Privacy Policy
This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) in the context of the provision of our services and within our online offering and the websites, functions and content associated with it as well as external online presences, such as our Social Media Profile (hereinafter jointly referred to as “online offering”). With regard to the terms used, such as “processing” or “person responsible”, we refer you to the definitions in Art. 4 of the Data Protection Basic Regulation (DSGVO).
Responsible
Project-MOC
Montenegro
Email address: contact@project-moc.com
Managing Director: Frank Hoffer
Data Protection Officer: contact@project-moc.com
Types of data processed
– Inventory data (e.g., person master data, names or addresses).
– Contact data (e.g., e-mail, telephone numbers).
– Content data (e.g., text entries, photographs, videos).
– Usage data (e.g., websites visited, interest in content, access times).
– Meta/communication data (e.g., device information, IP addresses).
Categories of data subjects
Visitors and users of the online offer (hereinafter referred to collectively as “users”).
Purpose of processing
– Provision of the online offer, its functions and contents.
– Answering contact requests and communicating with users.
– Security measures.
– Range measurement/Marketing
Terms used
“personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier (e.g. a cookie) or to one or more specific characteristics which express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, is regarded as identifiable.
“processing” means any operation carried out with or without the aid of automated processes, or set of operations, involving personal data. The term is broad and covers practically every handling of data.
“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the provision of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures ensuring that the personal data are not attributed to an identified or identifiable natural person.
“Profiling” means any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to the work performance, economic situation, health, personal preferences, interests, reliability, conduct, whereabouts or movements of that natural person.
The “controller” is 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.
Applicable legal bases
In accordance with Art. 13 DSGVO we inform you about the legal basis of our data processing. For users from the area of application of the data protection basic regulation (DSGVO), i.e. the EU and the EEC, the following applies, if the legal basis is not mentioned in the data protection explanation:
The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 DSGVO;
The legal basis for the processing for the fulfilment of our services and the implementation of contractual measures as well as the answering of inquiries is Art. 6 para. 1 lit. b DSGVO;
The legal basis for the processing for the fulfilment of our legal obligations is Art. 6 para. 1 lit. c DSGVO;
Art. 6 para. 1 lit. d DSGVO serves as the legal basis in the event that vital interests of the data subject or another natural person necessitate the processing of personal data.
The legal basis for the processing necessary to perform a task which is in the public interest or in the exercise of official authority entrusted to the data controller is Art. 6 para. 1 lit. e DSGVO.
The legal basis for the processing to safeguard our legitimate interests is Art. 6 para. 1 lit. f DSGVO.
The processing of data for purposes other than those for which they were collected is governed by the provisions of Art. 6 (4) DSGVO.
The processing of special categories of data (pursuant to Art. 9 (1) DSGVO) is governed by the provisions of Art. 9 (2) DSGVO Security measures
We take appropriate technical and organisational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, extent, circumstances and purposes of the processing, as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.
Measures shall include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to, access to, inputting, disclosure, securing and separation of data. In addition, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data and the response to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and data protection-friendly default settings.
Cooperation with contract processors, joint managers and third parties
Insofar as we disclose data to other persons and companies (contract processors, jointly responsible persons or third parties) within the scope of our processing, transfer them to them or otherwise grant them access to the data, this shall only take place on the basis of legal permission (e.g. if a transfer of the data to third parties, such as payment service providers, is necessary for the fulfilment of the contract), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
Insofar as we disclose, transmit or otherwise grant access to data to other companies of our group of companies, this is done in particular for administrative purposes as a legitimate interest and beyond that on a basis corresponding to the legal requirements.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or if this is done in the context of the use of third party services or disclosure or transfer of data to other persons or companies, this only occurs if it is done to fulfil our (pre)contractual obligations, on the basis of your consent, a legal obligation or on the basis of our legitimate interests. Subject to express consent or contractually required transfer, we process or allow the data to be processed only in third countries with a recognised level of data protection, which includes US processors certified under the “Privacy Shield” or on the basis of special guarantees, such as a contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission).
Rights of the data subjects
Right of access: You have the right to obtain confirmation as to whether the data in question will be processed and to obtain access to such data, as well as further information and a copy of the data in accordance with the provisions of the law.
Right of rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of inaccurate data concerning you.
Right to deletion and limitation of processing: You have the right, in accordance with the statutory provisions, to demand that the data concerned be deleted immediately or, alternatively, to demand that the processing of the data be limited in accordance with the statutory provisions.
Right to data transfer: You have the right to receive data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to demand that it be transferred to another responsible party.
Complaint to the supervisory authority: You also have the right to submit a complaint to the responsible supervisory authority in accordance with the statutory provisions.
Right of revocation
You have the right to revoke any consent you have given with effect for the future.
Right of objection
Right of objection: You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you on the basis of Art. 6 para. 1 lit. e or f DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct advertising, you have the right at any time to object to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling insofar as it is connected with such direct advertising.
