This is Diceray.com’s Privacy Policy. For the purposes of
this Privacy Policy, ' Diceray.com' and any references to Dice Ray Technology
', 'we', or 'us' shall mean Dice Ray Technology, LLC, a Delaware limited
liability company. Diceray.com respects your privacy and is committed to
protecting your personal data. This Privacy Policy explains how we collect,
use, disclose, and safeguard your information when you visit our website, use
our hosting services, or otherwise interact with us.
Because we serve customers both in the United States and
internationally, including in the European Union, this Privacy Policy is
structured to comply with various privacy laws, including:
The California Consumer Privacy Act (CCPA) and other
applicable US federal and state privacy laws;
The General Data Protection Regulation (GDPR) for users
located in the European Economic Area (EEA), United Kingdom, and Switzerland.
To ensure transparency, this Privacy Policy is divided into
jurisdiction-specific sections. Please refer to the section applicable to your
place of residence:
Section A – United States Residents: Contains
information relevant under US laws, including the CCPA.
Section B – EU/EEA, UK, and Swiss Residents: Contains
information required under the GDPR and related legislation.
SECTION A
Contains information relevant under US laws, including
the CCPA.
1.
Parties
This Privacy Policy discusses the ways in which we collect,
use, maintain and disclose information collected by us from our customers,
visitors to our websites, and, in some cases, visitors to our customer’s
websites (“Users”). Capitalized terms used but not defined in this policy have
the meaning given to them in our Terms of Services, located at: Terms of Service.
2.
Purpose
The nature of internet business requires us to collect
information from Users. While this policy is entitled a “privacy policy,” it
discusses all of the ways in which we use information collected directly or
indirectly from our Users, including personally identifiable information
gathered by us (“PI”) and other anonymous information (“AI”) (collectively,
“Information”). Information transmitted, collected, processed or which is
otherwise provided to us by Users is not necessarily considered by us to be
private. Please review this Privacy Policy carefully to determine how we treat
this information.
3.
Acceptance of the Policy
You accept this Privacy Policy by using our website (located
at: www.diceray.com, referred to herein as the “Site”), placing an order
for Services (as defined in the Terms of Service) with us or joining our email
list.
4.
Changes to Policy
If we make a change to this Policy that, in our sole
discretion, is material, we will notify you by email, post a notice of such
changes on the Site or flag our Privacy Policy on the Site as updated. You
agree to our use of electronic communications with you for purposes of this
Policy. If you do not agree to the changes to this Policy, we will continue to
maintain and use PI previously collected in accordance with the Policy in force
as of that date.
5.
Information that we Collect; Use of
Information.
a. Generally. We may use PI as
required or permitted by law, including in response to service of legal process
(court order, summons, subpoena, and the like). We may disclose PI to law
enforcement or regulatory authorities as part of an investigation into activity
at the Site (such as a suspected breach). We shall use commercially reasonable
measures to limit disclosure and use of such PI. We may use PI in connection
with the establishment or defense of legal claims. Any information sent to us
will not be deemed to be confidential, and may be shared by us with any other
individual or entity, regardless of whether you mark it confidential.
b. Information contained in your
customer record. Users who are our customers provide us with their name,
address, phone number, user name, credit/debit card or bank information and
other personally identifiable or confidential information and other information
we require to provide Service to them. We may also acquire information about
customers from third parties such as credit reporting agencies, as well as
collect information about our customers’ use of the Services. This information
may be linked to the information provided to us by our customers to create an
administrative record and is referred to as “Registration and Billing
Information”.
c. User inquiries. Users who
contact us with questions may be required to give us additional information to
assist us in resolving their questions, or to assist us in our business (“User
Inquiry Information”).
d. Anonymous Information. We
collect anonymous information (AI) regarding your use of the Site, such as
computer-related information (browser type you used, your Internet Protocol
address, last URL visited, and the date and time of day of your login). We send
a “cookie” or “pixel tag” to your computer which contains an identification
number that is unique to the computer you are using. You may decline to provide
such information to us and/or refuse cookies in your browser, although some of
our features or services may not function properly as a result, and some
services may not be available. We use this information to enhance the
experience of using the Site, to tailor our Site to its visitors, to understand
how our Site is used, to investigate and verify proper conduct at the Site, and
to monitor the security and integrity of the Site.
e. Third Party Agents – Access to
and Use of PI. We may contract with third parties to assist us in our business,
including providing certain Services, hosting of the Site, hosting of data
(including PI and AI), promotional services, authorization and processing of
payments, fulfillment of product orders and processing of returns. Such third
parties shall agree with us in writing to maintain your privacy at least with
the level of protection set forth in this Privacy Policy.
f. Unrelated Third Party Links and
Information. Our Site contains links to other websites or other information and
materials provided by third parties (by way of example, links to third party
social media websites). We do not own or control such other websites or third
parties and are not responsible for the information provided at those websites
or in such materials. We do not control, and are not responsible for, their
privacy policies or the information collected at such third party websites.
g. Customer Inquiries. We use
customer inquiry information to identify Users personally. It is used
throughout our business to provide services to Users, and to market new
products and services to Users. Customer inquiry information is shared with
third parties in the following circumstances: to identify and fix problems with
the Services when we are not capable of doing so ourselves. Providers of third
party products may require us to provide them with customer inquiry
information. When Customer Inquiry Information is shared with third parties in
these circumstances, the third parties are required to keep this information
confidential. Further, entities that provide products to us may have privacy
policies that differ from ours. We will be happy to provide you with the names
of those businesses that provide Services through us to you, and links to their
privacy policies, on your request.
h. Information about Children. We
do not knowingly collect personally identifiable information from children
under the age of 13. If a parent or guardian believes that their child under
the age of 13 has provided us with personally identifiable information, they
should contact us. Other than in response to a lawful request by public
authorities, Diceray.com only shares your personal information with third
parties who are acting as Diceray.com’s agents or subcontractors and only uses
your personal information for the purposes stated herein (or other purposes
stated at the time of collection). Should Diceray.com’s practices with respect
to processing or use of personal information change, Diceray.com will provide
you with notice (either by means of an amendment to this Privacy Policy or
otherwise) and provide you with an opportunity to opt out.
