if claims are assigned

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

Freshdesk Support
 
If you contact our support team by email, info@trackle.de, or via Facebook Messenger, your requests will be redirected to our helpdesk tool. This service is provided by Freshworks INC, San Francisco, USA, 1250 Bayhill Drive, Suite 315, San Bruno, CA 94066, USA.

If you send us a support request either by email or via Facebook Messenger and your request includes data (e.g. your name or email address), then those data will be saved to Freshdesk servers, which may also be located outside the EU.

The Freshdesk privacy policy can be viewed here and here (Privacy Notice and Data Security Addendum). You can revoke your data processing consent at any time. However, revocation will not impact the effectiveness of any data processing that took place in the past.

Legal basis and right to revoke:
 Data processing on this website is based on your consent, pursuant to Art. 6(1)(a) GDPR. You can revoke your consent at any time with effect for the future: open the data protection settings at the bottom left (“shield” icon) and move the slider in the relevant direction.

Pure Chat live chat
 
In order to operate a live chat system and to answer live enquiries on this website, any chat content you enter will be collected and stored for the duration of each chat. The chat tool is provided by Pure Chat Inc., 13835 N Northsight Blvd Suite 205, Scottsdale, AZ 85260, USA.
 The chat function provides Pure Chat with details of your device, IP address, browser type, browser settings and cookie information. These cookies allow the identification of the web browser of each site visitor, so that the system can differentiate between different users of the chat function of our website.
 If you wish to prevent the storage of cookies, you can set your web browser so that it cannot store cookies on your computer in the future or so that it deletes any cookies it has stored up to that point. However, if you disable all cookies, you may no longer be able to use the chat function on our website.

Click here for further details of Pure Chat’s privacy policy.

Legal basis and right to revoke:
 Data processing on this website is based on your consent, pursuant to Art. 6(1)(a) GDPR. You can revoke your consent at any time with effect for the future: open the data protection settings at the bottom left (“shield” icon) and move the slider in the relevant direction.

JotForm
 
If you contact our support team by email, info@trackle.de, or via Facebook Messenger, your technical queries will be processed with the help of questionnaires. This service is provided by JotForm Inc., San Francisco, 111 Pine Street, Suite 1815, CA 94111, USA.
 If you enter and transmit data via the questionnaire for the purpose of a support request (e.g. your name or email address), then those data will be saved to JotForm servers, which may also be located outside the EU.
 We have concluded a data processing agreement with JotForm whereby JotForm is under an obligation to protect our customers’ data and not to disclose them to third parties. Further details of JotForm’s data protection can be viewed 
here.

Legal basis and right to revoke:
 Data processing on this website is based on your consent, pursuant to Art. 6(1)(a) GDPR. You can revoke your consent at any time with effect for the future: open the data protection settings at the bottom left (“shield” icon) and move the slider in the relevant direction.

10. Retention period

Any personal data we collect will be erased when the purpose of processing no longer applies or when the relevant statutory retention periods expire.

 

11. Information about the data subject’s duties of disclosure

When you use our website, you are under no statutory or contractual obligation to disclose information.

 

12. Existence of an automated decision-taking process including profiling

There is no automated decision-taking process, incl. profiling, under Art. 22 GDPR.

 

13. Your rights

You have the following rights towards us regarding your personal data:

13.1. General rights

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

13.2. Rights concerning data processing based on legitimate interest

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 your personal data where data are processed on the basis of Art. 6(1)(e) GDPR (data processing in the public interest) or Art 6(1)(f) (data processing for the purposes of legitimate interests); this also applies to profiling based on this provision. If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for processing which override your interests, rights or freedoms, or unless processing serves to assert, exercise or defend legal claims.

13.3. Rights in relation to direct marketing

If we process your personal data for the purpose of direct marketing, you have the right at any time – under Art. 21(2) GDPR – to object to the processing of your personal data for the purpose of such marketing; this also applies to profiling if it is associated with such direct marketing.

If you object to processing for direct marketing purposes, we will no longer process your personal data for such purposes.

13.4. Right to lodge a complaint with a supervisory authority

You are also entitled to lodge a complaint with a relevant data protection authority about our processing of your personal data.

 

14. Contacting us by email or via a contact form

When you contact us by email or via a contact form, the data you provide (your email address and name) will be stored by us with a view to answering your questions. In cases where our contact form requests input that is not necessary for the purpose of contacting us, we have marked those questions as optional in all instances. We use such details to clarify your enquiry and to improve the processing of your request. You will expressly share such details with us on the basis of your voluntary consent – see  Art. 6(1)(a) GDPR. Where those details concern channels of communication (e.g. email address, phone number), you also declare you consent that we may contact you via the relevant channel, so that we can respond to your request. You may, of course, revoke your consent at any time with effect for the future.

In such a case, we will erase the available data once their storage is no longer required, or we will restrict processing of those data if they are subject to statutory provisions on retention.

15. Data security

We have taken extensive technical and operational precautions to protect your data from accidental or intentional manipulation, loss, destruction or access by unauthorised persons. Our security procedures are regularly reviewed and adapted to technological progress.

16. Data transfer and intended data transfer to a third country or to an international organisation

None of your data are transferred to third parties, unless we are legally obliged to do so or the transfer of data is necessary for the execution of the contractual relationship or you have previously expressly agreed to the transfer of your data.

 

 
 
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