Privacy Policy

I. Introduction

Wholesome Health GmbH operates the app "cyclio". The app accompanies menstruating people with the aim of preventing and alleviating menstrual cramps in a natural way without medication.

It is very important to us to give our users a protected space and to ensure their privacy. For this reason, we make every effort to comply with the requirements of the GDPR.

In the following, we explain to you how we process your data on our website and when you use the app. To do this, we use the clearest and most transparent language possible so that you really understand what happens with your data.

II. What you should know

1. Processing of personal data and other terms

Data protection applies to the processing of personal data. Personal data means all data with which you can be personally identified. This is, for example, the IP address of the device (PC, laptop, smartphone, etc.) in front of which you are currently sitting. Such data is processed when 'something happens to it'. Here, for example, 'the IP' of 'your browser' is transmitted to our provider and stored there automatically. This is then a processing (according to Art. 4 No. 2 DSGVO) of personal data (according to Art. 4 No. 1 DSGVO).

You can find these and other legal definitions in Art. 4 DSGVO.

2. Applicable regulations/laws - DSGVO, BDSG and TTDSG.

The scope of data protection is regulated by laws. In this case, these are the DSGVO (Basic Data Protection Regulation) as a European regulation and the BDSG (Federal Data Protection Act) as a national law.

In addition, the TTDSG supplements the regulations from the DSGVO as far as the use of cookies is concerned.

3. The responsible party

The person responsible for data processing on this website is the controller within the meaning of the DSGVO. In this case, this is:

Wholesome Health GmbH, Urbanstraße 71, 10967 Berlin.

Insofar as you have further questions or suggestions following this summary, you will find the exact contact information in the next section.

4. How data is processed on this website

As we have already stated, there are data (e.g. IP address) that are automatically collected. These data are mainly needed for the technical provision of the homepage. If we use additional personal data or collect other data, we will inform you about it or ask for your consent.

You consciously provide us with other personal data. This happens, for example, when you become or are a user of the app. Without your personal data, the functions of the app cannot be displayed.

You will find detailed information on this below.

5. These are your rights

The GDPR provides you with comprehensive rights. These are, for example, the free information about the origin, recipient and purpose of your stored personal data. You can also request the correction, blocking or deletion of this data or complain to the competent data protection supervisory authority. You can revoke your consent at any time.

How these rights look in detail and how you can easily exercise them can be found in the last section.‍

III. We also want to share this with you

1. Data protection – our view

For us, data protection is more than just an annoying duty! Personal data is of great value and careful handling of this data should be a matter of course in our digitalized world. In addition, as a website visitor or app user, you should be able to decide for yourself what "happens" to your data. Therefore, we commit ourselves to comply with all legal requirements, collect only the data that is necessary for us and, of course, treat it confidentially.

2. Disclousre and deletion

The transfer and deletion of data are also important and sensitive issues. Therefore, we would like to briefly inform you in advance about our general approach to this.

Data is only passed on on the basis of a legal basis and only if this is unavoidable. This may be the case, in particular, if it is a so-called processor and a contract processing agreement has been concluded in accordance with Art. 28 DSGVO.

We will delete your data when the purpose and the legal basis for processing cease to apply and there are no other legal obligations to the deletion. A 'good' overview of this is also provided by Art. 17 DSGVO.

For all further information, please refer to this privacy policy and contact the responsible person if you have specific questions.

3. Responsibility

Responsible for data processing on this website is the controller in the sense of the DSGVO. This is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

You can reach the controller at:

Wholesome Health Ltd.

Urbanstraße 71

10967 Berlin

dataprotection@cyclio.app

4. Hosting

This website is hosted externally. The personal data collected on this website is stored on the host's servers. This includes the automatically collected and stored log files (see below for more details), as well as all other data provided by website visitors and (test) users.

External hosting is used for the purpose of secure, fast and reliable provision of our website and in this context serves the fulfillment of contracts with our potential and existing users.

The legal basis for the processing is Art. 6 para. 1 lit. a), b) and f) DSGVO, as well as Section 25 para. 1 TTDSG, insofar as consent includes the storage of cookies or access to information in the terminal device of the website visitor or user as defined by the TTDSG.