6.
Your Access to and Ability to Change
PI
You may request access, updating and corrections of
inaccuracies in your PI by contacting us as set out below. For security
purposes, we may request PI from you in connection with such access. You may
also: (i) modify your information through your control panel in your account,
or (ii) ask that information regarding your inquiries be deleted by contacting
us through our contact form at https://diceray.com/contact/.
7.
Deleting and Retention of PI
You may request that we delete your PI, and we shall attempt
to accommodate such requests. However, we may retain and use PI for such
periods of time as required or permitted by law or best business practices.
8.
Security
We have implemented technical, physical and administrative
safeguards designed to protect PI against loss and against unauthorized access,
use, and disclosure. Passwords are stored on our server in encrypted form. We
have personal information retention processes designed to retain personal
information as necessary for the purposes stated above or to otherwise meet
legal requirements. Unless this Privacy Policy states otherwise, our employees
are required to keep the information set out here confidential.
California Privacy Rights
If you are a resident of the State of California and you
have provided your personal information to us, you have the right to request a
list of all third parties to which we have disclosed your personal information
for direct marketing purposes. If you exercise your right to submit such a
request to us, we will send you the following information:
- The
categories of information we have disclosed to any third party for any
third party’s direct marketing purposes during the preceding year; and
- The
names and addresses of third parties that received such information, or if
the nature of their business cannot be determined from the name, then
examples of the products or services marketed.
You may make such a request by contacting us in writing by
postal mail or via the email address provided at the end of this Privacy Notice
under the heading “Contact Information” with a preference on how our response
to your request should be sent.
California law also requires that we disclose how we respond
to “do-not-track requests” from our users. At this time, we do not currently
respond to “do-not-track” requests from our users’ browsers.
HIPAA (The Health Insurance Portability And
Accountability Act)
HIPPA does not apply to the service we provide. We are not a
“Covered Entity” or a “Business Associate” as those terms are defined by HIPAA.
As HIPAA does not apply, our service does not need to and may not meet the
standards set forth in HIPAA. Accordingly, using the service should not be used
submit, store, or disclose information that would be subject to HIPAA in a
manner that is compliant with HIPAA and its requirements.
Testimonials
Pursuant to our Terms of Service, you may provide us with an
Endorsement in connection with your use of the Services. We may, at our
discretion, use the Endorsement to promote our Services as specified in our
Terms of Service. In connection with our use of your Endorsement, you hereby
agree that we may use your first name, last initial, home state, voice or
likeness, and/or contact information in connection with its publication of the
Endorsement. If, at any time, you want us to stop using your Endorsement,
please contact us using the contact information in Section 18 of our Terms of
Service and we will cease using the Endorsement soon after processing your
request.
Section B
Contains information required under the GDPR and related
legislation.
1.
An overview of data protection
General information
The following information will provide you with an easy to
navigate overview of what will happen with your personal data when you visit
this website. The term “personal data” comprises all data that can be used to
personally identify you. For detailed information about the subject matter of
data protection, please consult our Data Protection Declaration, which we have
included beneath this copy.
Data recording on this website
Who is the responsible party for the recording of data on
this website (i.e., the “controller”)?
The data on this website is processed by the operator of the
website, whose contact information is available under section “Information
about the responsible party (referred to as the “controller” in the GDPR)” in
this Privacy Policy.
How do we record your data?
We collect your data as a result of your sharing of your
data with us. This may, for instance be information you enter into our contact
form.
Other data shall be recorded by our IT systems automatically
or after you consent to its recording during your website visit. This data
comprises primarily technical information (e.g., web browser, operating system,
or time the site was accessed). This information is recorded automatically when
you access this website.
What are the purposes we use your data for?
A portion of the information is generated to guarantee the
error free provision of the website. Other data may be used to analyze your
user patterns. If contracts can be concluded or initiated via the website, the
transmitted data will also be processed for contract offers, orders or other
order enquiries.
What rights do you have as far as your information is
concerned?
You have the right to receive information about the source,
recipients, and purposes of your archived personal data at any time without
having to pay a fee for such disclosures. You also have the right to demand
that your data are rectified or eradicated. If you have consented to data
processing, you have the option to revoke this consent at any time, which shall
affect all future data processing. Moreover, you have the right to demand that
the processing of your data be restricted under certain circumstances.
Furthermore, you have the right to log a complaint with the competent
supervising agency.
Please do not hesitate to contact us at any time if you have
questions about this or any other data protection related issues.
Analysis tools and tools provided by third parties
There is a possibility that your browsing patterns will be
statistically analyzed when your visit this website. Such analyses are
performed primarily with what we refer to as analysis programs.
For detailed information about these analysis programs
please consult our Data Protection Declaration below.
2.
Hosting and Content Delivery Networks
(CDN)
Cloudflare
We use the “Cloudflare” service provided by Cloudflare Inc.,
101 Townsend St., San Francisco, CA 94107, USA. (hereinafter referred to as
“Cloudflare”).
Cloudflare offers a content delivery network with DNS that
is available worldwide. As a result, the information transfer that occurs
between your browser and our website is technically routed via Cloudflare’s
network. This enables Cloudflare to analyze data transactions between your
browser and our website and to work as a filter between our servers and
potentially malicious data traffic from the Internet. In this context,
Cloudflare may also use cookies or other technologies deployed to recognize
Internet users, which shall, however, only be used for the herein described
purpose.
