Privacy Policy

As of 14.09.2023

Identity and contact details of the data controller

The data controller responsible in accordance with the purposes of the General Data Protection Regulation (GDPR) of the European Union and other data protection regulations is:

SoundReply Solutions GmbH
Oskar-Jäger-Straße 173
50825 Köln
Deutschland
+4922198658843
hello@how.fm
https://www.how.fm/

Contact details of the data protection officer

The designated data protection officer is:

DataCo GmbH
Dachauer Str. 65
80335 Munich
Germany
+49 89 7400 45840
www.dataguard.de 

General information on data processing

1. Scope of processing personal data
In general, we only process the personal data of our users to the extent necessary to provide a functioning website with our content and services. The regular processing of personal data only takes place with the consent of the user. Exceptions include cases where prior consent cannot be technically obtained and where the processing of the data is permitted by law.

2. Legal basis for data processing
Where consent is appropriate for processing personal data, Art. 6 (1) (a) GDPR serves as the legal basis to obtain the consent of the data subject for the processing of their data.

As for the processing of personal data required for the performance of a contract of which the data subject is party, Art. 6 (1) (b) GDPR serves as the legal basis. This also applies to processing operations required to carry out pre-contractual activities.

When it is necessary to process personal data in order to fulfill a legal obligation to which our company is subject, Art. 6 (1) (c) GDPR serves as the legal basis.

If vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (d) GDPR serves as the legal basis.

If the processing of data is necessary to safeguard the legitimate interests of our company or that of a third party, and the fundamental rights and freedoms of the data subject do not outweigh the interest of the former, Art. 6 (1) (f) GDPR will serve as the legal basis for the processing of data.

3. Data removal and storage duration
The personal data of the data subject will be erased or restricted as soon as the purpose of its storage has been accomplished. Additional storage may occur if this is provided for by the European or national legislator within the EU regulations, law, or other relevant regulations to which the data controller is subject. Restriction or erasure of the data also takes place when the storage period stipulated by the aforementioned standards expires, unless there is a need to prolong the storage of the data for the purpose of concluding or fulfilling the respective contract.

Rights of the data subject

When your personal data is processed, you are a data subject within the meaning of the GDPR and have the following rights:

1. Right of access (Art. 15 GDPR)
You may request the data controller to confirm whether your personal data is processed by them. If such processing occurs, you can request the following information from the data controller:

  • Purposes of processing
  • Categories of personal data being processed.
  • Recipients or categories of recipients to whom the personal data have been or will be disclosed.
  • Planned storage period or the criteria for determining this period
  • The existence of the rights of rectification, erasure or restriction or opposition.
  • The existence of the right to lodge a complaint with a supervisory authority.
  • If applicable, origin of the data (if collected from a third party).
  • If applicable, existence of automated decision-making including profiling with meaningful information about the logic involved, the scope and the effects to be expected.
  • If applicable, transfer of personal data to a third country or international organization.

2. Right to rectification (Art. 16 GDPR)
You have a right to rectification and/or modification of the data, if your processed personal data is incorrect or incomplete. The data controller must correct the data without delay.

3. Right to the restriction of processing (Art. 18 GDPR)
You may request the restriction of the processing of your personal data under the following conditions:

  • If you challenge the accuracy of your personal data for a period that enables the data controller to verify the accuracy of your personal data.
  • The processing is unlawful, and you oppose the erasure of the personal data and instead request the restriction of their use instead.
  • The data controller or its representative no longer need the personal data for the purpose of processing, but you need it to assert, exercise or defend legal claims; or
  • If you have objected to the processing pursuant, and it is not yet certain whether the legitimate interests of the data controller override your interests.

4. Right to erasure (“Right to be forgotten”) (Art. 17 GDPR)
If you request from the data controller to delete your personal data without undue delay, they are required to do so immediately if one of the following applies:

  • Personal data concerning you is no longer necessary for the purposes for which they were collected or processed.
  • You withdraw your consent on which the processing is based pursuant to and where there is no other legal basis for processing the data.
  • You object to the processing of the data and there are no longer overriding legitimate grounds for
  • processing, or you object pursuant to Art. 21 (2) GDPR. Your personal data has been processed unlawfully.
  • The personal data must be deleted to comply with a legal obligation in Union law or Member State law to which the data controller is subject.
  • Your personal data was collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.

The right to deletion does not exist if the processing is necessary

  • to exercise the right to freedom of speech and information;
  • to fulfill a legal obligation required by the law of the Union or Member States to which the data controller is subject, or to perform a task of public interest or in the exercise of public authority delegated to the representative.
  • for reasons of public interest in the field of public health.
  • for archival purposes of public interest, scientific or historical research purposes or for statistical purposes.
  • to enforce, exercise or defend legal claims.

5. Right to data portability
You have the right to receive your personal data given to the data controller in a structured and machine-readable format. In addition, you have the right to transfer this data to another person without hindrance by the data controller who was initially given the data, if:

6. Right to object
For reasons that arise from your particular situation, you have, at any time, the right to object to the processing of your personal data pursuant to Art. 6 (1) (e) or 6 (1) (f) GDPR; this also applies to profiling based on these provisions.