Our host only processes data that is necessary for the fulfillment of its service obligation and acts as our order processor, which means that it is subject to our instructions. We have concluded a corresponding contract on commissioned processing in compliance with the new standard contractual clauses with our host.

We use the following host:

GoDaddy.com, LLC
Corporate Headquarters
2155 E. GoDaddy Way
Tempe, AZ 85284 USA

privacy@godaddy.com

5. Legal basis

The processing of personal data always requires a legal basis. The GDPR provides for the following possibilities in Art. 6 (1) sentence 1:

a. The data subject has given consent to the processing of personal data concerning him or her for one or more specific purposes;

b. Processing is necessary for the performance of a contract to which the data subject is party or in order to carry out pre-contractual measures at the data subject's request;

c. The processing is necessary for compliance with a legal obligation to which the controller is subject;

d. The processing is necessary in order to protect the vital interests of the data subject or another natural person;

e. Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

f. Processing is necessary for the purposes of the legitimate interests of the controller or a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data, in particular where the data subject is a child.

In the following sections, we will provide you with the specific legal basis for the processing in question.

IV. What happens on our website

When you visit our website, we process your personal data.

To protect this data in the best possible way against unauthorized access by third parties, we use SSL or TLS encryption (https://www.cyclio.app). You can recognize this encrypted connection by the fact that a https:// or a lock symbol is displayed in the address bar of your browser.

In the following, you will find out what data is collected when you visit our website, for what purpose this is done and on what legal basis.

1. Data collectioon when visiting the website

By visiting up the website, information is automatically stored in so-called server log files. This information is as follows:

  • Browser type and browser version
  • Operating system used
  • Referrer URL
  • Host name of the accessing computer
  • Time of the server request
  • IP address

This data is temporarily required in order to be able to display our website permanently and without problems. In particular, this data serves the following purposes:

  • System security of the website
  • System stability of the website
  • Troubleshooting on the website
  • Establishing a connection to the website
  • Presentation of the website

The data processing is carried out in accordance with Art. 6 para. 1 lit. f) DSGVO and is based on our legitimate interest in processing this data, in particular our interest in the functionality of the website as well as its security.

If possible, this data is stored pseudonymously and deleted after the respective purpose has been achieved.

Insofar as the server log files allow the identification of the person concerned, the data will be stored for a maximum period of 14 days. An exception exists if a security-relevant event occurs. In this case, the server log files are stored until the elimination and final clarification of the security-relevant event.

For the rest, a consolidation with other data does not take place.

2. Cookies

- General

This website uses so-called cookies. This is a data record, information that is stored in the browser of your terminal device and is related to our website.

By setting cookies, the visitor can in particular facilitate the navigation of the website.

In our cookie consent tool, you will find all information about the cookies that we use on our website (if necessary, after your consent).

- Reject cookies

You can manage all cookies that are not technically necessary directly via our cookie consent banner.

In addition, you can prevent cookies from being set by adjusting the settings of your browser.

Here you can find the corresponding links to frequently used browsers:

Mozilla Firefox: https://support.mozilla.org/de/kb/cookies-und-website-daten-in-firefox-loschen?redirectslug=Cookies+l%C3%B6schen&redirectlocale=en

Google Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=de

Microsoft Edge: https://support.microsoft.com/de-de/windows/l%C3%B6schen-und-verwalten-von-cookies-168dab11-0753-043d-7c16-ede5947fc64d

Safari: https://support.apple.com/de-de/guide/mdm/mdmf7d5714d4/web and https://support.apple.com/de-de/guide/safari/sfri11471/mac

As far as you use another browser, it is recommended to delete the name of your browser unc cookies, enter it into a search engine and follow the official link to your browser.

Alternatively, you can manage your cookie settings at www.aboutads.info/choices/ or www.youronlinechoices.com.

Wir müssen Dich allerdings darauf hinweisen, dass eine umfassende Blockierung/Löschung von Cookies zu Beeinträchtigungen bei der Nutzung der Website führen kann.