The use of Cloudflare is based on our legitimate interest in
a provision of our website offerings that is as error free and secure as
possible (Art. 6(1)(f) GDPR).
Data transmission to the US is based on the Standard
Contractual Clauses (SCC) of the European Commission. Details and further
information on security and data protection at Cloudflare can be found here:
The company is certified in accordance with the “EU-US Data
Privacy Framework” (DPF). The DPF is an agreement between the European Union
and the US, which is intended to ensure compliance with European data
protection standards for data processing in the US. Every company certified
under the DPF is obliged to comply with these data protection standards. For
more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5666.
Data processing
We have concluded a data processing agreement (DPA) for the
use of the above-mentioned service. This is a contract mandated by data privacy
laws that guarantees that they process personal data of our website visitors
only based on our instructions and in compliance with the GDPR.
3.
General information and mandatory
information
Data protection
The operators of this website and its pages take the
protection of your personal data very seriously. Hence, we handle your personal
data as confidential information and in compliance with the statutory data
protection regulations and this Data Protection Declaration.
Whenever you use this website, a variety of personal
information will be collected. Personal data comprises data that can be used to
personally identify you. This Data Protection Declaration explains which data
we collect as well as the purposes we use this data for. It also explains how,
and for which purpose the information is collected.
We herewith advise you that the transmission of data via the
Internet (i.e., through e-mail communications) may be prone to security gaps.
It is not possible to completely protect data against third-party access.
Information about the responsible party (referred to as
the “controller” in the GDPR)
The data processing controller on this website is:
Dice Ray Technology
License No: 1261164
Dubai, United Arab Emirate
diceray.com | info@diceray.com |
+971 55 825 3600
The controller is the natural person or legal entity that
single-handedly or jointly with others makes decisions as to the purposes of
and resources for the processing of personal data (e.g., names, e-mail
addresses, etc.).
Storage duration
Unless a more specific storage period has been specified in
this privacy policy, your personal data will remain with us until the purpose
for which it was collected no longer applies. If you assert a justified request
for deletion or revoke your consent to data processing, your data will be
deleted, unless we have other legally permissible reasons for storing your
personal data (e.g., tax or commercial law retention periods); in the latter
case, the deletion will take place after these reasons cease to apply.
General information on the legal basis for the data
processing on this website
If you have consented to data processing, we process your
personal data on the basis of Art. 6(1)(a) GDPR or Art. 9 (2)(a) GDPR, if
special categories of data are processed according to Art. 9 (1) DSGVO. In the
case of explicit consent to the transfer of personal data to third countries,
the data processing is also based on Art. 49 (1)(a) GDPR. If you have consented
to the storage of cookies or to the access to information in your end device
(e.g., via device fingerprinting), the data processing is additionally based on
§ 25 (1) TDDDG. The consent can be revoked at any time. If your data is
required for the fulfillment of a contract or for the implementation of
pre-contractual measures, we process your data on the basis of Art. 6(1)(b)
GDPR. Furthermore, if your data is required for the fulfillment of a legal
obligation, we process it on the basis of Art. 6(1)(c) GDPR. Furthermore, the
data processing may be carried out on the basis of our legitimate interest
according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each
individual case is provided in the following paragraphs of this privacy policy.
Information on the data transfer to third-party countries
that are not secure under data protection law and the transfer to US companies
that are not DPF-certified
We use, among other technologies, tools from companies
located in third-party countries that are not safe under data protection law,
as well as US tools whose providers are not certified under the EU-US Data
Privacy Framework (DPF). If these tools are enabled, your personal data may be
transferred to and processed in these countries. We would like you to note that
no level of data protection comparable to that in the EU can be guaranteed in
third countries that are insecure in terms of data protection law.
We would like to point out that the US, as a secure
third-party country, generally has a level of data protection comparable to
that of the EU. Data transfer to the US is therefore permitted if the recipient
is certified under the “EU-US Data Privacy Framework” (DPF) or has appropriate
additional assurances. Information on transfers to third-party countries,
including the data recipients, can be found in this Privacy Policy.
Recipients of personal data
In the scope of our business activities, we cooperate with
various external parties. In some cases, this also requires the transfer of
personal data to these external parties. We only disclose personal data to
external parties if this is required as part of the fulfillment of a contract,
if we are legally obligated to do so (e.g., disclosure of data to tax
authorities), if we have a legitimate interest in the disclosure pursuant to
Art. 6 (1)(f) GDPR, or if another legal basis permits the disclosure of this
data. When using processors, we only disclose personal data of our customers on
the basis of a valid contract on data processing. In the case of joint
processing, a joint processing agreement is concluded.
Revocation of your consent to the processing of data
A wide range of data processing transactions are possible
only subject to your express consent. You can also revoke at any time any
consent you have already given us. This shall be without prejudice to the
lawfulness of any data collection that occurred prior to your revocation.
Right to object to the collection of data in special
cases; right to object to direct advertising (Art. 21 GDPR)
IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART.
6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING
OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS
ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL
BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA
PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR
AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING
PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR
INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE
CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO
ART. 21(1) GDPR).
IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE
IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR
AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS
ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT
ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE
USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).
Right to log a complaint with the competent supervisory
agency
In the event of violations of the GDPR, data subjects are
entitled to log a complaint with a supervisory agency, in particular in the
member state where they usually maintain their domicile, place of work or at
the place where the alleged violation occurred. The right to log a complaint is
in effect regardless of any other administrative or court proceedings available
as legal recourses.
Right to data portability
You have the right to have data that we process
automatically on the basis of your consent or in fulfillment of a contract
handed over to you or to a third party in a common, machine-readable format. If
you should demand the direct transfer of the data to another controller, this
will be done only if it is technically feasible.
