Privacy Policy
1. Data protection at a glance
General information
The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to personally identify you. Detailed information on the subject of data protection can be found in the full Privacy Policy set out below.
Data collection on this website
Who is responsible for data collection on this website?
The data processing on this website is carried out by the website operator. You can find the operator’s contact details in the section “Information on the controller” in this Privacy Policy.
How do we collect your data?
On the one hand, your data is collected when you provide it to us. This can, for example, be data that you enter into a contact form.
Other data is collected automatically or after your consent when you visit the website by our IT systems. This is mainly technical data (e.g. internet browser, operating system or time of the page view). The collection of this data happens automatically as soon as you enter this website.
What do we use your data for?
Part of the data is collected to ensure error-free provision of the website. Other data may be used to analyze your user behavior.
What rights do you have regarding your data?
You have the right to obtain information free of charge and at any time about the origin, recipients and purpose of your stored personal data. You also have the right to request the rectification or deletion of this data. If you have given consent to data processing, you may revoke this consent at any time with effect for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.
You can contact us at any time regarding this and any other questions on the subject of data protection.
Analytics tools and tools from third-party providers
When you visit this website, your browsing behavior may be statistically evaluated. This is mainly done using analytics programs.
Detailed information about these analytics programs can be found in the following Privacy Policy.
2. Hosting and Content Delivery Networks (CDN)
Squarespace
We host our website with Squarespace Ireland Ltd., Le Pole House, Shipstreet Great, Dublin 8, Ireland (hereinafter “Squarespace”).
Squarespace is a tool for creating and hosting websites. When you visit our website, your data is processed on Squarespace’s servers. In this context, personal data may also be transferred to Squarespace’s parent company, Squarespace Inc., 8 Clarkson St, New York, NY 10014, USA. Squarespace also stores cookies that are required for displaying the site and ensuring security (necessary cookies).
We also provide our own videos via Squarespace, which are delivered via Squarespace’s servers or the associated CDN. No external video platforms such as YouTube or Vimeo are embedded.
The use of Squarespace is based on Art. 6(1)(f) GDPR. We have a legitimate interest in the most reliable presentation of our website possible. Where corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR; consent can be revoked at any time.
The data transfer to the USA is based on the European Commission’s Standard Contractual Clauses. Details can be found here: https://support.squarespace.com/hc/de/articles/360000851908-DSGVO-und-Squarespace.
Conclusion of a data processing agreement
We have concluded a data processing agreement with Squarespace. This is a contract required by data protection law that ensures Squarespace processes the personal data of visitors to our website only in accordance with our instructions and in compliance with the GDPR.
3. General information and mandatory details
Data protection
The operators of these pages take the protection of your personal data very seriously. We handle your personal data confidentially and in accordance with statutory data protection regulations and this Privacy Policy.
When you use this website, various personal data is collected. Personal data is data that can be used to personally identify you. This Privacy Policy explains what data we collect and what we use it for. It also explains how and for what purpose this takes place.
We point out that data transmission over the internet (e.g. communication by email) may have security gaps. Complete protection of the data against access by third parties is not possible.
Information on the controller
The controller responsible for data processing on this website is:
NeoPrivée GmbH
Registered office: Berlin
Managing Director: A. Meister
Schönhauser Allee 42
10435 Berlin
Germany
Phone: 017622292928
Email: mail@neoprivee.de
The controller is the natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data (e.g. names, email addresses, etc.).
Storage period
Unless a more specific storage period has been stated within this Privacy Policy, your personal data will remain with us until the purpose for data processing 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 grounds for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, deletion will take place after these reasons no longer apply.
Notice regarding data transfers to the USA and other third countries
Our website may integrate tools from companies based in the USA or other non-EU countries that are not considered secure from a data protection perspective. When these tools are active, your personal data may be transferred to and processed in such third countries. We point out that in these countries no data protection level comparable to that in the EU can be guaranteed. For example, US companies are obliged to hand over personal data to security authorities, without you as the data subject being able to effectively take legal action against this. It can therefore not be ruled out that US authorities (e.g. intelligence services) process, evaluate and permanently store your data located on US servers for monitoring purposes. We have no influence on these processing activities.
Revoking your consent to data processing
Many data processing operations are only possible with your explicit consent. You may revoke any consent you have already given at any time. The lawfulness of the data processing carried out up to the time of revocation remains unaffected by the revocation.
Right to object to data collection in special cases and to direct marketing (Art. 21 GDPR)
IF THE DATA PROCESSING IS BASED ON ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT AT ANY TIME, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENSE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).
IF YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT MARKETING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).
Right to lodge a complaint with the competent supervisory authority
In the event of breaches of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged infringement. The right to lodge a complaint is without prejudice to any other administrative or judicial remedies.
Right to data portability
You have the right to have data that we process on the basis of your consent or in performance of a contract handed over to you or to a third party in a commonly used, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done where technically feasible.
Access, deletion and rectification
Within the framework of the applicable legal provisions, you have the right at any time to obtain free information about your stored personal data, its origin, recipients and the purpose of the data processing and, if necessary, a right to rectification or deletion of this data. You can contact us at any time for this and for further questions on the subject of personal data.
Right to restriction of processing
You have the right to request the restriction of the processing of your personal data. You can contact us at any time regarding this. The right to restriction of processing exists in the following cases:
- If you contest the accuracy of the personal data we hold about you, we usually need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
- If the processing of your personal data was/ is unlawful, you may request the restriction of data processing instead of deletion.
- If we no longer need your personal data, but you need it for the establishment, exercise or defense of legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
- If you have lodged an objection pursuant to Art. 21(1) GDPR, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.