- Technically necessary cookies

We use technically necessary cookies on this website to ensure that our website functions without errors and in accordance with applicable laws. You help to make the website user-friendly. Some functions of our website cannot be displayed without the use of cookies.

The legal basis for this is Art. 6 para. 1 lit. b), c) and f) DSGVO.

- Technically unnecessary cookies

In addition, we also use cookies on our website that are not technically necessary. These cookies are used, among other things, to analyze the surfing behavior of the website visitor or to offer website functions that are, however, not technically necessary.

The legal basis for this is your consent in accordance with Art. 6 para. 1 lit. a) DSGVO.

Technically unnecessary cookies are only set with your consent, which you can revoke at any time in the cookie consent banner.

3. Analysis and tracking tools

Google Analytics 

This website uses Google Analytics. This service is offered by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland), hereinafter referred to as Google, and is used to analyze website usage by the respective user.

Google uses cookies that enable an analysis of the website usage by the respective user. These cookies are only used if you have consented to their use in our cookie consent banner. You can revoke your consent at any time via the consent banner.

The collected information is usually sent to a Google server in the USA and also stored there.

The legal basis for the processing is thus consent according to Art. 6 para. 1 lit. a) DSGVO.

Through the use of Google Analytics, IP anonymization takes effect. The IP address of the respective user is shortened within the member states of the EU (or the European Economic Area) in such a way that it is no longer possible to trace it back to a natural person. In addition, Google undertakes to ensure appropriate data protection via the Google Ads data processing terms and conditions and compiles an evaluation of website use and website activity and provides the services associated with use. The Google Ads Data Processing Terms apply to companies subject to the European Economic Area (EEA) EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), or similar regulations.

By using an additional browser plugin, you can prevent the collected information (such as your IP address) from being sent to and used by Google. You can find the plugin and more information about it at https://tools.google.com/dlpage/gaoptout?hl=de.

Otherwise, the storage period depends on the type of data processed. Each customer can choose how long Google Analytics stores data before it is automatically deleted.

You can also find more information about Google's use of data at https://support.google.com/analytics/answer/6004245?hl=de. For all other inquiries, you can also contact us directly at support-deutschland@google.com.

4. Data processing through user input

- Contact us

E-Mail

If you contact us by email, we will process your e-mail address and any other data contained in the e-mail. These are stored on the mail server and partly on the respective end devices. Depending on the request, the legal basis for this is regularly Art. 6 para. 1 lit. f) DSGVO or Art. 6 para. 1 lit. b) DSGVO. The data will be deleted as soon as the respective purpose ceases to apply and it is possible according to the legal requirements.

- Newsletter registration - Mailchimp

We use Mailchimp of Rocket Science Group (LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA) to provide you with our newsletter.

So that we can inform you about all news, we offer the possibility to register for our newsletter. For this registration we need your e-mail address. With this we will then verify via a so-called double opt-in process that you have personally entered your email address and that you actually want to receive the newsletter. Subsequently, there is the possibility in each newsletter to unsubscribe again.

Mailchimp stores your IP address after registration and the time of registration and confirmation to document your consent. When you unsubscribe from the newsletter, the data is deleted.

Mailchimp also evaluates performance data, such as the delivery statistics of e-mails and other communication data. This information is used to send you emails and to enable certain other Mailchimp functions (e.g. evaluation of the newsletter). This in turn allows us to customize the newsletter to your needs and improve the service.

Mailchimp uses cookies to ensure the security and reliability of the systems, compliance with the terms of use and the prevention of abuse. These cookies are only used when you sign up for the newsletter.

These cookies may collect, among other things, the following data: Information about your terminal device (IP address, device information, operating system, browser ID, information about the application you use to read your emails and other information about hardware and internet connection. In addition, usage data is collected such as date and time, when you opened the email/campaign and browser activity (e.g. which emails/websites were opened).

Mailchimp may also share this data with third parties or collect additional information about you from other sources. This serves to improve the Mailchimp services, but we have no influence on this process.

Mailchimp is an American company and the collected data may also be processed on US servers.