Information about, rectification and eradication of data
Within the scope of the applicable statutory provisions, you
have the right to demand information about your archived personal data, their
source and recipients as well as the purpose of the processing of your data at
any time. You may also have a right to have your data rectified or eradicated.
If you have questions about this subject matter or any other questions about
personal data, please do not hesitate to contact us at any time.
Right to demand processing restrictions
You have the right to demand the imposition of restrictions
as far as the processing of your personal data is concerned. To do so, you may
contact us at any time. The right to demand restriction of processing applies
in the following cases:
In the event that you should dispute the correctness of your
data archived by us, we will usually need some time to verify this claim.
During the time that this investigation is ongoing, you have the right to
demand that we restrict the processing of your personal data.
If the processing of your personal data was/is conducted in
an unlawful manner, you have the option to demand the restriction of the
processing of your data instead of demanding the eradication of this data.
If we do not need your personal data any longer and you need
it to exercise, defend or claim legal entitlements, you have the right to
demand the restriction of the processing of your personal data instead of its
eradication.
If you have raised an objection pursuant to Art. 21(1) GDPR,
your rights and our rights will have to be weighed against each other. As long
as it has not been determined whose interests prevail, you have the right to
demand a restriction of the processing of your personal data.
If you have restricted the processing of your personal data,
these data – with the exception of their archiving – may be processed only
subject to your consent or to claim, exercise or defend legal entitlements or
to protect the rights of other natural persons or legal entities or for
important public interest reasons cited by the European Union or a member state
of the EU.
SSL and/or TLS encryption
For security reasons and to protect the transmission of
confidential content, such as purchase orders or inquiries you submit to us as
the website operator, this website uses either an SSL or a TLS encryption
program. You can recognize an encrypted connection by checking whether the
address line of the browser switches from “http://” to “https://” and also by
the appearance of the lock icon in the browser line.
If the SSL or TLS encryption is activated, data you transmit
to us cannot be read by third parties.
Encrypted payment transactions on this website
If you are under an obligation to share your payment
information (e.g. account number if you give us the authority to debit your
bank account) with us after you have entered into a fee-based contract with us,
this information is required to process payments.
Payment transactions using common modes of paying
(Visa/MasterCard, debit to your bank account) are processed exclusively via
encrypted SSL or TLS connections. You can recognize an encrypted connection by
checking whether the address line of the browser switches from “http://” to
“https://” and also by the appearance of the lock icon in the browser line.
If the communication with us is encrypted, third parties
will not be able to read the payment information you share with us.
4.
Recording of data on this website
Cookies
Our websites and pages use what the industry refers to as
“cookies.” Cookies are small data packages that do not cause any damage to your
device. They are either stored temporarily for the duration of a session
(session cookies) or they are permanently archived on your device (permanent
cookies). Session cookies are automatically deleted once you terminate your
visit. Permanent cookies remain archived on your device until you actively
delete them, or they are automatically eradicated by your web browser.
Cookies can be issued by us (first-party cookies) or by
third-party companies (so-called third-party cookies). Third-party cookies
enable the integration of certain services of third-party companies into
websites (e.g., cookies for handling payment services).
Cookies have a variety of functions. Many cookies are
technically essential since certain website functions would not work in the
absence of these cookies (e.g., the shopping cart function or the display of
videos). Other cookies may be used to analyze user behavior or for promotional
purposes.
Cookies, which are required for the performance of
electronic communication transactions, for the provision of certain functions
you want to use (e.g., for the shopping cart function) or those that are
necessary for the optimization (required cookies) of the website (e.g., cookies
that provide measurable insights into the web audience), shall be stored on the
basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The
operator of the website has a legitimate interest in the storage of required cookies
to ensure the technically error-free and optimized provision of the operator’s
services. If your consent to the storage of the cookies and similar recognition
technologies has been requested, the processing occurs exclusively on the basis
of the consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TDDDG); this consent
may be revoked at any time.
You have the option to set up your browser in such a manner
that you will be notified any time cookies are placed and to permit the
acceptance of cookies only in specific cases. You may also exclude the
acceptance of cookies in certain cases or in general or activate the
delete-function for the automatic eradication of cookies when the browser
closes. If cookies are deactivated, the functions of this website may be
limited.
Which cookies and services are used on this website can be
found in this privacy policy.
Consent with Cookiebot
Our website uses consent technology from Cookiebot to obtain
your consent to the storage of certain cookies on your end device or for the
use of certain technologies and to document this in a data protection-compliant
manner. The provider of this technology is Cybot A/S, Havnegade 39, 1058
Copenhagen, Denmark (hereinafter “Cookiebot”).
When you enter our website, a connection is established with
the Cookiebot servers to obtain your consent and provide you with other
explanations regarding the use of cookies. Cookiebot will then store a cookie
in your browser to identify the consent you have given or its revocation. The
data collected in this way is stored until you request us to delete it, delete
the Cookiebot cookie itself or the purpose for which the data is stored no
longer applies. Mandatory legal storage obligations remain unaffected.
Cookiebot is used to obtain the legally required consent for
the use of cookies. The legal basis for this is Art. 6(1)(c) GDPR.
Data processing
We have concluded a data processing agreement (DPA) for the
use of the above-mentioned service. This is a contract mandated by data privacy
laws that guarantees that they process personal data of our website visitors
only based on our instructions and in compliance with the GDPR.
Server log files
The provider of this website and its pages automatically
collects and stores information in so-called server log files, which your
browser communicates to us automatically. The information comprises:
The type and version of browser used
The used operating system
Referrer URL
The hostname of the accessing computer
The time of the server inquiry
The IP address
This data is not merged with other data sources.
This data is recorded on the basis of Art. 6(1)(f) GDPR. The
operator of the website has a legitimate interest in the technically error free
depiction and the optimization of the operator’s website. In order to achieve
this, server log files must be recorded.