If the personal data relating to you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data in regard to such advertising; this also applies to profiling associated with direct marketing.

7. Right to complain to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority if you consider that the processing of personal data concerning you infringes the GDPR. The supervisory authority to which the complaint has been lodged shall inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy under Art. 78 GDPR. A list, of the locally competent supervisory authorities in Germany can be found on the website of the Federal Commissioner for Data Protection at the following link: https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html

Provision of website and creation of log files

1. Description and scope of data processing
Each time our website is accessed, our system automatically collects data and relevant information from the computer system of the calling device.

The following data is collected:

  • Information about the browser type and the version used The user’s operating system
  • The Internet service provider of the user
  • Date and time of access
  • Websites from which the user’s system accessed our website
  • Websites the user’s system accessed through our website

This data is stored in the log files of our system.
This data is not stored together with other personal data of the user.

2. Purpose of data processing
The temporary storage of the IP address by the system is necessary for the delivery of the website to the computer of the user. For this purpose, the user’s IP address must be kept for the duration of the session.

The storage in logfiles is done to ensure the functionality of the website. The data is also used to optimize the website and to ensure the security of our IT systems. An analysis of the data for marketing purposes does not take place.

3. Legal basis for data processing
The legal basis for the temporary storage of data and log files is Art. 6 (1) (f) GDPR.

4. Duration of storage
The data will be deleted as soon as it is no longer necessary for the purpose of its collection. The session is complete when the collection of data for the provision of the website is accomplished.

If the data is stored in log files, this is the case after seven days at the latest. Storage beyond this is possible. In this case, the IP addresses of the users are deleted or alienated so that an assignment of the calling client is not possible.

5. Objection and removal
The collection of data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. The user can object to this. Whether the objection is successful is to be determined within the framework of a balancing of interests.

Use of cookies

1. Description and scope of data processing
When you visit our website, we use technical tools for various functions, in particular cookies, which can be stored on your device. When you visit our website for the first time and at any time later, you have the choice of whether you generally permit the setting of cookies or which individual additional functions you would like to select. You can make changes in your browser settings or via our consent manager. Cookies are text files or information in a database that are stored on your hard drive and assigned to the browser you are using so that certain information can be passed to the entity that sets the cookie.

We use technically necessary cookies, which are required for the technical structure of the website. Without these cookies, our website cannot be displayed (completely correctly) or the support functions are not possible.

The following data is stored and transmitted in the technical necessary cookies: 

  • Language settings
  • Log-in information

We use cookies on our website that are not technically necessary. Technically unnecessary cookies are text files that are not only used for the functionality of the website, but also collect other data.

As a result, the following data will be processed: 

  • IP-address
  • Internet user location
  • Date and time of the website request Tracking of the surfing behavior
  • Linking the website visit with other social media platforms

2. Purpose of data processing
The purpose of using technically necessary cookies is to ensure the functionality of our website. Some functions of our website cannot be offered without the use of cookies. For these, it is necessary that the browser is recognized even after a page change.

We need technical necessary cookies for the following purposes: 

  • Storage of language settings
  • Storage of search queries

The use of technically not necessary cookies is carried out for the purpose of improving the quality of our website, its content and thus our reach and profitability. By setting these cookies, we learn how the website is used and can thus constantly optimize our offer. These cookies serve us particularly for the following purposes:

User behavior on our website; other information used for marketing purposes.

3. Legal basis for data processing
The regulations of the Telecommunications-Telemedia Data Protection Act (TTDSG) are relevant for the storage of information in the end user’s terminal equipment and/or access to information already stored in the end user’s terminal equipment. If the setting and reading of cookies is technically necessary, this is done to ensure the functionality of our website. In this case, the storage of and access to cookies on your terminal equipment is carried out on the basis of § 25(2)(2) TTDSG. This storage of and access to the information in your terminal equipment serves to facilitate your use of our website and to be able to offer you our services as you have requested. Some functions of our website also do not work without the use of these cookies and could therefore not be offered. The cookies are generally deleted after the session ends (e.g. logging out or closing the browser) or after the expiry of a specified duration. Information on different storage periods for cookies can be found in the following sections of this data protection declaration.

As far as cookies are set that are not technically necessary, this is done on the basis of your expressed consent, which you can provide via the cookie banner. The basis for storing and accessing information in this case is § 25(1) TTDSG in conjunction with. Art. 6(1)(1)(a), Art. 7 GDPR. You can withdraw your consent at any time with effect for the future or subsequently grant it again by configuring your settings for cookies accordingly. Alternatively, you can prevent the storage of cookies by making the appropriate settings in your browser software. Please note that the browser settings you make only affect the browser you are using. If personal data is processed following the storage of and access to the information on your terminal equipment, the provisions of the GDPR are relevant. Information on this can be found in the following sections of this privacy policy.