Mailchimp uses so-called standard contractual clauses according to Art. 46 DSGVO (Standard Contractual Clauses - SCC). These templates are provided by the EU Commission to ensure that your data is protected in accordance with European data protection standards when it is transferred to and stored in third countries (in this case, the USA). By doing so, Mailchimp commits to comply with the European level of data protection.

The legal basis for the processing is consent in accordance with Art. 6 (1) a) DSGVO.

The data will be deleted when the contract between us and Mailchimp ends, unless you revoke your consent beforehand. In this case, the data will be deleted with the revocation of consent.

You can also find more information at https://mailchimp.com/de/help/mailchimp-european-data-transfers/ and https://mailchimp.com/de/gdpr/. You can find out more about the use of cookies by Mailchimp and further information about data protection on these pages at https://mailchimp.com/legal/cookies/ and https://www.intuit.com/privacy/statement/.

For all other queries, you can also contact us directly at privacy@mailchimp.com.

- Google Workspace (including Google Forms)

This website uses Google Workspace. This service is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

We use Google Workspace to create surveys via online forms, store the results and send emails. Input is collected and integrated via the online forms.

This allows you to sign up for the app or contact us for a demo of the app.

By clicking on "Join the waitlist" you will be redirected to Google. The data you enter in the form will be stored on the Google Forms servers until you request deletion, revoke your consent to storage, or the purpose for storing the data no longer applies. Mandatory legal provisions regarding retention periods remain unaffected.

The use of Google Workspace is based on Art. 6 para. 1 lit. b DSGVO.

Further details:
https://policies.google.com/


- Typeform

On our website we use Typeform. This is a service provided by TYPEFORM SL, C/Bac de Roda, 163, 08018 Barcelona, Spain, to create online forms and online surveys.

This service allows us to create and embed online forms to collect messages, requests or other input for our website.

Typeform receives the information you provide in the form on our website. We have concluded an order processing agreement with Typeform in accordance with Art. 28 DSGVO.

Typeform sets cookies for data collection and storage on our website. These cookies are only set with your consent. You can revoke this consent at any time. The legal basis for this is Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG, insofar as this consent includes access to information in the user's terminal device or the storage of cookies as defined by the TTDSG.

Furthermore, the legal basis for the use of Typeform is Art. 6 para. 1 lit. f DSGVO. We have a legitimate interest in creating online forms and integrating them in a functioning manner on our website. Insofar as the data processing via the form serves the provision of our contractual services, the legal basis is Art. 6 para. 1 lit. b DSGVO.

The data you enter in the form will be stored on Typeform's servers until you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies. Mandatory legal provisions regarding retention periods remain unaffected.

You can find more information about Typeform's data processing here:

https://admin.typeform.com/to/dwk6gt/.

5. Third-party content

- Cloudfront.net

Our website uses Cloudfront.net. This is a content delivery network from Amazon (Amazon Europe Core S.à r.l. (Société à responsabilité limitée), 5 Rue Plaetis, L-2338, Luxembourg).

Cloudfront.net uses cookies to load images and videos on the website, and display them accordingly. The service is technically necessary for the website to function without errors and in accordance with applicable laws.

The legal basis for the processing is Art. 5 para. 1 p. 1 lit. f) DSGVO.

The information collected here is regularly stored on servers in the EU, but may, depending on the specific use, be sent to Amazon servers in other countries and also stored there.

The data is deleted at the latest as soon as it is no longer required for the purposes of processing.

You can find more details about the processing of personal data by Amazon at: https://aws.amazon.com/privacy/.

- Google reCAPTCHA

This website uses Google reCAPTCHA. Google reCAPTCHA is a plugin offered by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

The service makes it possible to determine whether a data entry is made by a human or by an automated program. This analysis begins automatically in the background as soon as the website is entered. For this purpose, various information is collected, which is transmitted to Google. A reference to this analysis does not take place.

The legal basis for the processing is Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG. The consent can be revoked at any time.

You can find more details here:

https://policies.google.com/privacy?hl=de https://policies.google.com/terms?hl=de.

- Zapier

We use Zapier on this website. Zapier is a tool to synchronize different services with each other. This service is provided by Zapier Inc, Market St. #62411, San Francisco, CA 95104-5401, USA.