Request by e-mail, telephone, or fax
If you contact us by e-mail, telephone or fax, your request,
including all resulting personal data (name, request) will be stored and
processed by us for the purpose of processing your request. We do not pass
these data on without your consent.
These data are processed on the basis of Art. 6(1)(b) GDPR
if your inquiry is related to the fulfillment of a contract or is required for
the performance of pre-contractual measures. In all other cases, the data are
processed on the basis of our legitimate interest in the effective handling of
inquiries submitted to us (Art. 6(1)(f) GDPR) or on the basis of your consent
(Art. 6(1)(a) GDPR) if it has been obtained; the consent can be revoked at any
time.
The data sent by you to us via contact requests remain with
us until you request us to delete, revoke your consent to the storage or the
purpose for the data storage lapses (e.g. after completion of your request).
Mandatory statutory provisions - in particular statutory retention periods -
remain unaffected.
Pipedrive
We use Pipedrive to manage customer data. The provider is
Pipedrive GmbH, Mustamäe tee 3a, 10615 Tallinn, Estonia (hereinafter
“Pipedrive”).
Pipedrive is a CRM system and enables us, among other
things, to manage existing and potential customers and customer contacts and to
organize sales and communication processes. The use of the CRM system also
enables us to analyze our customer-related processes. The customer data is
stored on Pipedrive’s servers.
Details on the functions of Pipedrive can be found
here: https://www.pipedrive.com/.
Pipedrive is used on the basis of Art. 6(1)(f) GDPR. The
website operator has a legitimate interest in the most efficient customer
management and customer communication possible. If a corresponding consent has
been requested, the processing is carried out exclusively on the basis of Art.
6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent includes the storage of
cookies or access to information in the user’s terminal device (e.g. device
fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any
time.
Details can be found in Pipedrive’s privacy policy: https://www.pipedrive.com/privacy.
Data processing
We have concluded a data processing agreement (DPA) for the
use of the above-mentioned service. This is a contract mandated by data privacy
laws that guarantees that they process personal data of our website visitors
only based on our instructions and in compliance with the GDPR.
Registration on this website
You have the option to register on this website to be able
to use additional website functions. We shall use the data you enter only for
the purpose of using the respective offer or service you have registered for.
The required information we request at the time of registration must be entered
in full. Otherwise, we shall reject the registration.
To notify you of any important changes to the scope of our
portfolio or in the event of technical modifications, we shall use the e-mail
address provided during the registration process.
The data entered during registration is processed for the
purpose of implementing the user relationship established by the registration
and, if necessary, for the initiation of further contracts (Art. 6 (1)(b)
GDPR).
The data recorded during the registration process shall be
stored by us as long as you are registered on this website. Subsequently, such
data shall be deleted. This shall be without prejudice to mandatory statutory
retention obligations.
5.
Analysis tools and advertising
Google Tag Manager
We use the Google Tag Manager. The provider is Google
Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
The Google Tag Manager is a tool that allows us to integrate
tracking or statistical tools and other technologies on our website. The Google
Tag Manager itself does not create any user profiles, does not store cookies,
and does not carry out any independent analyses. It only manages and runs the
tools integrated via it. However, the Google Tag Manager does collect your IP
address, which may also be transferred to Google’s parent company in the United
States.
The Google Tag Manager is used on the basis of Art. 6(1)(f)
GDPR. The website operator has a legitimate interest in the quick and
uncomplicated integration and administration of various tools on his website.
If appropriate consent has been obtained, the processing is carried out
exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the
consent includes the storage of cookies or the access to information in the
user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG.
This consent can be revoked at any time.
The company is certified in accordance with the “EU-US Data
Privacy Framework” (DPF). The DPF is an agreement between the European Union
and the US, which is intended to ensure compliance with European data
protection standards for data processing in the US. Every company certified
under the DPF is obliged to comply with these data protection standards. For
more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.
Google Analytics
This website uses functions of the web analysis service
Google Analytics. The provider of this service is Google Ireland Limited
(“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics enables the website operator to analyze the
behavior patterns of website visitors. To that end, the website operator
receives a variety of user data, such as pages accessed, time spent on the
page, the utilized operating system and the user’s origin. This data is
summarized in a user-ID and assigned to the respective end device of the
website visitor.
Furthermore, Google Analytics allows us to record your mouse
and scroll movements and clicks, among other things. Google Analytics uses
various modeling approaches to augment the collected data sets and uses machine
learning technologies in data analysis.
Google Analytics uses technologies that make the recognition
of the user for the purpose of analyzing the user behavior patterns (e.g.,
cookies or device fingerprinting). The website use information recorded by
Google is, as a rule transferred to a Google server in the United States, where
it is stored.
The use of these services occurs on the basis of your
consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your
consent at any time.
Data transmission to the US is based on the Standard
Contractual Clauses (SCC) of the European Commission. Details can be found
here: https://privacy.google.com/businesses/controllerterms/mccs/.
The company is certified in accordance with the “EU-US Data
Privacy Framework” (DPF). The DPF is an agreement between the European Union
and the US, which is intended to ensure compliance with European data
protection standards for data processing in the US. Every company certified
under the DPF is obliged to comply with these data protection standards. For
more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.
IP anonymization
Google Analytics IP anonymization is active. As a result,
your IP address will be abbreviated by Google within the member states of the
European Union or in other states that have ratified the Convention on the
European Economic Area prior to its transmission to the United States. The full
IP address will be transmitted to one of Google’s servers in the United States
and abbreviated there only in exceptional cases. On behalf of the operator of
this website, Google shall use this information to analyze your use of this
website to generate reports on website activities and to render other services
to the operator of this website that are related to the use of the website and
the Internet. The IP address transmitted in conjunction with Google Analytics
from your browser shall not be merged with other data in Google’s possession.