Contact via Email

1. Description and scope of data processing
You can contact us via the email address provided on our website. In this case the personal data of the user transmitted with the email will be stored.
The data will be used exclusively for the processing of the conversation.

2. Purpose of data processing
If you contact us via email, this also constitutes the necessary legitimate interest in the processing of the data.

3. Legal basis for data processing
The legal basis for the processing of data transmitted in the course of sending an email is Art. 6 (1) (f) GDPR. Our legitimate interest is to optimally answer your request that you send by email.

If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) GDPR.

4. Duration of storage
The data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. For personal data sent by email, this is the case when the respective conversation with the user has ended. The conversation ends when it can be concluded from the circumstances that the matter in question has been conclusively resolved.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

5. Objection and removal
The user has the possibility to withdraw consent to the processing of their personal data at any time. If the user contacts us by email, he can object to the storage of his personal data at any time.

Every person affected by the processing of personal data has the right granted by the European Directive and Regulation to withdraw consent to the processing of personal data at any time. If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact the company by email at legal@how.fm for processing.

In this case, all personal data stored while establishing contact will be deleted.

Contact form

1. Description and scope of data processing
A Contact form is available on our website, which can be used for electronic contact. If a user makes use of this option, the data entered in the input mask will be transmitted to us and stored.

When sending the message the following data will also be stored: 

  • Email address
  • Last name 
  • First name
  • Voluntary data, message content 
  • IP address of the user’s device 
  • Date and time

2. Purpose of data processing
The processing of the personal data from the input mask as well as if you contact us by mail serves us exclusively for the purpose of establishing contact.

The other personal data processed during the sending process serve to prevent misuse of the Contact form and to ensure the security of our information technology systems.

3. Legal basis for data processing
The legal basis for the processing of data transmitted while sending an email is Art. 6 (1) (f) GDPR. Our legitimate interest is to provide you with the best possible response to the request you send to us via the contact form. If the purpose of the email contact is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) GDPR.

4. Duration of storage
The data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. For the personal data from the input mask of the Contact form and those sent by email, this is the case when the respective conversation with the user has ended. The conversation ends when it can be inferred from the circumstances that the facts in question have been conclusively clarified.

The additional personal data collected during the sending process will be deleted after a period of seven days at the latest.

5. Objection and removal
If the user contacts us via the input mask in the contact form or via email, the user can object to the storage of his or her personal data at any time.

Every person affected by the processing of personal data has the right granted by the European Directive and Regulation to withdraw consent to the processing of personal data at any time. If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact the company by email at legal@how.fm for processing.

In this case, all personal data stored while establishing contact will be deleted.

Contact form Get Customer Support

1. Scope of the processing of personal data
We use functions of the Hubspot Forms of

HubSpot Inc.
25 First Street, 2nd Floor
Cambridge, MA 02141
United States

(hereinafter referred to as: Get Customer Support).

This contact form is available on our website, which can be used for making business contact. If a user makes use of this option, the data entered in the input mask will be transmitted to us and stored and the user will receive a single email sent by us.

If a website user takes advantage of this option, the data entered in the input mask will be transmitted to us and stored. These data are:

  • Email
  • Company name (optional)
  • First name (optional)
  • Last name (optional)
  • Topic
  • Account
  • Problem Description (optional)
  • Where is the issue (optional)
  • Urgency 
  • File upload (optional)

For more information on the processing of data by Get Customer Support, please click here: https://legal.hubspot.com/privacy-policy

2. Purpose of data processing
Your personal data is stored for the purpose of processing the request transmitted with your communication and, if necessary, to contact you. 

3. Legal basis for the processing of personal data
The legal basis for the processing of data transmitted in the course of a transmission is Art. 6 (1) (f) GDPR. Our legitimate interest is the appropriate response to contact requests. If the email contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 (1) (b) GDPR. 

4. Duration of storage
The data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. For personal data, this is the case when the respective conversation with the user has ended. The conversation is terminated when it can be inferred from the circumstances that the matter in question has been conclusively clarified.

5. Possibility of objection and removal
If the user contacts us by email, he or she can object to the storage of his or her personal data at any time by sending an email to legal@how.fm. In such a case, the conversation cannot be continued.

All personal data stored in the course of contacting us will be deleted in this case.

Application via application form Personio

1. Scope of the processing of personal data
An application form is available on our website, which can be used for electronic applications. For the provision of the application form, we use the recruiting page of the personnel and applicant management software Personio of the service provider Personio GmbH, Rundfunkplatz 4, 80335, Munich, Germany.

If an applicant uses this option, the data entered in the input mask is transmitted to Personio and stored.

In addition, we offer an applicant/talent pool.

