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Privacy Policy

In this privacy policy, we inform you about the processing of personal data when using our website.

Personal data is information that relates to an identified or identifiable person. This primarily includes information that allows conclusions to be drawn about your identity, for example your name, telephone number, address or e-mail address. Statistical data that we collect, for example, during a visit to our website and that cannot be associated with your person do not fall under the concept of personal data.

Content of this privacy policy‍‍

1. contact person

2. data processing on our website

2.1 Calling up our website / access data

2.2 Contacting

‍3. Use of cookies and comparable technologies

‍3.1 Legal basis and revocation‍

3.2 Essential tools

3.3 Functional tools

3.4 Analysis tools

3.5 Marketing tools

4. online presence in social networks

5. disclosure of data

6. data transfer to third countries

7. storage period

8. your rights, in particular revocation and objection

9. changes to the privacy policy

1. contact person

 

Contact person and so-called responsible for the processing of your personal data when visiting this website within the meaning of the General Data Protection Regulation (GDPR) is

VENMATE GmbH

Zionskirchstraße 49

10119 Berlin

E-Mail: privacy@ven-mate.com


For all questions regarding data protection in connection with our products and services or the use of our website, you can also contact our data protection officer at any time. He or she can be reached at the above postal address and at the e-mail address given above (keyword: "Data Protection Officer"). We expressly point out that if you use this e-mail address, the contents will not be exclusively noted by our data protection officer. If you wish to exchange confidential information, please therefore first contact us directly via this e-mail address.

2. data processing on our website

2.1 Calling up our website / access data

 

Each time you use our website, we collect the access data that your browser automatically transmits to enable you to visit the website. The access data includes in particular:

IP address of the requesting computer,

date and time of access,

name and URL of the accessed file,

website from which the access is made (referrer ULR),

the browser used and, if applicable, the operating system of your computer and the name of your access provider.


The data processing of this access data is necessary to enable the visit of the website and to ensure the permanent functionality and security of our systems. The access data is also temporarily stored in internal log files for the purposes described above, in order to compile statistical information about the use of our website, to further develop our website with regard to the usage habits of our visitors (e.g. if the proportion of mobile devices used to access the pages increases) and for general administrative maintenance of our website.

The legal basis is Art. 6 para. 1 p. 1 lit. b DSGVO, insofar as the page call occurs in the course of the initiation or execution of a contract, and otherwise Art. 6 para. 1 p. 1 lit. f DSGVO due to our legitimate interest in the permanent functionality and security of our systems.

The data is deleted as soon as it is no longer required for the purpose for which it was collected. When collecting data to provide the website, this is the case when the respective session has ended.

2.2 Contacting

 

You have various options for contacting us. These include the contact under the e-mail addresses listed in the imprint, the contact form. In this context, we process data exclusively for the purpose of communicating with you.

The legal basis is Art. 6 para. 1 p. 1 lit. b DSGVO, insofar as your information is required to answer your inquiry or to initiate or execute a contract, and otherwise Art. 6 para. 1 p. 1 lit. f DSGVO due to our legitimate interest that you contact us and we can answer your inquiry. We only make promotional telephone calls if you have given your consent for this. If you are not an existing customer, we will also send you promotional e-mails only on the basis of your consent. The legal basis in these cases is Art. 6 para. 1 p. 1 lit. a DSGVO.

The data we collect when you use the contact form will be automatically deleted after we have fully processed your request, unless we still need your request to fulfill contractual or legal obligations (see section 7 "Storage period").



3. Use of cookies and comparable technologies

 

This website uses cookies and similar technologies (collectively, "Tools"), either provided by us or by third parties.

A cookie is a small text file that is stored on your device by the browser. Cookies are not used to run programs or download viruses onto your computer. Comparable technologies are in particular web storage (local / session storage), fingerprints, tags or pixels. Most browsers are set by default to accept cookies and comparable technologies. However, you can usually adjust your browser settings so that cookies or comparable technologies are rejected or stored only with your prior consent. If you reject cookies or comparable technologies, not all of our offers may work properly for you.

The following lists the tools we use by category, informing you in particular about the providers of the tools, the storage period of the cookies and the transfer of data to third parties. We also explain in which cases we obtain your voluntary consent to use the tools and how you can revoke this consent.



3.1 Legal basis and revocation

3.1.1 Legal basis


We use tools necessary for website operation on the basis of our legitimate interest pursuant to Art. 6 (1) p. 1 lit. f DSGVO to enable you to use our website more conveniently and individually and to make use as time-saving as possible. In certain cases, these tools may also be necessary for the performance of a contract or for the implementation of pre-contractual measures, in which case the processing is carried out in accordance with Art. 6 para. 1 p. 1 lit. b DSGVO.

