This Application collects some Personal Data from its Users.
Owner and Data Controller
Isil Uysal Calvelli
Rushaimerstr. 11 80689 Muenchen
Types of Data collected
- Contact information (Name, Surname, E-mail).
- Content (e.g. Text, comments, photos and videos).
- Usage data (e.g. visited websites, interest in content, time of visits).
- Meta-/Communication data (e.g. Device information, IP- Addresses).
The Purpose of Data Collection
- The data collected is mandatory to provide the online service, the functions and the content
- To answer contact requests and to communicate with the users and visitors
- For security measures.
- For research purposes such as measuring the online audience and efficiency of communication/ marketing efforts
Explanation of terms
“Personal data”means any information relating to an identified or identifiable natural person (hereinafter the “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term goes far and includes virtually every handling of data.
“Pseudonymisation” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person;
“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;
“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.
“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
Relevant legal bases
We implement appropriate technical and organisational measures to ensure a level of protection appropriate to the risk in accordance with Art. 32 GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons.
Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as controlling their access, input, disclosure, ensuring availability and separation. We have also set up procedures to ensure the exercise of data subject rights, data deletion and reaction to data vulnerability. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings (Article 25 GDPR).
Collaboration with processors and third parties
If, in the context of our processing, we disclose data to other persons and companies (processors or third parties), transmit data to them or otherwise grant access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, as required by payment service providers, pursuant to Art. 6 (1) (b) GDPR to fulfil the contract), on the basis your consent that you have provided, to fulfil a legal obligation or based on our legitimate interests (e.g the use of agents, Web hosting companies, etc.).
If we commission third parties to process data on the basis of a so-called “data processing agreement”, this is done on the basis of Art. 28 GDPR.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done if it is to fulfil our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of Art. 44 et seq. of GDPR. That the processing is e.g. on the basis of specific guarantees, such as the officially recognised level of data protection (e.g. for the US through the Privacy Shield) or compliance with officially recognised special contractual obligations (so-called “standard contractual clauses”).
Rights of Data Subjects
You have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.
You have the right accordingly. Art. 16 GDPR to demand the completion or the correction of the data concerning you.
In accordance with Art. 17 GDPR, you have the right to demand that the relevant data be deleted immediately or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 GDPR.
You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 GDPR and request their transfer to other controllers.
You have according to Art. 77 DSGVO the right to file a complaint with the competent supervisory authority.
Right to Withdraw
You have the right to withdraw the consent given with effect for the future according to Art. 7 Abs. 3 GDPR.
Right to Object
You can object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection may in particular be made against processing for direct marketing purposes.
Cookies und Right to Object to Direct Marketing
“Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, e.g. the contents of a shopping cart in an online shop or a login status are saved. The term “permanent” or “persistent” refers to cookies that remain stored even after the browser has been closed. Thus, e.g. the login status will be saved if users visit it after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for audience measurement or marketing purposes. A “third-party cookie” refers to cookies that are offered by providers other than the person who manages the online offer (otherwise, if it is only their cookies, this is called “first-party cookies”).
If users do not want cookies stored on their computer, they will be asked to disable the option in their browser’s system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
Deletion of Data
According to legal requirements in Germany, the storage takes place in particular for 10 years according to §§ 147 Abs. 1 AO, 257 Abs. 1 Nr. 1 and 4, Abs. 4 HGB (books, records, management reports, accounting documents, trading books, relevant for taxation Documents, etc.) and 6 years in accordance with § 257 (1) no. 2 and 3, para. 4 HGB (commercial letters).
Business Related Data Processing
In addition, we process
– contract data (e.g., contract subject, term, customer category).
– Payment data (e.g., bank details, payment history, billing address )
from our customers, prospects and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
We process the data of our contractual partners and interested parties as well as other clients, customers, clients, clients or contractual partners (uniformly referred to as “contractual partners”) in accordance with Art. 6 para. 1 lit. b. DSGVO in order to provide you with our contractual or pre-contractual services. The data processed, the nature, scope and purpose and necessity of their processing are determined by the underlying contractual relationship.
The processed data includes the master data of our contractual partners (eg, names and addresses), contact data (eg e-mail addresses and telephone numbers) as well as contract data (eg, services used, contract contents, contractual communication, names of contact persons) and payment data (eg, Bank details, payment history).
In principle, we do not process special categories of personal data, unless they are part of a contracted or contractual processing.
We process data which are necessary for the establishment and fulfillment of the contractual services and point out the necessity of their indication, if this is not evident for the contractual partners. Disclosure to external persons or companies will only be made if required by a contract. When processing the data provided to us within the framework of an order, we act in accordance with the instructions of the client as well as the legal requirements.
As part of the use of our online services, we can save the IP address and the time of each user action. The storage is based on our legitimate interests, as well as the interests of the user in the protection against misuse and other unauthorized use. A transfer of these data to third parties does not take place, unless it is to pursue our claims acc. Art. 6 para. 1 lit. f. DSGVO required or there is a legal obligation in accordance with. Art. 6 para. 1 lit. c. DSGVO.