Further information can be found in the Personio privacy policy: https://www.personio.de/datenschutzerklaerung/ 

If an applicant takes advantage of this option, the data entered in the input mask will be transmitted to us and stored. These data are:

  • First name 
  • Surname
  • Email address
  • Telephone/cell phone number (optional)
  • Expected date of availability
  • Salary expectation 
  • Language skills German & English (optional)
  • Work permit status (blue card required or not)
  • LinkedIn (optional)
  • Curriculum vitae 
  • Other personal data voluntarily communicated during the application process

Alternatively, you can also send us your application by email. In this case, we will record your email address and the data you provide in the email.

After sending your application, you will receive a confirmation of receipt of your application documents by email from us.

The data will be used exclusively for processing your application.

2. Purpose of data processing
The processing of your personal data serves us solely to process your application. The other personal data processed during the submission process serve to prevent misuse of the contact form and to ensure the security of our information technology systems.

3. Legal basis for data processing
The legal basis for the processing of your data is the contract initiation which takes place at the request of the data subject, Art. 6 (1) (b) GDPR and § 26 (1) BDSG.

4. Duration of storage
After completion of the application process, the data will be stored for up to six months. Your data will be deleted after six months at the latest. In the event of a legal obligation, the data will be stored within the framework of the applicable provisions.

5. Possibility of objection and elimination
The applicant has the option to object to the processing of his/her personal data at any time by sending an email to legal@how.fm. In such a case, the application can no longer be considered.

All personal data stored in the course of electronic applications will be deleted in this case.

Corporate web profiles on social networks

Instagram:
Instagram, Part of Meta Platforms Ireland Ltd., 4 Grand Canal Square Grand Canal Harbour, Dublin 2 Ireland

On our company profile we provide information and offer Instagram users the possibility of communication. If you carry out an action on our Instagram company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by Instagram, we cannot make any binding statements regarding the purpose and scope of the processing of your data.

Our corporate profile in social networks is used for communication and information exchange with (potential) customers. We integrated components of the following networks on this website: Facebook, Instagram and LinkedIn. These networks are used to connect with users of existing business contacts as well as to connect with other contacts who are interested in our product. Furthermore, these networks are used as a platform and serve to exchange opinions and experiences. This enables the internet community to provide personal and/or company-related information. Furthermore, these networks enable users to share photos and videos and to disseminate such data in other social networks.

Publications on the company profile can contain the following content: 

  • Information about products
  • Information about services
  • Advertisement
  • Contact with customers

Every user is free to publish personal data.

As far as we process your personal data in order to evaluate your online behavior, to offer you sweepstakes or to conduct lead campaigns, this is done on the basis of your express declaration of consent, Art. 6 (1) (a), Art. 7 GDPR. The legal basis for processing personal data for the purpose of communicating with customers and interested parties is Art. 6 (1) (f) GDPR. Thereby, our legitimate interest is to answer your request optimally or to be able to provide the requested information. If the aim of contacting you is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (1) (b) GDPR.

The data generated on the company profile are not stored in our own systems.

For the processing of your personal data in third countries, we have provided appropriate guarantees in form of standard data protection clauses pursuant to Art. 46(2)(c) GDPR. A copy of the standard data protection clauses can be requested from us.

You can object at any time to the processing of your personal data that we collect within the framework of your use of our Instagram corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to legal@how.fm. For further information on the processing of your personal data by Instagram and the corresponding objection options, please click here:
Instagram: https://help.instagram.com/519522125107875 

YouTube:
YouTube LLC, 901 Cherry Ave., San Bruno, CA 94066, United States

On our company profile we provide information and offer Youtube users the possibility of communication. If you carry out an action on our Youtube company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by Youtube, we cannot make any binding statements regarding the purpose and scope of the processing of your data.

Our corporate profile in social networks is used for communication and information exchange with (potential) customers. We integrated components of the following networks on this website: Facebook, Instagram and LinkedIn. These networks are used to connect with users of existing business contacts as well as to connect with other contacts who are interested in our product. Furthermore, these networks are used as a platform and serve to exchange opinions and experiences. This enables the internet community to provide personal and/or company-related information. Furthermore, these networks enable users to share photos and videos and to disseminate such data in other social networks.

Publications on the company profile can contain the following content:

  • Information about products 
  • Information about services 
  • Advertisement
  • Contact with customers

Every user is free to publish personal data.

As far as we process your personal data in order to evaluate your online behavior, to offer you sweepstakes or to conduct lead campaigns, this is done on the basis of your express declaration of consent, Art. 6 (1) (a), Art. 7 GDPR. The legal basis for processing personal data for the purpose of communicating with customers and interested parties is Art. 6 (1) (f) GDPR. Thereby, our legitimate interest is to answer your request optimally or to be able to provide the requested information. If the aim of contacting you is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (1) (b) GDPR.

The data generated on the company profile are not stored in our own systems.

For the processing of your personal data in third countries, we have provided appropriate guarantees in form of standard data protection clauses pursuant to Art. 46(2)(c) GDPR. A copy of the standard data protection clauses can be requested from us.