If you have restricted the processing of your personal data, such data—apart from its storage—may only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.
Objection to promotional emails
The use of contact details published as part of the legal notice obligation for the purpose of sending unsolicited advertising and information material is hereby rejected. The operators of these pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, such as spam emails.
4. Data collection on this website
Cookies
Our websites use so-called “cookies”. Cookies are small text files that do not cause any damage to your end device. They are either stored temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your device. Session cookies are automatically deleted after your visit. Permanent cookies remain stored on your device until you delete them yourself or your web browser deletes them automatically.
In some cases, cookies from third-party companies may also be stored on your device when you enter our site (third-party cookies). These enable us or you to use certain services of the third-party company (e.g. cookies for processing payment services).
Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. shopping cart functions or displaying videos). Other cookies are used to evaluate user behavior or display advertising.
Cookies that are required to carry out the electronic communication process (necessary cookies), to provide certain functions you have requested (functional cookies, e.g. for the shopping cart function) or to optimize the website (e.g. cookies to measure the web audience) are stored on the basis of Art. 6(1)(f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing cookies for the technically error-free and optimized provision of its services. Where consent to the storage of cookies has been requested, the relevant cookies are stored exclusively on the basis of this consent (Art. 6(1)(a) GDPR); consent can be revoked at any time.
You can set your browser to inform you about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies in certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited.
Where cookies from third-party companies or for analysis purposes are used, you will be informed separately about this within this Privacy Policy and, if necessary, consent will be requested.
Inquiry by email or telephone
If you contact us by email or telephone, your inquiry including all resulting personal data (name, inquiry) will be stored and processed by us for the purpose of handling your request. We do not pass on this data without your consent.
The processing of this data is based on Art. 6(1)(b) GDPR, if your request is related to the performance of a contract or is necessary for taking steps prior to entering into a contract. In all other cases, the processing is based on our legitimate interest in the effective processing of inquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR), where requested.
The data you send to us via contact inquiries will remain with us until you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. once your request has been fully processed). Mandatory statutory provisions—particularly statutory retention periods—remain unaffected.
5. Newsletter
Newsletter data
If you would like to receive the newsletter offered on the website, we require an email address from you as well as information that allows us to verify that you are the owner of the specified email address and that you agree to receive the newsletter. No further data is collected, or only on a voluntary basis. We use this data exclusively for sending the requested information and do not pass it on to third parties.
The processing of the data entered in the newsletter registration form is based exclusively on your consent (Art. 6(1)(a) GDPR). You can revoke your consent to the storage of the data, the email address and its use for sending the newsletter at any time, for example via the “unsubscribe” link in the newsletter. The lawfulness of the data processing already carried out remains unaffected by the revocation.
The data you provide for the purpose of receiving the newsletter will be stored by us until you unsubscribe from the newsletter with us or the newsletter service provider and deleted from the newsletter distribution list after you cancel the newsletter or once the purpose no longer applies. We reserve the right to delete or block email addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest in accordance with Art. 6(1)(f) GDPR.
After you unsubscribe from the newsletter distribution list, your email address may be stored by us or the newsletter service provider in a blacklist in order to prevent future mailings. The data from the blacklist is used only for this purpose and is not merged with other data. This serves both your interest and our interest in complying with statutory requirements for newsletter dispatch (legitimate interest within the meaning of Art. 6(1)(f) GDPR). Storage in the blacklist is not time-limited. You may object to this storage if your interests outweigh our legitimate interest.
6. Plugins and tools
Google Ads Conversion Tracking & Enhanced Conversions
We use “Google Ads” on our website, a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. In this context, we use so-called conversion tracking. If you reach our website via an ad placed by Google, a cookie for conversion tracking is set, provided you have given your consent via the cookie banner.
With the help of conversion tracking, we can see which actions users perform after clicking on an ad (e.g. submitting a form). Storage and processing are carried out exclusively on the basis of your consent pursuant to Art. 6(1)(a) GDPR.
We also use Enhanced Conversions. In this context, data you enter as part of a conversion (e.g. email address or telephone number) can be used to assign conversions more accurately to specific ads. Before being transmitted to Google, the data is hashed using the SHA-256 procedure and cannot be directly assigned to a person by Google.
The data processing may also take place on servers in the USA. For this transfer, the European Commission’s Standard Contractual Clauses and additional protective measures implemented by Google apply. For more information, please refer to Google’s privacy policy: https://policies.google.com/privacy.
You can revoke your consent at any time via the cookie settings dialog on our website.
Google Web Fonts (local hosting)
This site uses so-called web fonts provided by Google for the uniform display of fonts. Google Fonts are installed locally. No connection to Google’s servers is established in this context.
Further information on Google Web Fonts can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://policies.google.com/privacy?hl=en.
Google Maps
This site uses the Google Maps map service. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
To use the functions of Google Maps, it is necessary to store your IP address. This information is usually transferred to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer. When Google Maps is activated, Google may use Google Web Fonts for the uniform display of fonts. When you access Google Maps, your browser loads the required web fonts into your browser cache in order to display texts and fonts correctly.
The use of Google Maps is in the interest of an appealing presentation of our online offers and easy findability of the locations indicated on the website. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR. Where corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR; consent can be revoked at any time.
The data transfer to the USA is based on the European Commission’s Standard Contractual Clauses. Details can be found here: https://privacy.google.com/businesses/gdprcontrollerterms/ and https://privacy.google.com/businesses/gdprcontrollerterms/sccs/.
More information on how user data is handled can be found in Google’s privacy policy: https://policies.google.com/privacy?hl=en.
Source: e-recht24.de