Member Salma de Nora
SDN Vixion S.L.
Ronda del Oeste 109 bajos local 1
07680 Porto Cristo
Types of data processed:
– Inventory data (Usernames).
– contact information (email).
– content data (e.g., text input, photographs, videos).
– usage data (e.g., websites visited, interest in content, access times).
– Meta / communication data (e.g., device information, IP addresses).
Affected Person Categories
Visitors and Users of the Online Offering (In the following, we collectively refer to the Affected Persons as “Users”)
Purpose of Processing
– Providing the online offering, its features and content.
– Answering contact requests and communicating with users.
– Safety measures
– Audience measurement / Marketing |
“Personal Information” is any information that identifies itself to an identified person or identifiable natural person (hereinafter referred to as “affected person”); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (eg cookie) or to one or more special features, are the expression of the physical, physiological, genetic, mental, economic, cultural or social identity of this 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 covers a wide range and covers virtually every approach to data.
“Pseudonymisation” means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data not assigned to an identified or identifiable natural person.
“Profiling” means any kind of automated processing of personal data which involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to job performance, economic situation, health, personal To analyze or predict preferences, interests, reliability, behavior, location, or location of this natural person.
“Responsible” means the natural or legal person, public authority, agency or other body that alone or together with others decides on the purposes and means of processing personal data
‘Processor’ means a natural or legal person, public authority, body or body that processes personal data on behalf of the controller.
Relevant legal basis
In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 DSGVO, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 (1) lit. b DSGVO, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c DSGVO, and the legal basis for processing for the protection of our legitimate interests Art. 6 para. 1 lit. f DSGVO. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO as legal basis.
In accordance with Art. 32 GDPR, we take into account the state of the art, the implementation costs and the type , the scope, circumstances and purposes of the processing, as well as the different likelihood and severity of the risk to the rights and freedoms of natural persons, appropriate technical and organizational measures to ensure a level of protection commensurate with the risk Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and disconnection. We have also set up procedures to ensure the enjoyment of data subject rights, data deletion and 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 DSGVO).
Collaboration with processors and third parties
If, in the course of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit them to them or otherwise give them access to the Granting of data, this is done only on the basis of a legal permission (eg if a transmission of the data to third parties, as to payment service providers, in accordance with article 6 paragraph 1 letter b DSGVO is necessary to fulfill the contract), you have consented to a legal obligation this provides or based on our legitimate interests (eg the use of agents, webhosters, etc.).
Insofar as we commission third parties to process data on the basis of a so-called “contract processing contract”, this is done on the basis of Art. 28 GDPR.
Transfers to Third Countries
If we process data in a third country (ie 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 If data is passed on to third parties, this will only be done if it is to fulfill 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. DSGVO. That the processing is e.g. on the basis of specific guarantees, such as the officially recognized level of data protection (eg for the USA through the Privacy Shield) or compliance with officially recognized special contractual obligations (so – called “standard contractual clauses”).
Rights of Data Subjects
You have the right to ask for confirmation as to whether such data is being processed and for information about such data and for further information and copying of the data accordingly Art. 15 DSGVO.
You have accordingly. Art. 16 DSGVO the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you.
You have the right to demand that the relevant data be deleted immediately in accordance with Art. 17 GDPR or, alternatively, in accordance with Art. 18 GDPR, require a restriction on the processing of the data.
You have the right to demand that the data relating to you that you provide us in accordance with Art DSGVO and request their transmission to other responsible persons.
You also have gem. Art. 77 DSGVO the right to file a complaint with the competent supervisory authority.
Right of Withdrawal
You have the right to give consent in accordance with Art. Revoke Article 7 (3) of the GDPR with effect for the future
Right to object
You may, in accordance with the provisions of the Art. 21 DSGVO contradict at any time. The objection may in particular be made against processing for purposes of direct mail.
Cookies and the right to object Direct mail
“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 range measurement or marketing purposes. A “third-party cookie” refers to cookies offered by providers other than the person responsible for the online offer (otherwise, if only its cookies are called “first-party cookies”)
If users do not want cookies stored on their computers, they will be asked to select the appropriate option in the system settings of their browser to disable. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies may restrict the functionality 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 4, para. 4 HGB (books, records, management reports, accounting documents, trading books, documents relevant to taxation, etc.) and 6 years pursuant to section 257 (1) nos. 2 and 3, para. 4 HGB (commercial letters).
According to legal regulations in Austria the storage takes place especially for 7 J according to § 132 Abs. 1 BAO (accounting documents, receipts / invoices, accounts, receipts, business papers, statement of income and expenses, etc.), for 22 Years in connection with real estate and for 10 years in the case of documents relating to electronically supplied services, telecommunications, broadcasting and television services provided to non-entrepreneurs in EU Member States and for which the Mini-One-Stop-Shop (MOSS) in
Additionally we process
– contract data (eg, object of contract, term, customer category).
Privacy Notice in Application Procedure
We process the applicant data only for the purpose and in the context of the application process in accordance with the legal requirements. The processing of the applicant data takes place in order to fulfill our (pre) contractual obligations in the context of the application process in the sense of the art. 6 Para. 1 lit. b. DSGVO Art. 6 para. 1 lit. f. DSGVO if the data processing e.g. It is necessary for us in the context of legal proceedings (in Germany, § 26 BDSG also applies).
The application process requires applicants to provide us with the applicant data. The necessary applicant data are, as far as we offer an online form marked, otherwise result from the job descriptions and basically include the information on the person, postal and contact addresses and the application documents, such as cover letter, CV and the certificates. In addition, applicants may voluntarily provide us with additional information.
Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are voluntarily communicated within the framework of the application procedure, their processing is additionally carried out in accordance with Art. 9 (2) lit. b DSGVO (e.g., health information such as disability or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are requested from applicants in the context of the application procedure, their processing is additionally carried out in accordance with Art. 9 para. 2 lit. a GDPR (for example, health data if necessary for the profession)
If provided, applicants can submit their applications via our online web site on our website. The data will be transmitted in encrypted form according to the state of the art.
Furthermore, applicants can send us their applications via e-mail. However, please note that e-mails are generally not sent in encrypted form and that applicants themselves must provide encryption. We can therefore take no responsibility for the transmission of the application between the sender and the reception on our server and therefore recommend rather to use an online form or the postal delivery. Because instead of applying via the online form and e-mail, applicants still have the option of sending us the application by post.
The data provided by the applicants can be used in the case of a successful application for employment purposes. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which the applicants are entitled to do at any time.
The deletion is subject to a legitimate revocation of the candidates, after the expiration of a period of six months, so that we may To answer follow-up questions about the application and to fulfill our obligations under the Equal Treatment Act. Invoices for any reimbursement of travel expenses will be archived according to the tax regulations.
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Users can create a user account. As part of the registration, the required mandatory information is communicated to the users and based on Art. 6 para. 1 lit. b DSGVO processed for purposes of providing the user account. The processed data include in particular the login information (name, password and an e-mail address). The data entered during registration will be used for the purpose of using the user account and its purpose.
Users can access information relevant to their user account, such as: technical changes, be informed by e-mail. If users have terminated their user account, their data will be deleted with respect to the user account, subject to a statutory retention requirement. It is the responsibility of the users to secure their data upon termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract.
As part of the use of our registration and registration functions as well as the use of 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 transfer of these data to third parties does not take place, unless it is necessary for the prosecution of our claims or there is a legal obligation in accordance with. Art. 6 para. 1 lit. c. DSGVO. The IP addresses will be anonymized or deleted after 7 days at the latest.
Retrieving profile pictures on Gravatar
We’re putting in ours On-line offerings and in particular the blog Gravatar of Automattic Inc., 60 29th Street # 343, San Francisco, CA 94110, USA, in particular on the blog.
Gravatar is a service where users log in and profile pictures and their E -Mail addresses can deposit. If users with the respective e-mail address on other online sites (especially in blogs) leave posts or comments, so their profile pictures can be displayed next to the posts or comments. For this purpose, the e-mail address communicated by the users to Gravatar is transmitted encrypted in order to check whether a profile is stored for it. This is the sole purpose of the transmission of the e-mail address and it will not be used for other purposes, but will be deleted.
The use of Gravatar is based on our legitimate interests within the meaning of Art. 6 para. 1 lit. , f) DSGVO, because with the help of Gravatar we offer the post and comment writers the possibility to personalize their posts with a profile picture.
By displaying the pictures Gravatar knows the IP address of the users, because this is necessary for communication between a browser and an online service. For more information about Gravatar’s collection and use of the data, see the Automattic Privacy Notice: https://automattic.com/privacy/ .
If users do not want a user picture linked to their email address on Gravatar to appear in the comments, you should use a non-Gravatar email address to comment is deposited. We also point out that it is also possible to use an anonymous or even no e-mail address if the users do not want their own e-mail address to be sent to Gravatar. Users can completely prevent the transfer of data by not using our annotation system.
When contacting us (eg via contact form, e-mail, telephone or via social media) the information provided by the user will be used to process the contact request and process it gem. Art. 6 para. 1 lit. b. (in the context of contractual / pre-contractual relationships), Art. 6 para. 1 lit. f. (other requests) DSGVO processed .. User information can be stored in a Customer Relationship Management System (“CRM System”) or similar request organization.
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 registration, dispatch and statistical evaluation procedures as well as your right of objection. By subscribing to our newsletter, you agree to the receipt and the procedures described.
Content of the newsletter: We send out newsletters, e-mails and other electronic notifications with promotional information (hereinafter “newsletter”) only with the consent of the recipient or a legal permit. Insofar as the contents of a newsletter are concretely described, they are authoritative for the consent of the users. Incidentally, our newsletters contain information about our services and us.
Double-Opt-In and logging: Registration for our newsletter takes place 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. Similarly, changes to your data stored with the shipping service provider will be logged.
Login credentials: To sign up for the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to give a name in the newsletter for personal address.
The dispatch of the newsletter and the related performance measurement are based on the consent of the recipients acc. Art. 6 para. 1 lit. a, Art. 7 DSGVO 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. DSGVO i.V.m. § 7 Abs. 3 UWG.
The logging of the registration procedure takes place on the basis of our legitimate interests acc. Art. 6 para. 1 lit. f DSGVO. Our interest is 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 provide evidence of consent.
Cancellation – You can have the reception terminate 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 defense against claims. An individual request for cancellation is possible at any time, provided that the former existence of a consent is confirmed at the same time.
Newsletter – Success Measurement
The newsletter contains a so-called “web-beacon”, ie a pixel-sized file that is retrieved from the server when opening the newsletter from our server, or if we use a shipping 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 assigned to the individual newsletter recipients. However, it is neither our goal nor, if used, that of the shipping service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different contents according to the interests of our users.
A separate revocation of the performance measurement is unfortunately not possible, in this case the entire newsletter subscription must be canceled.