You can object at any time to the processing of your personal data that we collect within the framework of your use of our Youtube corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to legal@how.fm. For further information on the processing of your personal data by Youtube and the corresponding objection options, please click here:
YouTube: https://policies.google.com/privacy?gl=DE&hl=en 

Twitter:
Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, Ireland

On our company profile we provide information and offer Twitter users the possibility of communication. If you carry out an action on our Twitter company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public. However, as we generally or to a large extent have no influence on the processing of your personal data by Twitter, we cannot make any binding statements regarding the purpose and scope of the processing of your data.

Our corporate profile in social networks is used for communication and information exchange with (potential) customers. We integrated components of the following networks on this website: Facebook, Instagram and LinkedIn. These networks are used to connect with users of existing business contacts as well as to connect with other contacts who are interested in our product. Furthermore, these networks are used as a platform and serve to exchange opinions and experiences. This enables the internet community to provide personal and/or company-related information. Furthermore, these networks enable users to share photos and videos and to disseminate such data in other social networks.

Publications on the company profile can contain the following content: 

  • Information about products
  • Information about services
  • Advertisement
  • Contact with customers

Every user is free to publish personal data.

As far as we process your personal data in order to evaluate your online behavior, to offer you sweepstakes or to conduct lead campaigns, this is done on the basis of your express declaration of consent, Art. 6 (1) (a), Art. 7 GDPR. The legal basis for processing personal data for the purpose of communicating with customers and interested parties is Art. 6 (1) (f) GDPR. Thereby, our legitimate interest is to answer your request optimally or to be able to provide the requested information. If the aim of contacting you is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (1) (b) GDPR.

The data generated on the company profile are not stored in our own systems.

For the processing of your personal data in third countries, we have provided appropriate guarantees in form of standard data protection clauses pursuant to Art. 46(2)(c) GDPR. A copy of the standard data protection clauses can be requested from us.

You can object at any time to the processing of your personal data that we collect within the framework of your use of our Twitter corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to legal@how.fm. For further information on the processing of your personal data by Twitter and the corresponding objection options, please click here:
Twitter: https://twitter.com/de/privacy

Use of corporate profiles in professionally oriented networks

1. Scope of data processing
We use corporate profiles on professionally oriented networks. We maintain a corporate presence on the following professionally oriented networks:

  • LinkedIn

On our site we provide information and offer users the possibility of communication.
The corporate profile is used for job applications, information, public relations, and active sourcing.

We do not have any information on the processing of your personal data by the companies jointly responsible for the corporate profile. Further information can be found in the privacy policy of:

LinkedIn: https://www.linkedin.com/legal/privacy-policy

If you carry out an action on our company profile (e.g. comments, contributions, likes etc.), you may make personal data (e.g. clear name or photo of your user profile) public.

2. Legal basis for data processing
The legal basis for the processing of personal data for the purpose of communication with customers and interested parties is Art. 6 (1) (f) GDPR. Our legitimate interest is to answer your request optimally or to be able to provide the requested information. If the aim of contacting you is to conclude a contract, the additional legal basis for the processing is Art. 6 (1) (b) GDPR.

3. Purpose of the data processing
Our corporate web profile serves to inform users about our services. Every user is free to publish personal data.

4. Duration of storage
The data generated on the company profile are not stored in our own systems.

5. Objection and removal
You can object at any time to the processing of your personal data which we collect within the scope of your use of our corporate web profile and assert your rights as a data subject mentioned under IV. of this privacy policy. Please send us an informal email to the email address stated in this privacy policy. You can find further information on objection and removal options here:
LinkedIn: https://www.linkedin.com/legal/privacy-policy

Hosting

The website is hosted on servers of a service provider commissioned by us. Our service provider is:

Cloudways
Junction Business Centre
1st Floor Sqaq Lourdes
St Julians STJ3334
Malta

The servers automatically collect and store information in so-called server log files, which your browser automatically transmits when you visit the website. The stored information is: 

  • Information about the browser type and the version used
  • The user’s operating system
  • The Internet service provider of the user
  • Date and time of access
  • Websites from which the user’s system accessed our website
  • Websites the user’s system accessed through our website

This data will not be merged with other data sources. The data is collected on the basis of Art. 6 (1) (f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of his website – and server log files are therefore recorded.

The server of the website is geographically located in the European Union (EU) or the European Economic Area (EEA).

Usage of Plugins

We use plugins for various purposes. The plugins used are listed below:

Use of Google Analytics

1. Scope of processing of personal data
We use Google Analytics, a web analysis service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and its representative in the Union Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland (Hereinafter referred to as Google). Google Analytics examines, among other things, the origin of visitors, their length of stay on individual pages and the use of search engines, thus allowing better monitoring of the success of advertising campaigns. Google places a cookie on your computer. This allows personal data to be stored and evaluated, in particular the user’s activity (in particular which pages have been visited and which elements have been clicked on), device and browser information (in particular the IP address and the operating system), data on the advertisements displayed (in particular which advertisements have been displayed and whether the user has clicked on them) and also data on advertising partners (in particular pseudonymised user IDs). The information generated by the cookie about your use of this website will be transmitted to and stored by Google on servers in the United States. However, if IP anonymization is enabled on this online presence, Google will previously truncate your IP address within member states of the European Union or other signatory states to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.