The data will be deleted if the data is no longer required for the fulfillment of contractual or statutory duties of care and for the handling of any warranty and comparable obligations, whereby the necessity of keeping the data is reviewed every three years; otherwise the statutory storage obligations apply.
Administration, Financial accounting, Office organization, Contact management
We process data in the context of administrative tasks and organization of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of rendering our contractual services. The processing principles are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. DSGVO. The processing affects customers, prospects, business partners and website visitors. The purpose and interest in processing lies in administration, financial accounting, office organization, data archiving, that is, tasks that serve to maintain our business, perform our duties and provide our services. The deletion of the data in terms of contractual performance and contractual communication corresponds to the information provided in these processing activities.
We disclose or transmit data to the financial administration, consultants, such as tax accountants or auditors, and other fee agents and payment service providers.
Furthermore, based on our business interests, we store information about suppliers, promoters and other business partners, e.g. for later contact. We generally store this majority of company-related data permanently.
Business Analysis and Market Research
In order to operate our business economically, to recognise market trends, wishes of the contractors and users, we analyse the data available to us for business transactions, contracts, inquiries, etc. we process data inventory, communication data, contract data, payment data, usage data, metadata based on the nature 6 para. 1 lit. f. GDPR, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offer.
The analyses are carried out for the purpose of business analysis, marketing and market research. In doing so, we can observe the profiles of registered users with information such as the services they use. The analysis serve us to increase the user-friendliness, the optimisation of our offer and the business economics. The analyses are for us alone and will not be disclosed externally unless they are anonymous, aggregated value analyses.
If these analyses or profiles are personal, they will be deleted or anonymised upon termination of the users, otherwise after two years from the conclusion of the contract. Incidentally, the overall business analysis and general trend provisions are created anonymously if possible.
Participation in Affiliate-Programs
Within our online offer, we rely on our legitimate interests (i.e., interest in the analysis, optimization and economic operation of our online offer) acc. Art. 6 para. 1 lit. f GDPR industry-standard tracking measures as required for the operation of the affiliate system. Below we clarify the users about the technical background.
The services offered by our contractual partners can also be advertised and linked to other websites (so-called affiliate links or after-buy systems, if, for example, links or services of third parties are offered after conclusion of a contract). The operators of the respective websites receive a commission if users follow the affiliate links and then take advantage of the offers.
In summary, our online offering requires us to be able to keep track of whether users who are interested in affiliate links and / or the offers available to us then take advantage of the offers on the affiliate links or on our online platform. For this, the affiliate links and our offers are supplemented by certain values that are part of the link or otherwise, e.g. in a cookie, can be set. The values include in particular the source website (referrer), time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking specific values such as Ad ID, affiliate ID, and categorisations.
The online user IDs used by us are pseudonymous values, meaning the online identifiers themselves do not contain personal data such as names or e-mail addresses. They only help us determine whether the same user who clicked on an affiliate link or was interested in an offer through our online offer, seized the offer, e.g. has signed a contract with the provider. However, the online identification is in this respect personal as the partner company and we have the online identification together with other user data are available to us and to the partner company. Only then the partner company tell us whether the user has accepted the offer and we, for example, can pay the bonus.
Comments und Posts
If users leave comments or other contributions, their IP addresses may be stored based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR . This is for our own safety, if someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.
Furthermore, we reserve the right, in accordance with our legitimate interests. Art. 6 para. 1 lit. f. GDPR to process the information of users for the purpose of spam detection.
The data provided in the comments and contributions are stored by us permanently until the users object.
Our online offering uses the “Akismet” service offered by Automattic Inc., 60 29th Street # 343, San Francisco, CA 94110, USA. The use is based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f) GDPR. With the help of this service, comments of real people are distinguished from spam comments. All comment information is sent to a server in the US, where it is analyzed and stored for four days for comparison. If a comment has been classified as spam, the data will be stored beyond that time. This information includes the name entered, the email address, the IP address, the comment content, the referrer, details of the browser used, the computer system and the time of the entry.
For more information about the collection and use of data by Akismet, see the Automattic Privacy Notice: https://automattic.com/privacy/.
Users are welcome to use pseudonyms, or to refrain from entering the name or email address. You can completely prevent the transfer of data by not using our commenting system. That would be a pity, but unfortunately we see no other alternatives that work equally effectively.
When the user contacts us (for example, by contact form, e-mail, telephone or via social media), the information of the user is processed for working on the contact request and its execution in accordance with. Art. 6 para. 1 lit. b) GDPR. User information can be stored in a Customer Relationship Management System (“CRM System”) or a comparable tool.
We delete the requests, if they are no longer required. We check the necessity every two years; Furthermore, the legal archiving obligations apply.
With the following information we inform you about the contents of our newsletter as well as the sign-up, sending and statistical analysis procedures as well as your right of objection. By subscribing to our newsletter, you agree to receiving our newsletters and the procedures described.
Content of the newsletter: We send newsletters, e-mails and other electronic communication with promotional information (hereinafter “newsletter”) only with the consent of the recipient or a legal permission. Insofar as the contents of a newsletter are concretely described, they are authoritative for the consent of the users. Mainly, our newsletter contains information about our services and us.