Cookies and right to object to direct advertising
Cookies” are small files that are stored on the user’s computer. Different data can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after the user’s visit to an online service. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his browser. The content of a shopping basket in an online shop or a login status, for example, can be stored in such a cookie. Cookies are referred to as “permanent” or “persistent” and remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. The interests of the users who are used for range measurement or marketing purposes can also be stored in such a cookie. Third party cookies” are cookies that are offered by providers other than the person responsible for operating the online service (otherwise, if they are only the latter’s cookies, they are referred to as “first party cookies”).
We may use temporary and permanent cookies and explain this in our privacy policy.
If we ask users for their consent to the use of cookies (e.g. in the context of a cookie agreement), the legal basis for this processing is Art. 6 Para. 1 lit. a. DSGVO. Otherwise, the personal cookies of the users will be processed in accordance with the following explanations within the framework of this data protection declaration on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. f. of the German Data Protection Act). DSGVO) or if the use of cookies is necessary for the provision of our contract-related services, in accordance with Art. 6 Para. 1 lit. b. DSGVO, or if the use of cookies is necessary for the performance of a task in the public interest or in the exercise of official authority, pursuant to Art. 6 para. 1 lit. e. DSGVO, processed.
If users do not wish cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
A general objection to the use of cookies for online marketing purposes can be raised for a large number of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/ . In addition, cookies can be saved by deactivating them in the browser settings. Please note that in this case not all functions of this online offer can be used.
Deletion of data
The data processed by us will be deleted in accordance with the statutory provisions or their processing will be restricted. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and there are no legal obligations to retain them.
If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons.
Changes and updates to the data protection declaration
We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
Business-related processing
Additionally we process
– Contract data (for example, contract object, duration, customer category).
– Payment data (e.g., bank details, payment history)
by our customers, interested parties and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
Order processing in the online shop and customer account
We process the data of our customers within the framework of the order processes in our online shop, in order to enable them to select and order the selected products and services, as well as their payment and delivery, or execution.
To the processed data belong inventory data, communication data, contract data, payment data and to the persons affected by the processing belong our customers, interested parties and other business partners. Processing is carried out for the purpose of providing contractual services within the framework of operating an online shop, billing, delivery and customer services. We use session cookies to store the contents of the shopping basket and permanent cookies to store the login status.
Processing is carried out to fulfil our services and carry out contractual measures (e.g. carrying out order processes) and insofar as it is legally prescribed (e.g., legally required archiving of business processes for trade and tax purposes). The information marked as necessary is required for the justification and fulfilment of the contract. We only disclose the data to third parties within the scope of delivery, payment or within the scope of the statutory permits and obligations, and also if this is done on the basis of our legitimate interests, about which we inform you in the context of this data protection declaration (e.g., to legal and tax advisors, financial institutions, freight companies and authorities).
Users can optionally create a user account by viewing their orders in particular. During the registration process, the necessary mandatory information will be provided to the users. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to its retention is necessary for commercial or tax reasons. Information in the customer account remains until its deletion with subsequent archiving in the case of a legal obligation or our legitimate interests (eg, in the case of litigation). It is the responsibility of the users to secure their data before the end of the contract in the event of termination.
Within the scope of registration and renewed registrations as well as use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. A passing on of these data to third parties does not take place in principle, except it is necessary for the pursuit of our legal requirements as entitled interest or it exists for this a legal obligation.
The deletion takes place after expiration of legal warranty and other contractual rights or obligations (e.g., payment claims or performance obligations from contracts with customers), whereby the necessity of the retention of data is reviewed every three years; in the case of retention due to legal archiving obligations, the deletion takes place insofar after their expiration.
Contractual services
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 them with our contractual or pre-contractual services. The data processed, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship.
The processed data includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g. e-mail addresses and telephone numbers) as well as contract data (e.g., services used, contract contents, contractual communication, names of contact persons) and payment data (e.g., bank details, payment history).
We do not process any special categories of personal data, unless they are part of a commissioned or contractual processing.
We process data which are necessary for the justification and fulfilment of the contractual services and point out the necessity of their indication, if this is not evident for the contracting parties. Disclosure to external persons or companies will only take place if it is necessary within the framework of 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 and the legal requirements.
Within the scope of using our online services, we can save the IP address and the time of the respective user action. The storage takes place on the basis of our justified interests, as well as the interests of the users in the protection from abuse and other unauthorized use. A passing on of these data to third parties does not take place in principle, unless it is necessary for the pursuit of our claims according to art. 6 para. 1 lit. f. DSGVO is necessary or there is a legal obligation to do so pursuant to Art. 6 Para. 1 lit. c. DSGVO.
The data will be deleted when the data is no longer required for the fulfilment of contractual or statutory welfare obligations and for the handling of any warranty and comparable obligations, whereby the necessity of storing the data is reviewed every three years; otherwise the statutory storage obligations apply.
External payment service providers
We use external payment service providers whose platforms users and we can use to carry out payment transactions. These payment service providers may include, each with a link to the privacy statement: Paypal (https://www.paypal.com/de/webapps/mpp/ua/privacy-ful ), Klarna (https://www.klarna.com/de/datenschutz/ ), Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/ ), Giropay (https://www.giropay.de/rechtliches/datenschutz-agb/ ), Visa (https://www.visa.de/datenschutz ), Mastercard (https://www.mastercard.de/de-de/datenschutz.html ), American Express (https://www.americanexpress.com/de/content/privacy-policy-statement.html ), Stripe (https://stripe.com/de/privacy ).
