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 „controller“, we refer to the definitions in Art. 4 of the Basic Data Protection Regulation (GDPR).
Person in charge
Sasiton Welz
C/Gran Via 23
07180 El Toro, MallorcaSpain
sasitonluna (a) gmail.com
Types of data processed
– Inventory data (e.g., person master data, names or addresses).
– Contact data (e.g. e-mail, telephone numbers).
– 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.
– Answer contact requests and communicate with users.
– Security measures.
– Reach 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 or set of operations which is carried out with or without the aid of automated processes and which involves personal data. The term reaches far 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. controller“ means any natural or legal person, public authority, agency or 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 GDPR we inform you about the legal basis of our data processing. The following applies to users from the area of application of the Basic Data Protection Regulation (GDPR), i.e. the EU and the EEC, insofar as the legal basis is not stated in the data protection declaration: The legal basis for obtaining consent is Art. 6 Para. 1 lit. a and Art. 7 GDPR; The legal basis for processing to fulfil our services and carry out contractual measures as well as answering enquiries is Art. 6 Para. 1 lit. a and Art. 7 GDPR; The legal basis for processing to fulfil our services and carry out contractual measures is Art. 6 Para. 1 lit. a and Art. 7 GDPR. The legal basis for the processing for the fulfilment of our legal obligations is Art. 6 para. 1 lit. b GDPR; Art. 6 para. 1 lit. d GDPR 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 for the performance of a task carried out in the public interest or in the exercise of official authority entrusted to the controller is Art. 6 para. 1 lit. e GDPR. The legal basis for the processing to safeguard our legitimate interests is Art. 6 para. 1 lit. f GDPR. The processing of data for purposes other than those for which they were collected is governed by the provisions of Art. 6 (4) GDPR. The processing of special categories of data (pursuant to Art. 9 para. 1 GDPR) is governed by the provisions of Art. 9 para. 2 GDPR.
Safety precautions
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 that data subjects‘ rights are exercised, that data is deleted and that we react 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 through 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 GDPR, information page of the EU Commission).
Rights of data subjects
You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with the provisions of the law. You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you. In accordance with the statutory provisions, you have the right to demand that the relevant data be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions. You have the right to demand that we receive the data concerning you that you have provided to us in accordance with the statutory provisions and to demand that it be passed on to other persons responsible. They also have the right to file a complaint with the competent supervisory authority in accordance with the statutory provisions.
Right of withdrawal
You have the right to revoke any consent you have given with effect for the future.
Right of objection
You may object at any time to the future processing of the data concerning you in accordance with the statutory provisions. The objection may in particular be lodged against processing for the purposes of direct marketing.
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 cart 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 can also be stored in such a cookie, which are used for range measurement or marketing purposes.
Third-Party-Cookie“ are cookies that are offered by other providers than the responsible person who operates the online service (otherwise, if they are only their cookies, one speaks of „First-Party Cookies“). We may use temporary and permanent cookies and explain this in our privacy policy. If we ask the user to consent to the use of cookies (e.g. in the context of a cookie consent), the legal basis for this processing is Art. 6 Para. 1 lit. a. GDPR. Otherwise, the personal cookies of the user will be stored according to 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 in the sense of Art. 6 Para. 1 lit. f.).
GDPR or insofar as the use of cookies is necessary for the provision of our contract-related services, pursuant to Art. 6 Para. 1 letter b. GDPR, 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. GDPR, 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 used for online marketing purposes can become the EU website http://www.youronlinechoices.com/erklärt for a large number of services, especially in the case of tracking, via the US American website http://optout.aboutads.info/?c=2&lang=EN
Furthermore, the storage of cookies can be achieved by switching them off 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 Privacy Policy
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 changes in the data processing we carry out make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
Contact us
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 requests) GDPR processed. We will delete the requests if they are no longer necessary. We review the necessity every two years; furthermore, the statutory archiving obligations apply.
Hosting and e-mailing
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 GDPR in conjunction with Art. 28 GDPR (conclusion of contract processing agreement).
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 may entail risks for users, e.g. by making it more difficult to enforce users‘ rights. With respect to US vendors certified under the Privacy Shield, we would like to point out that they are committed to complying with EU privacy standards. Furthermore, user data is usually processed for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the resulting interests of users. The user profiles can in turn be used, for example, to place advertisements inside and outside the platforms which are presumed to 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 be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them). The processing of users‘ personal data is carried out on the basis of our legitimate interests in effective information for users and communication with users pursuant to Art. 6 Para. 1 lit. f. GDPR. If the users are requested by the respective providers of the platforms to give their consent to the aforementioned data processing, the legal basis for the processing is Art. 6 Para. 1 lit. a., Art. 7 GDPR. For a detailed representation of the respective processing and the possibilities of objection (Opt-Out), 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 provide information. If you still need help, please do not hesitate to contact us. – Facebook, Pages, Groups, (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) on the basis of a Joint Processing Agreement – Privacy Statement:
Facebook, Pages, Groups, (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) on the basis of a Joint Processing Agreement – Privacy Statement: 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=adsand 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, Irland) – privacy policy https://policies.google.com/privacy, Opt-Out: https://adssettings.google.com/authenticated
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). GDPR) 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 these contents. We strive to use only those contents, whose respective offerers use the IP address only for the distribution of the contents. Third parties may also use so-called pixel tags (invisible graphics, also known 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 technical information about the browser and operating system, referring websites, visit times and other information about the use of our website, as well as may be linked to such information from other sources.
Google Fonts
Google Fonts We incorporate the fonts („Google Fonts“) of the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. According to Google, user data is used solely for the purpose of displaying fonts in the user’s browser. The integration takes place on the basis of our legitimate interests in a technically secure, maintenance-free and efficient use of fonts, their uniform presentation and consideration of possible licensing restrictions for their integration. Privacy policy: https://www.google.com/policies/privacy/
Google Maps
Google Maps We integrate the maps of the service „Google Maps“ of the provider Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The data processed may include, in particular, IP addresses and location data of users, which are not collected without their consent (usually within the framework of the settings of their mobile devices). The data can be processed in the USA. Privacy Policy: https://www.google.com/policies/privacy/,Opt-Out: https://adssettings.google.com/authenticated.