Browser plug-in
You can prevent the recording and processing of your data by
Google by downloading and installing the browser plugin available under the
following link: https://tools.google.com/dlpage/gaoptout?hl=en.
For more information about the handling of user data by
Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.
Google Signals
We use Google Signals. Whenever you visit our website,
Google Analytics records, among other things, your location, the progression of
your search and YouTube progression as well as demographic data (site visitor
data). This data may be used for customized advertising with the assistance of
Google Signal. If you have a Google account, your site visitor information will
be linked to your Google account by Google Signal and used to send you
customized promotional messages. The data is also used to compile anonymized
statistics of our users’ online patterns.
Contract data processing
We have executed a contract data processing agreement with
Google and are implementing the stringent provisions of the German data
protection agencies to the fullest when using Google Analytics.
Google Analytics E-Commerce-Tracking
This website uses the “E-Commerce Tracking” function of
Google Analytics. With the assistance of E-Commerce Tracking, the website
operator is in a position to analyze the purchasing patterns of website
visitors with the aim of improving the operator’s online marketing campaigns.
In this context, information, such as the orders placed, the average order
values, shipping costs and the time from viewing the product to making the
purchasing decision are tracked. These data may be consolidated by Google under
a transaction ID, which is allocated to the respective user or the user’s
device.
Microsoft Advertising
The website operator uses Microsoft Advertising. Microsoft
Advertising is an online advertising program of Microsoft Corporation, One
Microsoft Way, Redmond, WA 98052-6399, USA.
Microsoft Advertising enables us to display advertisements
in the Bing search engine or on third-party websites when the user enters
certain search terms into Bing (keyword targeting). Furthermore, targeted
advertisements can be displayed based on the user data available at Microsoft
(e.g., location data and interests) (target group targeting). As the website
operator, we can evaluate this data quantitatively by analyzing, for example,
which search terms led to the display of our advertisements and how many
advertisements led to the corresponding clicks.
We use universal event tracking (UET) from Microsoft
Advertising on this site. Pseudonymized data is collected to track the actions
you take on our websites after you have clicked on an advertisement of
Microsoft Advertising. UET collects your IP address (anonymized), device
identifiers, information about device and browser settings, Microsoft Click ID
(stored in cookie), time spent on the website, which areas of the website were
accessed, which advertisement brought you to the website and which keyword you
clicked on.
The use of this service is based on your consent in
accordance with Art. 6 (1)(a) GDPR and § 25 (1) TDDDG. Consent can be revoked
at any time.
Data transfer to the US is based on the standard contractual
clauses of the EU Commission. You can find details here: https://learn.microsoft.com/en-us/compliance/regulatory/offering-eu-model-clauses.
The company is certified in accordance with the “EU-US Data
Privacy Framework” (DPF). The DPF is an agreement between the European Union
and the US, which is intended to ensure compliance with European data
protection standards for data processing in the US. Every company certified
under the DPF is obliged to comply with these data protection standards. For
more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/6474.
Data processing
We have concluded a data processing agreement (DPA) for the
use of the above-mentioned service. This is a contract mandated by data privacy
laws that guarantees that they process personal data of our website visitors
only based on our instructions and in compliance with the GDPR.
Google Ads
The website operator uses Google Ads. Google Ads is an
online promotional program of Google Ireland Limited (“Google”), Gordon House,
Barrow Street, Dublin 4, Ireland.
Google Ads enables us to display ads in the Google search
engine or on third-party websites, if the user enters certain search terms into
Google (keyword targeting). It is also possible to place targeted ads based on
the user data Google has in its possession (e.g., location data and interests;
target group targeting). As the website operator, we can analyze these data
quantitatively, for instance by analyzing which search terms resulted in the
display of our ads and how many ads led to respective clicks.
The use of these services occurs on the basis of your
consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your
consent at any time.
Data transmission to the US is based on the Standard
Contractual Clauses (SCC) of the European Commission. Details can be found
here: https://policies.google.com/privacy/frameworks?hl=en and https://business.safety.google/controllerterms/.
The company is certified in accordance with the “EU-US Data
Privacy Framework” (DPF). The DPF is an agreement between the European Union
and the US, which is intended to ensure compliance with European data
protection standards for data processing in the US. Every company certified
under the DPF is obliged to comply with these data protection standards. For
more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.
Google Ads Remarketing
This website uses the functions of Google Ads Remarketing.
The provider of these solutions is Google Ireland Limited (“Google”), Gordon
House, Barrow Street, Dublin 4, Ireland.
With Google Ads Remarketing, we can assign people who
interact with our online offering to specific target groups in order to
subsequently display interest-based advertising to them in the Google
advertising network (remarketing or retargeting).
Moreover, it is possible to link the advertising target
groups generated with Google Ads Remarketing to device encompassing functions
of Google. This makes it possible to display interest-based customized
advertising messages, depending on your prior usage and browsing patterns on a
device (e.g., cell phone) in a manner tailored to you as well as on any of your
devices (e.g., tablet or PC).
If you have a Google account, you have the option to object
to personalized advertising under the following link: https://myadcenter.google.com/home?hl=en.
The use of these services occurs on the basis of your
consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your
consent at any time.
For further information and the pertinent data protection
regulations, please consult the Data Privacy Policies of Google at: https://policies.google.com/technologies/ads?hl=en.
The company is certified in accordance with the “EU-US Data
Privacy Framework” (DPF). The DPF is an agreement between the European Union
and the US, which is intended to ensure compliance with European data
protection standards for data processing in the US. Every company certified
under the DPF is obliged to comply with these data protection standards. For
more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.
Formation of Target Groups with Customer Reconciliation
For the formation of target groups, we use, among other
things, the Google Ads Remarketing customer reconciliation feature. To achieve
this, we transfer certain customer data (e.g., email addresses) from our
customer lists to Google. If the respective customers are Google users and are
logged into their Google accounts, matching advertising messages within the
Google network (e.g., YouTube, Gmail or in a search engine) are displayed for
them to view.