Within the framework of the performance of contracts, we shall appoint payment service providers on the basis of Art. 6 para. 1 lit. b. DSGVO. In addition, we use external payment service providers on the basis of our legitimate interests pursuant to Art. 6 Para. 1 lit. f. DSGVO in order to offer our users effective and secure payment options.
The data processed by the payment service providers includes inventory data such as name and address, bank data such as account numbers or credit card numbers, passwords, TANs and checksums as well as contract, sum and recipient details. The information is required to complete the transactions. However, the data entered will only be processed and stored by the payment service providers. This means that we do not receive any account- or credit card-related information, but only information with confirmation or negative information about the payment. Under certain circumstances, the data may be transmitted by the payment service provider to credit agencies. The purpose of this transmission is to check identity and creditworthiness. Please refer to the general terms and conditions and data protection information of the payment service providers.
For payment transactions, the terms and conditions and the data protection notices of the respective payment service providers apply, which can be accessed within the respective websites or transaction applications. We also refer to these for the purpose of further information and assertion of revocation, information and other rights affected.
Administration, Financial Accounting, Office Organization, Contact Management
We process data in the context of administrative tasks as well as the organisation of our business, financial accounting and compliance with legal obligations, such as archiving. Here we process the same data that we process within the scope of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. DSGVO, Art. 6 para. 1 lit. f. DSGVO. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks which serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the data specified in these processing activities.
We disclose or transmit data to the financial administration, consultants, such as tax consultants or auditors, as well as other fee offices and payment service providers.
Furthermore, on the basis of our business interests, we store information on suppliers, organisers and other business partners, e.g. for the purpose of establishing contact at a later date. This data, which is mainly company-related, is stored permanently.
Business analyses and market research
In order to run our business economically, to be able to recognise market trends, wishes of our contractual partners and users, we analyse the data available to us on business transactions, contracts, enquiries, etc., in order to identify the most suitable and appropriate solutions for your needs. We process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. DSGVO, whereby the persons concerned include contractual partners, interested parties, customers, visitors and users of our online services.
The analyses are carried out for the purpose of economic evaluations, marketing and market research. We can take into account the profiles of registered users with information, e.g. on the services they make use of. The analyses serve us to increase the user friendliness, the optimization of our offer and the business economy. The analyses serve us alone and are not disclosed externally unless they are anonymous analyses with summarized values.
If these analyses or profiles are person-related, they will be deleted or anonymised upon termination by the user, otherwise after two years from the conclusion of the contract. In all other respects, the macroeconomic analyses and general trend determinations are prepared anonymously wherever possible.
Google Cloud Services
We use the cloud and cloud software services offered by Google (the Software as a Service, for example, Google Suite) for the following purposes: storing and managing documents, managing calendars, sending email, spreadsheets and presentations, exchanging documents, content and information with specific recipients or publishing web pages, forms or other content and information, and chatting and participating in audio and video conferences.
The personal data of the users will be processed in this connection, insofar as these become part of the documents and content processed within the described services or are part of communication processes. This may include, for example, user master data and contact data, data on processes, contracts, other processes and their contents. Google also processes usage data and metadata used by Google for security purposes and service optimisation.
When using publicly accessible documents, websites or other content, Google may store cookies on the user’s computer for the purpose of web analysis or to remember user preferences.
We use the Google Cloud services on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f DSGVO in efficient and secure administrative and cooperation processes. Furthermore, the processing takes place on the basis of an order processing contract with Google (https://cloud.google.com/terms/data-processing-terms ).
Further information can be found in Google’s privacy policy (https://www.google.com/policies/privacy ) and the security information on Google cloud services (https://cloud.google.com/security/privacy/ ). You can object to the processing of your data in the Google Cloud in accordance with the legal requirements. In addition, the deletion of the data within Google’s cloud services is determined by the other processing procedures in which the data is processed (e.g. deletion of data no longer required for contractual purposes or storage for purposes of taxation of data required).
The Google Cloud Services are offered by Google Ireland Limited. As far as a transmission to the USA takes place, we refer to the certification of Google USA under the Privacy Shield (https://www.privacyshield.gov/participant?id=a2zt0000000000001L5AAI&status=Active ) and standard protection clauses (https://cloud.google.com/terms/data-processing-terms ).
registration function
Users can create a user account. Within the scope of registration, the required mandatory data will be communicated to the users and processed on the basis of Art. 6 Para. 1 lit. b DSGVO for the purpose of providing the user account. The processed data includes in particular the login information (name, password and an e-mail address). The data entered during registration will be used for the purposes of using the user account and its purpose.
Users may be informed by e-mail of information relevant to their user account, such as technical changes. If users have terminated their user account, their data will be deleted with regard to the user account, subject to a statutory retention obligation. It is the responsibility of the users to secure their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract.