With the help of Zapier, it is possible to automatically play out content from a website on the associated social media channels. Here, depending on the function of Zapier, different personal data are processed.

The legal basis for the processing is Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG. The consent can be revoked at any time.

In the case of data transfer to the USA, the standard contractual clauses (SCC) of the EU Commission apply.

https://zapier.com/tos

https://zapier.com/privacy/

6. Other external service providers

- Cookie-Consent-Tool (Cookiebot)

This website uses Cookiebot. Cookiebot is a consent tool. This service is provided by Cybot A/S, havnegade 39, 1058 Copenhagen, Denmark.

We use this service to obtain the website visitor's consent to the storage of certain cookies in his browser or the use of certain technologies and to document it in a privacy-compliant manner.

When this website is called up, the consent given by the website visitor or the revocation of consent is stored as a Cookiebot cookie in the browser of the website visitor. For this purpose, a connection is established to the servers of Cookiebot.

Until the website visitor requests the operator to delete the data or deletes Cookiebot itself or the purpose for storing the data no longer applies, the collected data will be stored. This does not affect the mandatory statutory retention periods.

The legal basis is Art. 6 para. 1 lit. c DSGVO. Cookiebot is used to obtain the legally required consent for the use of cookies.

- Google Tag Manager

We use Google Tag Manager on this website. This is a tag management system for managing JavaScript and HTML tags used to implement tracking and analysis tools.

The legal basis for the processing is Art. 6 para. 1 p. 1 lit. f) DSGVO.

This service is offered by Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland and is used to monitor system stability and performance. For this purpose, Google Tag Manager may collect some aggregate data about the triggering of tags. This data does not contain user IP addresses or user-specific identifiers that could be assigned to a specific person.

Further information on Google's data protection can be found here: https://policies.google.com/privacy?hl=en

- Website construction kit system (Webflow)

We use Webflow by Webflow, Inc (398 11th St, San Francisco, CA 94103, USA) to manage the content of our website. As a content management system, Webflow offers easy structuring of our website and is based on state-of-the-art technologies. This allows us to customize our website exactly to the functions and presentation we need.

Webflow uses cookies for browsing security and to prevent cross-site request forgery (session cookies), as well as for secure transactions on the website. You can find more information about Webflow's cookies and how long personal data is stored in our Cookie Consent Tool.

The service is technically necessary for the website to function without errors and in accordance with applicable laws.

The legal basis for the processing is Art. 5 para. 1 p. 1 lit. f) DSGVO.

Since Webflow is an American company, the collected data could also be processed on US servers. We have concluded standard contractual clauses with Webflow.

7. Third party websites

We use links to third-party websites to make it easier for you to use these external services or to get further information. Currently, you can reach the services of Instagram and LinkedIn via a link from our website.

When you click on the link, no data collected by us is transmitted to the corresponding providers. However, we have no influence on the data processing on the respective website to which you are redirected. Here, these services may collect, forward or otherwise process data from you. Please take note of the data protection statements applicable on these sites in order to understand how your data is processed there.

For our presence in social networks, the data protection provisions of the respective providers apply.

The currently valid privacy policies of these services can be found at https://help.instagram.com/519522125107875/?helpref=hc_fnav, https://de.linkedin.com/legal/privacy-policy and https://calendly.com/privacy.

V. What happens in our app

1. Data processing in the app

You can register with us as a user of the app after prior invitation to take advantage of our offer. In this case, you will receive accupressure and yoga exercises tailored to your individual needs to regulate your menstrual cramps.

The data will be stored exclusively for the purpose of assessing your menstrual cramps and subsequent care.

For this purpose, we ask you to provide the following data:

Name

E-mail address

Birthday

Type of menstrual cramps

Details of menstruation

Details of hormonal contraception

Details regarding gynecological diseases.

The legal basis for the processing is Art. 6 para. 1 p. 1 lit. b) DSGVO.