Braze
We use the customer engagement platform Braze, a service
provided by Braze, Inc. (330 West 34th Street, 18th Floor, New York, NY 10001,
USA), to deliver personalized marketing communications, push notifications,
in-app messages, and email campaigns.
Braze is used to analyze user behavior on our website and
mobile applications, including information such as app usage, device
information, and interaction with messages. This enables us to tailor our
communications and improve the relevance of our marketing efforts.
The legal basis for this processing is your consent pursuant
to Art. 6(1)(a) GDPR, or, where applicable, our legitimate interests under Art.
6(1)(f) GDPR, namely in providing you with relevant and engaging content and
improving our services.
Braze acts as our data processor under a data processing
agreement in accordance with Art. 28 GDPR. Braze is certified under the EU-U.S.
Data Privacy Framework, ensuring an adequate level of data protection in
accordance with Art. 45 GDPR. Where applicable, we have concluded Standard
Contractual Clauses (SCCs) approved by the European Commission to provide
appropriate safeguards for data transfers pursuant to Art. 46 GDPR.
You may withdraw your consent at any time with future effect
by [describe mechanism, e.g., adjusting your cookie preferences or contacting
us].
For further information on how Braze handles personal data,
please refer to Braze’s privacy policy at: https://www.braze.com/privacy.
Meta Pixel (formerly Facebook Pixel)
To measure conversion rates, this website uses the visitor
activity pixel of Meta. The provider of this service is Meta Platforms Ireland
Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Meta’s statement
the collected data will be transferred to the USA and other third-party
countries too.
This tool allows the tracking of page visitors after they
have been linked to the website of the provider after clicking on a Meta ad.
This makes it possible to analyze the effectiveness of Meta ads for statistical
and market research purposes and to optimize future advertising campaigns.
For us as the operators of this website, the collected data
is anonymous. We are not in a position to arrive at any conclusions as to the
identity of users. However, Meta archives the information and processes it, so
that it is possible to make a connection to the respective user profile on
Facebook or Instagram and Meta is in a position to use the data for its own
promotional purposes in compliance with the Meta Data Usage Policy (https://www.facebook.com/about/privacy/).
This enables Meta to display ads on Facebook or Instagram and other advertising
channels. We as the operator of this website have no control over the use of
such data.
The use of these services occurs on the basis of your
consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your
consent at any time.
Within the meta pixel, we are using the expanded alignment
function.
The expanded alignment allows us to transfer to Meta
different types of data (e.g., place of residence, federal state, zip code,
hashed email addresses, names, gender, date of birth or phone number) of our
customers and prospects we collect through our website. Herewith, we can tailor
the offers presented in our advertising campaigns on Facebook and Instagram to
individuals interested in what we offer even more precisely. Moreover, this
expanded alignment optimizes the allocation of website conversions and expands
custom audiences.
Insofar as personal data is collected on our website with
the help of the tool described here and forwarded to Meta, we and Meta
Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2,
Ireland are jointly responsible for this data processing (Art. 26 DSGVO). The
joint responsibility is limited exclusively to the collection of the data and
its forwarding to Meta. The processing by Meta that takes place after the
onward transfer is not part of the joint responsibility. The obligations incumbent
on us have been jointly set out in a joint processing agreement. The wording of
the agreement can be found under: https://www.facebook.com/legal/controller_addendum.
According to this agreement, we are responsible for providing the privacy
information when using the Meta tool and for the privacy-secure implementation
of the tool on our website. Meta is responsible for the data security of Meta
products. You can assert data subject rights (e.g., requests for information)
regarding data processed by Facebook or Instagram directly with Meta. If you
assert the data subject rights with us, we are obliged to forward them to Meta.
Data transmission to the US is based on the Standard
Contractual Clauses (SCC) of the European Commission. Details can be found
here: https://www.facebook.com/legal/EU_data_transfer_addendum and https://www.facebook.com/help/566994660333381.
In Meta’s Data Privacy Policies, you will find additional
information about the protection of your privacy at: https://www.facebook.com/about/privacy/.
You also have the option to deactivate the remarketing
function “Custom Audiences” in the ad settings section under https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.
To do this, you first have to log into Facebook.
If you do not have a Facebook or Instagram account, you can
deactivate any user-based advertising by Meta on the website of the European
Interactive Digital Advertising Alliance: https://www.youronlinechoices.com/.
The company is certified in accordance with the “EU-US Data
Privacy Framework” (DPF). The DPF is an agreement between the European Union
and the US, which is intended to ensure compliance with European data
protection standards for data processing in the US. Every company certified
under the DPF is obliged to comply with these data protection standards. For
more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/4452.
Meta Custom Audiences
We use Meta Custom Audiences. The provider of this service
is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland.
Whenever you visit or use our website and apps, utilize our
portfolio (e.g., participation in sweepstakes), transfer data to us or interact
with the Facebook or Instagram content of our company, we record related
personal data. In the event that you have given us your consent to the use of
Meta Custom Audiences, we will share these data with Meta to put Meta in a
position to send you compatible ads. These data may also be used to defined
target audiences (Lookalike Audiences).
Meta processes these data as our contract processor. For
details, please consult the user agreement of Meta: https://www.facebook.com/legal/terms/customaudience.
The use of these services occurs on the basis of your
consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your
consent at any time.
The transfer of date to the USA is based on the standard
contract clauses of the EU Commission. For details please see: https://www.facebook.com/legal/terms/customaudience and https://www.facebook.com/legal/terms/dataprocessing.
The company is certified in accordance with the “EU-US Data
Privacy Framework” (DPF). The DPF is an agreement between the European Union
and the US, which is intended to ensure compliance with European data
protection standards for data processing in the US. Every company certified
under the DPF is obliged to comply with these data protection standards. For
more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/4452.