When using our registration and login functions as well as the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. A passing on of these data to third parties does not take place in principle, unless it is necessary for the pursuit of our claims or there is a legal obligation according to Art. 6 para. 1 lit. c. DSGVO. The IP addresses will be anonymized or deleted after 7 days at the latest.
Comments and contributions
If users leave comments or other contributions, their IP addresses may be deleted on the basis of our legitimate interests within the meaning of Art. 6 Para. 1 lit. f. of the German Data Protection Act. DSGVO for 7 days. This is done for our security if someone leaves illegal contents (insults, forbidden political propaganda, etc.) in comments and contributions. In this case we can be prosecuted ourselves for the comment or contribution and are therefore interested in the identity of the author.
Furthermore, we reserve the right, on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. DSGVO, to process user data for the purpose of spam detection.
On the same legal basis, we reserve the right, in the case of surveys, to store the IP addresses of users for their duration and to use cookies in order to avoid multiple votes.
The personal information provided in the course of comments and contributions, any contact and website information as well as the content information will be stored permanently by us until the user objects.
Comment Subscriptions
Subsequent comments may be subscribed to by users with their consent pursuant to Art. 6 para. 1 lit. a DSGVO. Users receive a confirmation email to check whether they are the owner of the email address entered. Users can unsubscribe from ongoing comment subscriptions at any time. The confirmation email will contain information on the cancellation options. For the purposes of proving the users’ consent, we store the registration time and the IP address of the users and delete this information when users unsubscribe from the subscription.
You can cancel the receipt of our subscription at any time, i.e. revoke your consent. We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to provide evidence of a previously given consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time.
Akismet Anti-Spam Testing
Our online service uses the “Akismet” service provided by Automattic Inc, 60 29th Street #343, San Francisco, CA 94110, USA. The use is based on our legitimate interests in the sense of Art. 6 para. 1 lit. f) DSGVO. With the help of this service, comments of real people are distinguished from spam comments. All comments are sent to a server in the USA, where they are analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data is stored beyond this time. This information includes the name entered, the email address, the IP address, the comment content, the referrer, information about the browser used, the computer system and the time of the entry.
Further information on the collection and use of data by Akismet can be found in Automattic’s privacy policy: https://automattic.com/privacy/ .
Users are welcome to use pseudonyms or to refrain from entering their name or email address. You can completely prevent the transmission of data by not using our comment system. That would be a shame, but unfortunately we don’t see any other alternatives that work just as effectively.
Contact
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the user’s details are used to process the contact enquiry and to process it in accordance with Art. 6 Para. 1 lit. b. of the German Data Protection Act. (within the framework of contractual/pre-contractual relationships), Art. 6 Para. 1 lit. f. (other inquiries) DSGVO processed… The user data can be stored in a customer relationship management system (“CRM system”) or comparable inquiry organization.
We delete the requests if they are no longer necessary. We check the necessity every two years; furthermore, the legal archiving obligations apply.
Communication via WhatsApp Messenger
We use the WhatsApp Messenger for communication purposes and ask you to be aware of the following regarding WhatsApp’s functionality, encryption, risks, use of metadata within the Facebook group of companies, and your choices about opting out.
You do not need to use WhatsApp and can contact us by alternative means, such as telephone or e-mail. Please use the contact options provided to you or use the contact options provided on our website.
WhatsApp (WhatsApp Inc. Legal 1601 Willow Road Menlo Park, California 94025, USA) is a U.S. service, which means that the information you submit via WhatsApp may first be transferred to WhatsApp in the United States before it is transferred to us.
However, WhatsApp is certified under the Privacy Shield Agreement and therefore warrants to comply with European and Swiss privacy laws (https://www.privacyshield.gov/participant?id=a2zt0000000TSnwAAG&status=Active ).
WhatsApp also warrants that the communication content (i.e. the content of your message and attached images) will be encrypted end-to-end. This means that the content of the messages is not visible, not even by WhatsApp itself. You should always use a current version of WhatsApp to ensure that message content is encrypted.
However, we point out to our communication partners that WhatsApp may not see the content, but may know that and when communication partners are communicating with us, and may process technical information about the communication partner’s device used, and location information (known as metadata) depending on their device settings. With the exception of encrypted content, it is possible to transmit the data of the communication partners within the Facebook group of companies, in particular for the purpose of optimising the respective services and for security purposes. Also, communication partners should assume, at least as long as they have not objected, that their data processed by WhatsApp can be used for marketing purposes or to display advertisements tailored to users.
If we ask communication partners for their consent prior to communicating with them via WhatsApp, the legal basis for our processing of their data is Art. 6 Para. 1 lit. a. DSGVO. Otherwise, if we do not request your consent and you contact us, for example, on your own initiative, we will use WhatsApp in our relationship with our contractual partners and as part of the contract initiation as a contractual measure pursuant to Art. 6 Para. 1 lit. b. DSGVO and in the case of other interested parties and communication partners on the basis of our legitimate interests in fast and efficient communication and fulfilment of the needs of our communication partners in communication via messengers pursuant to Art. 6 para. 1 lit. f. DSGVO.