2. Google Firebase

We use Google Firebase in the app as an analysis and monitoring tool. This service is offered by Google Ireland Limited, Gordon House, Barrow Street Dublin 4, Ireland.
Firebase mostly processes so-called "instance IDs", which are provided with a timestamp. These IDs are assigned to a specific user and allow different events or processes to be linked. This is used to analyze and optimize user behavior, for example by evaluating crash reports.

Google Firebase uses cookies to analyze user behavior. These cookies are only set with your consent. You can revoke and manage your consent at any time in our cookie consent tool.

The legal basis for the processing is Art. 6 (1) lit. a DSGVO and Section 25 (1) TTDSG, as it involves accessing information in the user's terminal device or storing cookies as defined by the TTDSG.

You can find more information on data processing here:
https://policies.google.com/privacy

3. Bravo Studio

The app uses the service Bravo Studio, from the company App Foundry SL, Career Pamplona 88-90, Barcelona, Spain.

The service is a frontend builder that embeds the results of our design builder Figma on the website.

Bravo Studios uses cookies to adapt the display to your usage behavior. These cookies are only set with your consent. You can revoke and manage your consent at any time in our cookie consent tool.

The legal basis for the processing is Art. 6 (1) lit. a DSGVO and Section 25 (1) TTDSG, insofar as it concerns access to information in the user's terminal device or the storage of cookies as defined by the TTDSG.

In addition, the use of Bravo Studios is based on Art. 6 para. 1 lit. f DSGVO. We have a legitimate interest in the correct display of our designs in the frontend of the app.

You can find more information about data processing here:
https://www.bravostudio.app/privacy

4. Xano

The app uses Xano. This is a service provided by Xano Inc, 20700 Ventura Blvd Ste 210 Woodland Hills, CA 91364.

This is a database service that we use as a backend builder and database.

Xano uses cookies to personalize and analyze your user experience and improve the service. These cookies are only set with your consent. You can revoke and manage your consent at any time in our cookie consent tool.

The legal basis for the processing is Art. 6 (1) lit. a DSGVO and Section 25 (1) TTDSG, insofar as it concerns access to information in the user's terminal device or the storage of cookies as defined by the TTDSG.

Furthermore, the use of Bravo Studios is based on Art. 6 para. 1 lit. f DSGVO. We have a legitimate interest in the correct display of our designs in the frontend of the app.

Xano also processes data in the USA.

You can find more information about data processing here:
https://legal.xano.com/privacy-policy

5. Make

In the app, we integrate the make automation service. This is a service provided by Celonis, Inc, One World Trade Center, 87th floor, New York, NY, 10007, USA.

Using this service, we can connect applications and APIs to automate and optimize our workflows.

The legal basis for the processing is Art. 6 (1) lit. f DSGVO.

Data transfer to the USA cannot be ruled out. We have concluded standard contractual clauses with make to ensure an appropriate level of data protection.

You can find more information about data processing by make here:
https://www.make.com/en/privacy-notice

6. OneSignal

The app uses OneSignal, a customer engagement platform for businesses. This service is provided by OneSignal, Inc, 2850 S Delaware St Suite 201, San Mateo, CA 94403.

We use OneSignal's push notification service. This involves personalizing and automating push notifications through the use of first-party data.

OneSignal uses cookies to track users across websites or associate users with mobile IDs. These cookies are only set with your consent. You can revoke and manage your consent at any time in our Cookie Consent Tool.

The legal basis for the processing is Art. 6 (1) lit. a DSGVO and Section 25 (1) TTDSG, insofar as it concerns access to information in the user's terminal device or the storage of cookies as defined by the TTDSG.

Furthermore, the use of Bravo Studios is based on Art. 6 para. 1 lit. f DSGVO. We have a legitimate interest in improving customer relations through the use of push notifications.

OneSignal processes data in the USA, among other places.

You can find more information about data processing here:

https://onesignal.com/privacy_policy

7. Google Analytics

In our app, we use Google Analytics. Google Analytics is a web analytics service. This service is provided by Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics uses cookies for the following purpose: to recognize the user and thus analyze usage behavior. These cookies are only set with your consent. You can revoke your consent at any time and manage it in our cookie consent tool.

The legal basis for the processing is Art. 6 para. 1 lit. a DSGVO and § 25 para. 1 TTDSG.