Double opt-in and logging: Registration for our newsletter is done in a so-called double-opt-in procedure. That after registration, you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. The registration for the newsletter will be logged in order to prove the registration process according to the legal requirements. This includes the storage of the login and the confirmation time, as well as the IP address. Likewise, changes to your data stored with the newsletter service provider will be logged.
Credentials: To subscribe to the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to give a name and a surname in the newsletter for addressing you personally.
The sending of the newsletter and the associated performance measurement are based on a consent of the recipients acc. Art. 6 para. 1 lit. a, Art. 7 GDPR i.V.m § 7 Abs. 2 No. 3 UWG or if consent is not required, based on our legitimate interests in the direct marketing acc. Art. 6 para. 1 lt. F. GDPR i.V.m. § 7 Abs. 3 UWG.
The logging of the registration process is based on our legitimate interests in accordance with. Art. 6 para. 1 lit. f GDPR. Our interest lies in the use of a user-friendly and secure newsletter system, which serves both our business interests and the expectations of the users and also allows us to prove our consent.
Termination / Revocation – You may terminate the receipt of our newsletter at any time, ie. Revoke your consent. A link to cancel the newsletter can be found at the end of each newsletter. We may save the submitted email addresses for up to three years based on our legitimate interests before we delete them to provide prior consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for cancellation is possible at any time, provided that at the same time the former existence of a consent is confirmed.
Newsletter – Mailchimp
The service provider may use the data of the recipients in pseudonymous form, i.e. without assignment to a user, to optimise or improve their own services, e.g. for the technical optimisation of delivery and the presentation of newsletters or for statistical purposes. However, the service provider does not use the data of our newsletter recipients to address them themselves or to pass the data on to third parties.
Newsletter – Success Measurement
The newsletters contain a so-called “web-beacon”, i. e. pixel-sized file that is retrieved from the server when opening the newsletter from our server, or if we use a service provider. This call will initially collect technical information, such as information about the browser and your system, as well as your IP address and time of retrieval.
This information is used to improve the technical performance of services based on their specifications or audience and their reading habits, based on their locations (which can be determined using the IP address) or access times. Statistical surveys also include determining if the newsletters will be opened, when they will be opened and which links will be clicked. For technical reasons, this information can be matched with the individual newsletter recipients. However, it is neither our goal nor, if used, that of the service provider’s to observe individual users. The evaluations serve us much more to recognise the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
The hosting services we use are for the purpose of providing the following services: infrastructure and platform services, computing capacity, storage and database services, security and technical maintenance services we use to operate this online service.
Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer acc. Art. 6 para. 1 lit. f GDPR i.V.m. Art. 28 GDPR (Data processing agreement).
Collection of Access Data and Log Files
We, or our hosting provider (Site Ground), collects on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR Data on every access to the server on which this service is located (so-called server log files). The access data includes name of the retrieved web page, file, date and time of retrieval, amount of data transferred, message about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider ,
Logfile information is stored for security purposes (for example, to investigate abusive or fraudulent activities) for a 6 month period and then deleted. Data whose further retention is required for evidential purposes shall be exempted from the cancellation until final clarification of the incident.
Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European privacy legislation.
Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous usage profiles of the users can be created from the processed data.
We only use Google Analytics with activated IP anonymization. This means that the IP address of the users will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.
The IP address submitted by the user’s browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users may also prevent the collection by Google of the data generated by the cookie and related to its use of the online offer and the processing of such data by Google by downloading and installing the browser plug-in available at the following link: http: // tools .google.com / dlpage / gaoptout? hl = en.
Facebook (Custom Audience Pixel)
Custom Audience Pixel, a service of Facebook Inc., (1601 S. California Ave, Palo Alto, CA 94304, USA), is a small piece of Java script code which we have integrated into all of our websites. This piece of code provides a number of functions for the sending of application specific events and user defined data to Facebook. We use Custom Audience pixels in order to record information concerning the way in which visitors use our website. This pixel records and provides Facebook with information concerning the browser setting of the user, a hashed version of the Facebook ID and the URL which is being visited. Each Facebook user thus possesses a clear and device-independent Facebook ID, whereby it is possible to address the user via more than one device on the social network Facebook and to recognise him or her, so that we can target our visitors again for advertising purposes by means of Facebook adverts. After 180 days, the user information is deleted until the visitor accesses our website again. Therefore, no personal information is disclosed to Move to Munich in relation to the individual website visitors and we can only solicit website customer target groups once the target customer group has reached a critical mass in terms of numbers. Further information concerning Facebook and its private sphere settings above and beyond the details set out can be found in the Facebook Data Usage Policy
The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads.
Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation. (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
Online Presence in Social Media
We maintain online presence within social networks and platforms in order to communicate with customers, prospects and users active there and to inform them about our services. When calling the respective networks and platforms, the terms and conditions and the data processing guidelines apply to their respective operators.
Integration of Services and Content of Third Parties
Based on our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 (1) lit. GDPR), we make use of content or services offered by third-party providers in order to provide their content and services, such as Including videos or fonts (collectively referred to as “content”).
This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as “web beacons”) for statistical or marketing purposes. The “pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and other information regarding the use of our online offer.