Further information on the purposes, types and extent of the processing of your data by WhatsApp, as well as the relevant rights and setting options for the protection of your privacy, can be found in WhatsApp’s data protection information: https://www.whatsapp.com/legal .
You may opt out of communicating with us via WhatsApp at any time. If you subscribe to news (also known as “broadcasts”) via WhatsApp, you can delete our appropriate telephone number from their contacts and ask us to remove your contact from our directory. For ongoing individual requests or communications, you may also ask us not to continue communication through WhatsApp and to delete the communication content.
In the case of communication via WhatsApp, we will delete the WhatsApp messages as soon as we can assume that we have responded to any user information, if no reference to a previous conversation is to be expected, and if there are no legal obligations to store the deletion.
Furthermore, we would like to point out that we will not transmit the contact data provided to us to WhatsApp without your consent (e.g. by contacting you via WhatsApp).
Finally, we would like to point out that for reasons of your security, we reserve the right not to answer inquiries about WhatsApp. This is the case if, for example, internal contractual matters require special secrecy or if an answer via Messenger does not meet the formal requirements. In such cases, we refer you to more appropriate communication channels.
Communication via Facebook Messenger
We use the Facebook Messenger for communication purposes and ask you to note the following information about the functionality, encryption, risks of the Facebook Messenger, use of the metadata within the Facebook group of companies and your opposition options.
You do not have to use the Facebook Messenger and can contact us by alternative means, e.g. by telephone or e-mail. Please use the contact options provided to you or use the contact options provided on our website.
Facebook Messenger is offered by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, whereby the data entered and otherwise collected in the course of communication is processed in the USA by Facebook, 1 Hacker Way, Menlo Park, CA 94025, USA.
However, Facebook is certified under the Privacy Shield Agreement and therefore warrants to comply with European and Swiss data protection laws (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active ).
Facebook also assures that the communication content (i.e. the content of your message and attached images) is not readable and offers end-to-end encryption of the content. This means that the content of the messages is not viewable, not even by Facebook itself. However, end-to-end encryption requires activation, which you must activate in your Messenger settings with the “Secret Conversations” menu item. You should always use a current version of Facebook Messenger to ensure that message content is encrypted.
We would like to point out to our communication partners that, even if encryption is activated, Facebook can find out that and when communication partners communicate with us and process technical information about the communication partner’s device used and, depending on the settings of their device, also location information (so-called metadata). With the exception of the encrypted content, it is possible to transmit the data of the communication partners within the Facebook group of companies, in particular for the purpose of optimising the respective services and for security purposes. Communication partners should also assume, at least as long as they have not objected, that their data processed by the Facebook Messenger can be used for marketing or advertising purposes tailored to users.
If we request the consent of communication partners before communicating with them via the Facebook Messenger, the legal basis for our processing of their data is Art. 6 Para. 1 lit. a. DSGVO. Otherwise, if we do not request consent and you contact us, for example, on your own initiative, we will use WhatsApp in our relationship with our contractual partners and as part of contract initiation as a contractual measure pursuant to Art. 6 Para. 1 lit. b. DSGVO and in the case of other interested parties and communication partners on the basis of our legitimate interests in fast and efficient communication and fulfilment of the needs of our communication partners in communication via messengers pursuant to Art. 6 para. 1 lit. f. DSGVO.
Further information on the purposes, types and scope of the processing of your data by Facebook, as well as the relevant rights and setting options for the protection of your privacy, can be found in Facebook’s data protection information: https://www.facebook.com/about/privacy .
You can object to communication with us via Facebook Messenger at any time and request us not to continue communication via the Facebook Messenger and to delete the communication content. We delete the Facebook messages as soon as we can assume that we have answered any user information, if no reference to a previous conversation is to be expected and there are no legal obligations to store the deletion.
Finally, we would like to point out that we reserve the right, for reasons of your security, not to answer enquiries using the Facebook Messenger. This is the case if, for example, internal contractual matters require special secrecy or if an answer via the Messenger does not meet the formal requirements. In such cases, we refer you to more appropriate communication channels.
Trustedbadge of Trustedshops
The Trusted Shops Trustbadge is integrated on this website to display our Trusted Shops seal of approval and the possibly collected evaluations as well as to offer the Trusted Shops products to buyers after an order.
This serves the protection of our legitimate interests in an optimal marketing by enabling a safe purchase in accordance with Art. 6 Para. 1 S. 1 lit. f DSGVO. The Trustbadge and the services advertised with it are an offer of the Trusted Shops GmbH, Subbelrather Str. 15C, 50823 Cologne. The trust badge is provided by a CDN provider (Content-Delivery-Network) as part of order processing. The Trusted Shops GmbH uses also Dienstleister from the USA. An appropriate level of data protection is ensured. Further information to the data security of the Trusted Shops GmbH can be found here: https://www.trustedshops.de/impressum/#datenschutz .
When the Trustbadge is called up, the web server automatically saves a so-called server log file, which also contains the IP address of the user, the date and time of the call, the amount of data transferred and the requesting provider (access data) and documents the call. Individual access data are stored in a security database for the analysis of security problems. The log files are automatically deleted 90 days after creation at the latest.