TikTok Pixel
We have integrated TikTok pixel on this website. The
provider is TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380,
Ireland (hereinafter TikTok).
With the help of TikTok Pixel, we can display interest-based
advertisements on TikTok to website visitors who have viewed our offers (TikTok
Ads). At the same time, TikTok Pixel allows us to determine how effective our
advertising is on TikTok. This allows us to evaluate the effectiveness of the
TikTok Ads for statistical and market research purposes and to optimize them
for future advertising efforts. For this purpose, various usage data are
processed, such as IP address, page views, time spent, operating system used
and origin of the user, information about the ad on which a person clicked on
TikTok or an event that was triggered (timestamp). This data is summarized in a
user ID and assigned to the respective end device of the website visitor.
The use of this tool is based on Art. 6(1)(a) GDPR and § 25
(1) TDDDG. This consent can be revoked at any time.
Data transfer to third-party countries is based on the
standard contractual clauses of the EU Commission. Details can be found
here: https://www.tiktok.com/legal/page/eea/privacy-policy/en and https://ads.tiktok.com/i18n/official/policy/controller-to-controller.
Data processing
We have concluded a data processing agreement (DPA) for the
use of the above-mentioned service. This is a contract mandated by data privacy
laws that guarantees that they process personal data of our website visitors
only based on our instructions and in compliance with the GDPR.
6.
Plug-ins and Tools
YouTube with expanded data protection integration
This website integrates videos from the YouTube website. The
operator of the website is Google Ireland Limited (“Google”), Gordon House,
Barrow Street, Dublin 4, Ireland.
When you visit one of these websites on which YouTube is
integrated, a connection to the YouTube servers is established. This tells the
YouTube server which of our pages you have visited. If you are logged into your
YouTube account, you enable YouTube to assign your surfing behavior directly to
your personal profile. You can prevent this by logging out of your YouTube
account.
We use YouTube in extended data protection mode. According
to YouTube, videos that are played in extended data protection mode are not
used to personalize browsing on YouTube. Ads that are played in extended data
protection mode are also not personalized. No cookies are set in extended data
protection mode. Instead, so-called local storage elements are stored in the
user's browser, which contain personal data similar to cookies and can be used
for recognition. Details on the extended data protection mode can be found
here: https://support.google.com/youtube/answer/171780.
After activating a YouTube video, further data processing
operations may be triggered over which we have no influence.
The use of YouTube is based on our interest in presenting
our online content in an appealing manner. Pursuant to Art. 6(1)(f) GDPR, this
is a legitimate interest. If appropriate consent has been obtained, the
processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and §
25 (1) TDDDG, insofar the consent includes the storage of cookies or the access
to information in the user’s end device (e.g., device fingerprinting) within
the meaning of the TDDDG. This consent can be revoked at any time.
For more information on how YouTube handles user data,
please consult the YouTube Data Privacy Policy under: https://policies.google.com/privacy?hl=en.
The company is certified in accordance with the “EU-US Data
Privacy Framework” (DPF). The DPF is an agreement between the European Union
and the US, which is intended to ensure compliance with European data
protection standards for data processing in the US. Every company certified
under the DPF is obliged to comply with these data protection standards. For
more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.
7.
eCommerce and payment service
providers
Processing of Customer and Contract Data
We collect, process, and use personal customer and contract
data for the establishment, content arrangement and modification of our
contractual relationships. Data with personal references to the use of this
website (usage data) will be collected, processed, and used only if this is
necessary to enable the user to use our services or required for billing
purposes. The legal basis for these processes is Art. 6(1)(b) GDPR.
The collected customer data shall be deleted upon completion
of the order or termination of the business relationship and upon expiration of
any existing statutory archiving periods. This shall be without prejudice to
any statutory archiving periods.
Data transfer upon closing of contracts for services and
digital content
We share personal data with third parties only if this is
necessary in conjunction with the handling of the contract; for instance, with
the financial institution tasked with the processing of payments.
Any further transfer of data shall not occur or shall only
occur if you have expressly consented to the transfer. Any sharing of your data
with third parties in the absence of your express consent, for instance for
advertising purposes, shall not occur.
The basis for the processing of data is Art. 6(1)(b) GDPR,
which permits the processing of data for the fulfilment of a contract or for
pre-contractual actions.
Payment services
We integrate payment services of third-party companies on
our website. When you make a purchase from us, your payment data (e.g. name,
payment amount, bank account details, credit card number) are processed by the
payment service provider for the purpose of payment processing. For these
transactions, the respective contractual and data protection provisions of the
respective providers apply. The use of the payment service providers is based
on Art. 6(1)(b) GDPR (contract processing) and in the interest of a smooth,
convenient, and secure payment transaction (Art. 6(1)(f) GDPR). Insofar as your
consent is requested for certain actions, Art. 6(1)(a) GDPR is the legal basis
for data processing; consent may be revoked at any time for the future.
We use the following payment services / payment service
providers within the scope of this website:
PayPal
The provider of this payment service is PayPal (Europe)
S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter
“PayPal”).
Data transmission to the US is based on the Standard
Contractual Clauses (SCC) of the European Commission. Details can be found
here: https://www.paypal.com/de/webapps/mpp/ua/pocpsa-full.
Details can be found in PayPal’s privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.
Stripe
The provider for customers within the EU is Stripe Payments
Europe, Ltd,1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland
(hereinafter “Stripe”).
Data transmission to the US is based on the Standard
Contractual Clauses (SCC) of the European Commission. Details can be found
here: https://stripe.com/gb/privacy and https://stripe.com/gb/legal/dpa.
Details can be found in Stripe’s Privacy Policy at the
following link: https://stripe.com/gb/privacy.