On behalf of the operator of this online presence, Google will use this information to evaluate your use of the online presence, to compile reports on the activities of the online presence and to provide further services associated with the use of the online presence and the Internet use to the operator of the online presence. The IP address transmitted by your browser as part of Google Analytics is not combined with other data from Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of our website.

Further information on the collection and storage of data by Google can be found here: https://policies.google.com/privacy?hl=en-GB 

2. Purpose of data processing
The purpose of processing personal data is to specifically address a target group that has already expressed an initial interest by visiting the site.

3. Legal basis for the processing of personal data
The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (a) GDPR.

4. Duration of storage
Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law. Advertising data in server logs is anonymized by Google’s own statements to delete parts of the IP address and cookie information after 9 and 18 months respectively.

5. Possibility of revocation of consent and removal
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.

You may prevent the collection and processing of your personal data by Google by preventing the storage of cookies by third parties on your computer, by using the “Do Not Track” function of a supporting browser, by deactivating the execution of script code in your browser or by installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser. You can also prevent the collection of data generated by the cookie and related to your use of the online presence (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en

With the following link you can deactivate the use of your personal data by Google: https://adssettings.google.com 

Further information on objection and removal options against Google can be found at: https://policies.google.com/privacy?gl=EN&hl=en 

Use of Google ReCaptcha

1. Scope of processing of personal data
We use Google ReCaptcha of the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and the representative in the Union Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland. The purpose of this tool is to verify that a data entry is compliant and has not been performed by a bot by analyzing and authenticating the behavior of an online presence visitor with respect to various characteristics. This allows personal data to be stored and evaluated, in particular the user’s activity (in particular mouse movements and which elements were clicked on) and device and browser information (in particular time, IP address and operating system).

The data will not be associated with any data that may be collected or used in connection with the parallel use of authenticated Google services such as Gmail.

For more information about the collection and storage of data by Google, please visit: https://policies.google.com/privacy?hl=en-GB

2. Purpose of data processing
The use of Google ReCaptcha serves to protect our online presence from misuse.

3. Legal basis for the processing of personal data
The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (a) GDPR.

4. Duration of storage
Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law, e.g. for tax and accounting purposes.

5. Possibility of revocation of consent and removal
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.

You can prevent the collection and processing of your personal data by Google by preventing the storage of cookies from third parties on your computer, by using the “Do Not Track” function of a supporting browser, by deactivating the execution of script code in your browser or by using a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser.

With the following link you can deactivate the use of your personal data by Google: https://adssettings.google.com

Further information on objection and removal options against Google can be found at: https://policies.google.com/privacy?hl=en-GB
 

Use of Google Webfonts

1. Scope of processing of personal data
We use Google web fonts of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and its representative in the Union Google Ireland Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland (Hereinafter referred to as Google). The web fonts are transferred to the browser’s cache when the page is called up in order to be able to use them for the visually improved display of various information. If the browser does not support Google Web Fonts or does not allow access, the text will be displayed in a default font. When the page is accessed, no cookies are stored for the online presence visitor. Data transmitted in connection with the page view is sent to resource-specific domains such as https://fonts.googleapis.com or https://fonts.gstatic.com. It may be used to store and analyze personal data, in particular user activity (in particular which pages have been visited and which elements have been clicked on) and device and browser information (in particular IP address and operating system).

The data will not be associated with any data that may be collected or used in connection with the parallel use of authenticated Google services such as Gmail.

For more information about the collection and storage of data by Google, please visit: https://policies.google.com/privacy?hl=en-GB

2. Purpose of data processing
The use of Google Webfonts serves an appealing representation of our texts. If your browser does not support this feature, a standard font will be used by your computer to display it.

3. Legal basis for the processing of personal data
The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (a) GDPR.

4. Duration of storage
Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law, e.g. for tax and accounting purposes.

5. Possibility of revocation of consent and removal
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.

You can prevent the collection and processing of your personal data by Google by preventing the storage of cookies from third parties on your computer, by using the “Do Not Track” function of a supporting browser, by deactivating the execution of script code in your browser or by using a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser.

With the following link you can deactivate the use of your personal data by Google: https://adssettings.google.com 

Further information on objection and removal options against Google can be found at: https://policies.google.com/privacy?hl=en-GB

Use of Hotjar

1. Scope of processing of personal data
We use the Hotjar web analysis service of Hotjar Ltd, Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta (Hereinafter: Hotjar). Hotjar uses cookies, i.e. small text files, which are stored locally in the cache of your web browser on your end device and which enable an analysis of the use of our online presence by you. Personal data can thus be stored and evaluated, in particular the user’s activity (in particular which pages have been visited and which elements have been clicked on), device and browser information (in particular the IP address and the operating system) and a tracking code (pseudonymised user ID). The information thus collected will be transferred by Hotjar to a server in Ireland and stored there in an anonymised form. Further information on the collection and storage of data by Hotjar can be found at: https://www.hotjar.com/legal/policies/privacy

2. Purpose of data processing
The use of the Hotjar Plug-In serves to better understand the needs of our users and to optimize the offer on this online presence.