Further personal data is transferred to Trusted Shops GmbH if users decide to use Trusted Shops products after completing an order or have already registered for use. The contractual agreement between the users and Trusted Shops applies. For this an automatic collection of personal data from the order data takes place. Whether user as a buyer is already registered for a product use is checked automatically on the basis of a neutral parameter, the e-mail address hashed by cryptological one-way function. The e-mail address is converted into this hash value, which cannot be decoded for Trusted Shops, before transmission. After checking for a match, the parameter is automatically deleted.
This is necessary for the fulfilment of our and Trusted Shops’ predominantly legitimate interests in the provision of the buyer protection linked to the specific order and the transactional valuation services in accordance with Art. 6 Para. 1 S. 1 lit. f DSGVO. Further details, including objections, can be found in the Trusted Shops data protection declaration linked above and in the Trustbadge.
Newsletter
With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures and your rights of objection. By subscribing to our newsletter, you declare your agreement with the receipt and the described procedures.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter referred to as “newsletter”) only with the consent of the recipient or legal permission. If the contents of the newsletter are specifically described within the scope of registration, they are decisive for the consent of the user. Furthermore, our newsletters contain information about our products and information accompanying them (e.g. safety instructions), offers, promotions and our company.
Double-Opt-In and logging: The registration to our newsletter takes place in a so-called Double-Opt-In procedure. I.e. after registration you will receive an e-mail in which you will be asked to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address. Likewise the changes of your data stored with the Versanddienstleister are logged.
Registration data: To subscribe to the newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to enter a name in the newsletter for the purpose of addressing you personally.
The dispatch of the newsletter and the associated performance measurement are based on the consent of the recipients pursuant to Art. 6 Para. 1 lit. a, Art. 7 DSGVO in conjunction with § 107 Para. 2 TKG or, if consent is not required, on our legitimate interests in direct marketing pursuant to Art. 6 Para. 1 as per f. DSGVO in connection with § Art. 107 Par. 2 and 3 TKG.
The registration procedure is recorded on the basis of our legitimate interests pursuant to Art. 6 Para. 1 lit. f DSGVO. Our interest is directed towards the use of a user-friendly and secure newsletter system that serves our business interests as well as the expectations of the users and furthermore allows us to provide evidence of consent.
Cancellation/revocation – You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter. We may store the unsubscribed e-mail addresses for up to three years on the basis of our legitimate interests before deleting them in order to be able to provide evidence of a previously given consent. The processing of this data is limited to the purpose of a possible defence against claims. An individual request for deletion is possible at any time, provided that the former existence of a consent is confirmed at the same time.
Newsletter – Dispatch service provider
The dispatch of the newsletter is carried out by the dispatch service provider [NAME, ADRESSE, LAND]. The data protection regulations of the dispatch service provider can be viewed here: [LINK TO THE PRIVACY POLICY]. The shipping service provider will be informed on the basis of our legitimate interests in accordance with Art. 6 Para. 1 lit. f. of the German Data Protection Act. DSGVO and a contract processing agreement pursuant to Art. 28 para. 3 sentence 1 DSGVO.
The dispatch service provider can use the data of the recipients in pseudonymous form, i.e. without allocation to a user, to optimise or improve its own services, e.g. for technical optimisation of dispatch and presentation of the newsletter or for statistical purposes. However, the dispatch service provider does not use the data of our newsletter recipients to write to them itself or to pass the data on to third parties.
Newsletter – Measurement of success
The newsletters contain a so-called “web-beacon”, i.e. a file the size of a pixel, which is retrieved from our server when the newsletter is opened or, if we use a dispatch service provider, from its server. Within the scope of this retrieval, technical information such as information about the browser and your system, as well as your IP address and time of retrieval are first collected.
This information is used to technically improve the services on the basis of technical data or target groups and their reading behaviour on the basis of their retrieval locations (which can be determined with the help of the IP address) or access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. It is, however, neither our endeavour nor, if used, that of the dispatch service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our contents to them or to send different contents according to the interests of our users.
A separate cancellation of the performance measurement is unfortunately not possible, in which case the entire newsletter subscription must be cancelled.
Hosting and e-mail dispatch
The hosting services used by us serve the provision of the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services which we use for the purpose of operating this online service.
Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors to this online service on the basis of our legitimate interests in the efficient and secure provision of this online service in accordance with Art. 6 Para. 1 lit. f DSGVO in connection with Art. 28 DSGVO (conclusion of an order processing contract).
Google Tag Manager
Google Tag Manager is a solution with which we can manage so-called website tags via an interface (and thus integrate Google Analytics and other Google marketing services into our online offering). The Tag Manager itself (which implements the tags) does not process any personal user data. With regard to the processing of users’ personal data, reference is made to the following information on Google services. Terms of use: https://www.google.com/intl/de/tagmanager/use-policy.html .
Google Analytics
We use Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google uses cookies. The information generated by the cookie about users’ use of the website is generally transmitted to and stored by Google on servers in the United States.
Google will use this information on our behalf to evaluate the use of our website by users, to compile reports on activities within this website and to provide us with other services relating to the use of this website and the Internet. Pseudonymous user profiles can be created from the processed data.