As a rule, the collected information is transferred to a Google server in the USA and stored.

The standard contractual clauses (SCC) of the EU Commission apply to data transfer to the USA.

Otherwise, the storage period depends on the type of data processed. Each customer can choose how long Google Analytics stores data before it is automatically deleted.

You can also find more information about Google's data usage at https://support.google.com/analytics/answer/6004245?hl=de. For all other queries, you can also contact support-deutschland@google.com directly.

8. SendinBlue

In the app, we use Sendinblue. Sendinblue is a service for sending newsletters and email notifications. This service is offered by Mailgun Technologies Inc, 112E Pecan Sr. '#1135, San Antonia, Texas 78205, USA.

Through this service, the sending of newsletters and notifications can be organized and analyzed. The data entered for this purpose is stored on Sendinblue's servers in Germany.

With the help of Sendinblue, interactions with the newsletter and notifications can be analyzed and conversion rates can be determined. Users can be categorized to reach different target groups.

This analysis can be objected to.

The legal basis for the processing is Art. 6 para. 1 lit. a DSGVO. Consent can be revoked at any time by unsubscribing from the newsletter or notifications. The legality of the processing already carried out remains unaffected by any revocation.

The data remains stored by the website operator or the newsletter operator until the newsletter is unsubscribed. If this is the case, the data will be deleted from the distribution list.

Further details:https://de.sendinblue.com/datenschutz-uebersicht/.

VI. What else is important

Finally, we would like to inform you in detail about your rights and how you will be informed about changes in data protection requirements.

1. Your rights in detail

a. Right to information according to Art. 15 DSGVO

You can request information about whether your personal data is being processed. If this is the case, you can request further information about the type and manner of processing. A detailed list can be found in Art. 15 (1) a) to h) DSGVO.

b. Right to rectification according to Art. 16 DSGVO

This right includes the correction of incorrect data and the completion of incomplete personal data.

c. Right to erasure according to Art. 17 DSGVO

This so-called 'right to be forgotten' gives you the right, under certain conditions, to request the deletion of personal data by the controller. This is basically the case if the purpose of the data processing has ceased to exist, if consent has been revoked or if the initial processing took place without a legal basis. You can find a detailed list of reasons in Art. 17 (1) a) to f) DSGVO. Furthermore, this "right to be forgotten" corresponds with the controller's obligation under Art. 17(2) DSGVO to take reasonable measures to bring about a general erasure of the data.

d. Right to restriction of processing according to Art. 18 DSGVO

This right is subject to the conditions set out in Art. 18(1)(a) to (d).

e. Right to data portability according to Art. 20 DSGVO

This regulates the basic right to receive one's own data in a common form and to transfer it to another responsible party. However, this only applies to the data of a processing based on consent or contract according to Art. 20 (1) a) and b) and as far as this is technically feasible.

f. Right of objection according to Art. 21 DSGVO

In principle, you can object to the processing of personal data. This applies in particular if your interest in objecting outweighs the legitimate interest of the controller in the processing and if the processing relates to direct marketing and/or profiling. 

g. Right to "decision in individual cases" according to Art. 22 DSGVO

In principle, you have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you. However, this right is also subject to restrictions and additions in Art. 22 (2) and (4) DSGVO.

h. Further rights

The GDPR includes comprehensive rights to inform third parties whether or how you have asserted rights under Art. 16, 17, 18 GDPR. However, this only applies insofar as it is possible or feasible with a reasonable effort.

At this point, we would like to inform you once again of your right to withdraw your consent in accordance with Article 7 (3) of the GDPR. The lawfulness of the processing carried out up to that point will not be affected by this.

In addition, we would like to inform you about your rights according to §§ 32 ff. BDSG, which, however, are largely congruent with the rights just described.

i. Right of appeal according to Art. 77 DSGVO

You also have the right to complain to a data protection supervisory authority if you believe that processing of the personal data in question violates this Regulation.

VI. What if tomorrow the GDPR is abolished or other changes take place?

The current status of this Privacy Policy is February 2023. As soon as we change this Privacy Policy, we will inform you about it on our website.