3. Legal basis for the processing of personal data
The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (a) GDPR.

4. Duration of storage
Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law.

5. Possibility of revocation of consent and removal
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.

You can prevent Hotjar from collecting and processing your personal data by preventing the storage of third-party cookies on your computer, by using the “Do Not Track” function of a supporting browser, by deactivating the execution of script code in your browser, or by using a script blocker such as a “Do Not Track” function.B. Install NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser.

With the following link you can deactivate the use of your personal data by Hotjar: https://www.hotjar.com/legal/compliance/opt-out

For more information on objection and removal options against Hotjar please visit: https://www.hotjar.com/legal/policies/privacy

Use of HubSpot

1. Scope of processing of personal data
We use functions of HubSpot Inc., 2nd Floor, 25 First Street, Cambridge, MA 02141, USA (Hereinafter referred to as HubSpot). This is an integrated software solution that covers various aspects of our online marketing. These include, among other things: Email marketing (newsletters and automated mailings, e.g. to provide downloads), social media publishing & reporting, reporting (especially traffic sources, access, etc. …), contact management (especially user segmentation & CRM), landing pages and contact forms. HubSpot sets a cookie on your computer. This allows personal data to be stored and evaluated, in particular the user’s activity (in particular which pages have been visited and which elements have been clicked on), device and browser information (in particular the IP address and the operating system), data on the advertisements displayed (in particular which advertisements have been displayed and whether the user has clicked on them) and also data on advertising partners (in particular pseudonymised user IDs).

Further information on the collection and storage of data by HubSpot can be found at: https://legal.hubspot.com/privacy-policy

2. Purpose of data processing
The use of the HubSpot Plug-In serves exclusively for the optimization of our marketing.

3. Legal basis for the processing of personal data
The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (a) GDPR.

4. Duration of storage
Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law, e.g. for tax and accounting purposes.

5. Possibility of revocation of consent and removal
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.

You can prevent HubSpot from collecting and processing your personal data by preventing the storage of cookies from third parties on your computer, by using the “Do Not Track” function of a supporting browser, by deactivating the execution of script code in your browser or by installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser.

You can find further information on objection and removal options against HubSpot at:
https://legal.hubspot.com/privacy-policy

You can also find further information on objection and removal options against HubSpot at: https://legal.hubspot.com/privacy-policy

Use of Outbrain

1. Scope of processing of personal data
We use functions of Outbrain UK Limited, 5 New Bridge Street, London, EC4V 6JA, UK (Hereinafter: Outbrain). On parts of our online presence we use the technology of the provider Outbrain, with which our users are referred to further, for them if necessary also interesting contents within our online presence and to online presences of third parties. The further reading recommendations integrated by Outbrain, e.g. below an article, are determined on the basis of the content previously read by the user. Outbrain uses cookies, which are stored on the user’s terminal device, to display this interest-related content. This allows personal data to be stored and evaluated, in particular the user’s activity (in particular which pages have been visited and which elements have been clicked on) and device and browser information (in particular the IP address and the operating system). The content displayed in the Outbrain widget is automatically controlled and delivered by Outbrain in terms of content and technology. Outbrain uses cookies to display reading recommendations on a pseudonymised basis.

Further information on the collection and storage of data by Outbrain can be found here: https://www.outbrain.com/de/legal/privacy

2. Purpose of data processing
The use of the Outbrain Plug-In serves the improvement of the user friendliness of our online presence and service. We use this plug-in to offer article recommendations.

3. Legal basis for the processing of personal data
The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (a) GDPR.

4. Duration of storage
Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law, e.g. for tax and accounting purposes.

5. Possibility of revocation of consent and removal
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.
You can prevent Outbrain from collecting and processing your personal data by preventing the storage of third-party cookies on your computer, by using the “Do Not Track” feature of a supporting browser, by disabling the execution of script code in your browser, or by using a script blocker such as Install NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser.

With the following link, you can deactivate the use of your personal data by Outbrain under point 2. (d): https://www.outbrain.com/de/legal/privacy

For more information on opposition and removal options against Outbrain, please visit: https://www.outbrain.com/de/legal/privacy

Use of YouTube

1. Scope of processing of personal data
We use the plugin operated by Google from YouTube, YouTube LLC, 901 Cherry Ave, San Bruno, CA 94066, USA and their representatives in the Union Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (Hereinafter referred to as Google). We use the plugin from YouTube to embed videos from YouTube on our online presence. When you visit our website, your browser connects to YouTube’s servers. It may be used to store and analyze personal data, in particular user activity (in particular which pages have been visited and which elements have been clicked on) and device and browser information (in particular IP address and operating system).