We use Google Analytics only with activated IP anonymization. This means that the IP address of the user is 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 is the full IP address transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user’s browser is not merged with other Google data. Users may refuse the use of cookies by selecting the appropriate settings on their browser, they may also refuse the use of cookies by selecting the appropriate settings on their browser, they may refuse the use of cookies by selecting the appropriate settings on their browser, and they may refuse the processing of cookies by selecting the appropriate settings on Google, and they may refuse the processing of cookies by selecting the appropriate settings on Google, and they may refuse the processing of cookies by Google, by downloading and installing the browser plugin available from the following link: http://tools.google.com/dlpage/gaoptout?hl=en .
If we ask the users for their consent (e.g. in the context of a cookie consent), the legal basis for this processing is Art. 6 Para. 1 lit. a. DSGVO. Otherwise, the personal data of the user will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online service as defined in Art. 6 Para. 1 lit. f. of the German Data Protection Act). DSGVO).
As far as data is processed in the USA, we point out that Google is certified under the Privacy Shield Agreement and thereby assures compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active ).
Further information on the use of data by Google, setting and objection options can be found in Google’s privacy policy (https://policies.google.com/privacy ) and in the settings for the display of advertising by Google (https://adssettings.google.com/authenticated ).
The personal data of the users will be deleted or anonymized after 14 months.
Google Universal Analytics
We use Google Analytics in the form of “universal analytics”. “Universal Analytics” refers to a Google Analytics procedure in which user analysis is performed on the basis of a pseudonymous user ID and a pseudonymous profile of the user is thus created with information from the use of various devices (so-called “cross-device tracking”).
Target group formation with Google Analytics
We use Google Analytics to display ads placed by Google and its partners within our advertising services only to users who have shown an interest in our online services or who have specific characteristics (e.g. interests in specific topics or products determined on the basis of the websites visited) that we transmit to Google (so-called “remarketing” or “Google Analytics Audiences”). With the help of remarketing audiences, we also want to ensure that our ads match the potential interest of users.
Jetpack (WordPress Stats)
We use the plugin Jetpack (here the sub-function “WordPress Stats”), which includes a tool for statistical evaluation of visitor access and from Automattic Inc., 60 29th Street #343, San Francisco, CA 94110, USA. Jetpack uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the site.
The information generated by the cookie about your use of this website is stored on a server in the USA. User profiles can be created from the processed data, whereby these are only used for analysis and not for advertising purposes. Further information can be found in Automattic’s privacy policy: https://automattic.com/privacy/ and information on Jetpack cookies: https://jetpack.com/support/cookies/ .
If we ask the users for their consent (e.g. in the context of a cookie consent), the legal basis for this processing is Art. 6 Para. 1 lit. a. DSGVO. Otherwise, the personal data of the user will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online service as defined in Art. 6 Para. 1 lit. f. of the German Data Protection Act). DSGVO).
Facebook pixels, custom audiences and Facebook conversion
Within our online offer, the so-called “Facebook pixel” of the social network Facebook, which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”), is used.
With the help of the Facebook pixel, Facebook is on the one hand able to determine the visitors of our online offer as a target group for the presentation of ads (so-called “Facebook ads”). Accordingly, we use Facebook pixels to display Facebook ads placed by us only to those Facebook users who have shown an interest in our online offering or who have certain features (e.g., interests in certain topics or products that are determined on the basis of the websites visited) that we transmit to Facebook (so-called “custom audiences”). Using Facebook pixels, we also want to ensure that our Facebook ads match the potential interest of users and are not annoying. Using Facebook pixels, we can also track the effectiveness of Facebook ads for statistical and market research purposes by seeing if users were referred to our website after clicking on a Facebook ad (known as “conversion”).
Facebook processes the data in accordance with Facebook’s data usage policy. Accordingly, general information on the presentation of Facebook ads is provided in Facebook’s data usage policy: https://www.facebook.com/policy . Specific information and details about Facebook pixels and how they work can be found in the Facebook help section: https://www.facebook.com/business/help/651294705016616 .
If we ask the users for their consent (e.g. in the context of a cookie agreement), the legal basis for this processing is Art. 6 Para. 1 lit. a. DSGVO. Otherwise, the personal data of the user will be processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online service within the meaning of Art. 6 Para. 1 lit. f. of the German Data Protection Act). DSGVO).
Facebook is certified under the Privacy Shield Agreement and thereby assures that it complies with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active ).
You may object to the Facebook pixel collection and use of your data to display Facebook ads. To set what types of ads you see within Facebook, you can go to the page set up by Facebook and follow the instructions on how to set up usage-based ads: https://www.facebook.com/settings?tab=ads . The settings are platform-independent, i.e. they are applied to all devices, such as desktop computers or mobile devices.
You may also object to the use of cookies to measure reach and for advertising purposes, via the Network Advertising Initiative’s opt-out page (http://optout.networkadvertising.org/ ) and additionally via the U.S. website (http://www.aboutads.info/choices ) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/ ).
Online presences in social media
We maintain online presences within social networks and platforms in order to be able to communicate with customers, interested parties and users active there and to inform them about our services.
We would like to point out that user data may be processed outside the European Union. This can result in risks for users, as it could, for example, make it more difficult to enforce the rights of users. With regard to US providers that are certified under the Privacy Shield, we would like to point out that by doing so they commit themselves to comply with EU data protection standards.
In addition, user data is usually processed for market research and advertising purposes. For example, user profiles can be created on the basis of user behavior and the resulting interests of users. The usage profiles can in turn be used, for example, to place advertisements inside and outside the platforms that presumably correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer in which the user’s usage behaviour and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (in particular if the users are members of the respective platforms and are logged in to them).
The processing of the personal data of the users takes place on the basis of our legitimate interests in effective information of the users and communication with the users in accordance with Art. 6 Para. 1 letter f. DSGVO. If the users are requested by the respective providers of the platforms to consent to the aforementioned data processing, the legal basis for the processing is Art. 6 Para. 1 lit. a., Art. 7 DSGVO.
For a detailed description of the respective processing operations and the opt-out options, we refer to the following linked information of the providers.
Also in the case of requests for information and the assertion of user rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and give information. Should you nevertheless need help, you can contact us.
– Facebook, Pages, Groups (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) on the basis of an agreement on joint processing of personal data – Privacy Policy: https://www.facebook.com/about/privacy/ , specifically for Pages: https://www.facebook.com/legal/terms/information_about_page_insights_data , Opt-Out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com , Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active .
– Google/ YouTube (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) – Privacy Statement: https://policies.google.com/privacy , Opt-Out: https://adssettings.google.com/authenticated , Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.
– Google/ YouTube (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) – Privacy Statement: https://policies.google.com/privacy , Opt-Out: https://adssettings.google.com/authenticated , Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active .
– Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) – Privacy Statement / Opt-Out: http://instagram.com/about/legal/privacy/ .
– Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) – Privacy Statement: https://twitter.com/de/privacy , Opt-Out: https://twitter.com/personalization , Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active .
– Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA) – Privacy Statement / Opt-Out: https://about.pinterest.com/de/privacy-policy .
– LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland) – Privacy Statement https://www.linkedin.com/legal/privacy-policy , Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out , Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active .
– Xing (XING AG, Dammtorstraße 29-32, 20354 Hamburg, Germany) – Privacy Statement / Opt-Out: https://privacy.xing.com/de/datenschutzerklaerung .
– Wakalet (Wakelet Limited, 76 Quay Street, Manchester, M3 4PR, United Kingdom) – Privacy Statement / Opt-Out: https://wakelet.com/privacy.html .
– Soundcloud (SoundCloud Limited, Rheinsberger Str. 76/77, 10115 Berlin, Germany) – Privacy Statement / Opt-Out: https://soundcloud.com/pages/privacy .
Integration of third-party services and content
Within the scope of our online offer, we act on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. f. of the German Civil Code). DSGVO) content or service offers from third parties in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).
This always presupposes that the third-party providers of this content perceive the IP address of the user, since they would not be able to send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We make every effort to use only those contents whose respective providers only use the IP address to deliver the contents. Third party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. 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 contain, among other things, technical information about the browser and operating system, referring web pages, visit times and other information about the use of our online services, as well as may be linked to such information from other sources.
Youtube
We integrate the videos of the platform “YouTube” of the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Privacy Policy: https://www.google.com/policies/privacy/ , Opt-Out: https://adssettings.google.com/authenticated .
Google ReCaptcha
We integrate the function to recognize bots, e.g. for entries in online forms (“ReCaptcha”) of the provider GGoogle Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Privacy Policy: https://www.google.com/policies/privacy/ , Opt-Out: https://adssettings.google.com/authenticated .
Functions and contents of the Twitter service offered by Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA, can be integrated into our online offer. This may include, for example, content such as images, videos or texts and buttons with which users can share content from this online service within Twitter.
If the users are members of the Twitter platform, Twitter can assign the call of the above-mentioned contents and functions to the profiles of the users there. Twitter is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active ). Privacy Policy: https://twitter.com/de/privacy , Opt-Out: https://twitter.com/personalization .
Within our online offer, functions and contents of the service Instagram, offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, can be integrated. This may include, for example, content such as images, videos or text and buttons with which users can share content from this online offering within Instagram. If the users are members of the Instagram platform, Instagram can assign the call of the above contents and functions to the user profiles there. Instagram Privacy Policy: http://instagram.com/about/legal/privacy/ .
Sharing functions of AddThis
Within our online offer the service “AddThis” (1595 Spring Hill Rd Suite 300 Vienna, VA 22182, USA) is used to share contents of this online offer within social networks (so-called sharing).
The use takes place on the basis of our legitimate interests, i.e. interest in a spreading of our on-line offer in accordance with art. 6 exp. 1 lit. f. DSGVO.
AddThis uses the personal information of the users for the supply and the execution of the Sharing functions. In addition, AddThis may use pseudonymous user information for marketing purposes. This data is stored on the user’s computer using so-called “cookie” text files. Privacy policy: http://www.addthis.com/privacy , Opt-Out: http://www.addthis.com/privacy/opt-out.