We have no influence on the content of the plug-in. If you are logged into your YouTube account during your visit, YouTube can assign your online presence visit to this account. By interacting with this plug-in, this corresponding information is transmitted directly to YouTube and stored there.

Further information on the collection and storage of data by Google can be found here:
https://policies.google.com/privacy?hl=en-GB

2. Purpose of data processing
The use of the YouTube PlugIn serves the improvement of the user friendliness and an appealing representation of our on-line operational readiness level.

3. Legal basis for the processing of personal data
The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (a) GDPR.

4. Duration of storage
Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law, e.g. for tax and accounting purposes.

5. Possibility of revocation of consent and removal
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.

You can prevent the collection and processing of your personal data by Google by preventing the storage of cookies from third parties on your computer, by using the “Do Not Track” function of a supporting browser, by deactivating the execution of script code in your browser or by using a script blocker such as a NoScript (https://noscript.net/) or Ghostery (www.ghostery.com=EN&hl=e) in your browser.

With the following link you can deactivate the use of your personal data by Google: https://adssettings.google.com
Further information on objection and removal options against Google can be found at: https://policies.google.com/privacy?hl=en-GB

Use of Google Tag Manager

1. Scope of processing of personal data
We use the Google Tag Manager (https://www.google.com/intl/de/tagmanager/) of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA and its representative in the Union Google Ireland

Ltd., Gordon House, Barrow Street, D04 E5W5, Dublin, Ireland (Hereinafter referred to as Google). With Google Tag Manager, tags from Google and third-party services can be managed and bundled and embedded on an online presence. Tags are small code elements on an online presence that are used, among other things, to measure visitor numbers and behavior, capture the impact of online advertising and social channels, use remarketing and targeting, and test and optimize online presences. When a user visits the online presence, the current tag configuration is sent to the user’s browser. It contains statements about which tags are to be triggered. Google Tag Manager triggers other tags that may themselves collect data. You will find information on this in the passages on the use of the corresponding services in this data protection declaration. Google Tag Manager does not access this data.

For more information about the Google Tag Manager, please visit https://www.google.com/intl/de/tagmanager/faq.html and see Google’s privacy policy: https://policies.google.com/privacy?hl=en

2. Purpose of data processing
The purpose of the processing of personal data lies in the collected and clear administration as well as an efficient integration of the services of third parties.

3. Legal basis for the processing of personal data
The legal basis for the processing of personal data is the user’s given consent in accordance with Art. 6 (1) (a) GDPR.

4. Duration of storage
Your personal information will be stored for as long as is necessary to fulfill the purposes described in this Privacy Policy or as required by law. Advertising data in server logs is anonymized by Google’s own statements to delete parts of the IP address and cookie information after 9 and 18 months respectively.

5. Possibility of revocation of consent and removal
You have the right to revoke your declaration of consent under data protection law at any time. The revocation of the consent does not affect the lawfulness of the processing carried out on the basis of the consent up to the revocation.

You may prevent the collection and processing of your personal data by Google by preventing the storage of cookies by third parties on your computer, by using the “Do Not Track” function of a supporting browser, by deactivating the execution of script code in your browser or by installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser. You can also prevent the collection of data generated by the cookie and related to your use of the online presence (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en

With the following link you can deactivate the use of your personal data by Google: https://adssettings.google.de 

Further information on objection and removal options against Google can be found at: https://policies.google.com/privacy?gl=EN&hl=en

Use of Usercentrics

1. Scope of processing of personal data
We use the Content Manament Platform Usercentrics of the Usercentrics GmbH, Rosental 4, 80331 Munich, Germany (hereinafter referred to as Usercentrics). Usercentrics enables us to obtain the consent of the user for data processing, to administer it and to document it in a legally compliant manner.
The following data are processed:

  • Date and time of visit
  • Device information
  • Browser information
  • Anonymised IP address
  • Opt-in and Opt-out data

The data are processed geographically in the European Union.Further information on the collection and storage of data by Usercentrics can be found here: https://usercentrics.com/de/datenschutzerklaerung/

2. Purpose of data processing
The processing of personal data serves to comply with the legal obligations of the UGDPR and other data protection regulations.

3. Legal basis for the processing of personal data
The legal basis for data processing is Art. 6 (1) (f) GDPR. Our legitimate interest lies in the purposes of data processing mentioned under 2.

4. Duration of storage
Your personal information will be stored for as long as is necessary to fulfill the purposes described in this privacy policy, until you revoke your consent to its storage, or as required by law.

5. Possibility of objection and removal
You may prevent Usercentrics from collecting and processing your personal data by preventing the storage of third-party cookies on your computer, by using the “Do Not Track” feature of a supporting browser, by disabling the execution of script code in your browser, or by installing a script blocker such as NoScript (https://noscript.net/) or Ghostery (https://www.ghostery.com) in your browser.

For more information about objection and removal options regarding Usercentrics, please visit: https://usercentrics.com/privacy-policy/ 

This privacy policy has been created with the assistance of DataGuard.