We use other tools, in particular those for marketing purposes, based on your consent in accordance with Art. 6 para. 1 p. 1 lit. a DSGVO and in accordance with Section 15 para. 3 p. 1 TMG, insofar as usage profiles are created for the purposes of advertising or market research. Data processing with the help of these tools only takes place if we have received your prior consent for this.

If personal data is transferred to third countries, we refer you to section 6 ("Data transfer to third countries"), also with regard to the possible associated risks. We will inform you if we have concluded standard contractual clauses or other guarantees with the providers of certain tools. If you have given your consent to use certain tools, we (also) transfer the data processed when using the tools to third countries on the basis of this consent.


3.1.2 Obtaining your consent


To obtain and manage your consents, we use a cookie banner that informs you about the data processing on our website and gives you the opportunity to consent to all, individual or no data processing through optional tools. This banner appears the first time you visit our website. The banner also appears on subsequent visits to our website, provided that you have deactivated the storage of cookies or the cookie has been deleted by Wix or has expired.

Your consents or revocations, your IP address, information about your browser, your terminal device and at the time of your visit are transmitted to the tool. In addition, the tool sets a necessary cookie to store the consents and revocations you have given. If you delete your cookies, we will ask you for your consent again when you visit the site at a later time.

Data processing by the tool is necessary to provide you with the legally required consent management and to comply with our documentation obligations. The legal basis for the use of the banner is Art. 6 para. 1 p. 1 lit. f DSGVO, justified by our interest in fulfilling the legal requirements for cookie consent management.

 


3.1.3 Revoking your consent or changing your selection


You can revoke your consent for certain tools at any time. To do so, you can assert your revocation for certain tools directly with the provider.

3.2 Essential tools

 

We use certain tools to enable the basic functions of our website ("essential tools"). Without these tools, we could not provide our service. Therefore, essential tools are used without consent based on our legitimate interests according to Art. 6 para. 1 p. 1 lit. f DSGVO or to fulfill a contract or to perform pre-contractual measures according to Art. 6 para. 1 p. 1 lit. b DSGVO.

3.2.1 Google Tag Manager

 

Our website uses Google Tag Manager, a service provided for users from the European Economic Area and Switzerland by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland and for all other users by Google LLC 1600 Amphitheatre Parkway Mountain View, CA 94043, USA (together "Google").

The Tag Manager is used to manage tracking tools and other services, so-called website tags. A tag is an element that is stored in the source code of our website, for example, to record specified usage data. The Google Tag Manager ensures that the usage data required by our partners is forwarded to them.

The Google Tag Manager does not require the use of cookies.

The legal basis is Art. 6 (1) p. 1 lit. f DSGVO, based on our legitimate interest in integrating and managing multiple tags on our website in a straightforward manner.

We have concluded an order processing agreement with Google. Partially, data is processed on a Google server in the USA. In the event that personal data is transferred to the USA or other third countries, we have concluded standard contractual clauses with Google pursuant to Art. 46 (2) lit. c DSGVO. For more information, please refer to section 6 ("Data transfer to third countries").

For more information, please refer to Google's information on the Tag Manager.

3.2.2 Google reCAPTCHA

 

Our website uses the Google reCAPTCHA service, which is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland for users from the European Economic Area and Switzerland and by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (together "Google") for all other users.

reCAPTCHA prevents automated software (so-called bots) from carrying out abusive activities on the website, i.e. it checks whether the entries made actually originate from a human. To determine this, the following data is processed:

Referrer URL (address of the page from which the visitor came);

IP address;

Cookies set by Google;

Snapshot of the browser window;

User input behavior (e.g. answering the reCAPTCHA question, input speed in form fields, order in which the user selects input fields, number of mouse clicks);

Technical information: Browser type, browser plug-ins, browser size and resolution, date, language setting, display instructions (CSS) and scripts (Javascript).

Furthermore, Google reads the cookies from other Google services such as Gmail, Search and Analytics. If you do not wish this assignment to your Google account, it is necessary that you log out of Google before calling up a page where we have integrated Google reCAPTCHA.

The aforementioned data is sent to Google in encrypted form. Google's evaluation decides in which form the captcha is displayed on the page. The use of reCAPTCHA is evaluated statistically. According to Google, your data will not be used for personalized advertising.

legal basis is the necessity for the fulfillment of a contract or for the implementation of pre-contractual measures according to Art. 6 para. 1 p. 1 lit. b DSGVO, for example in the context of the registration of a user account, the use of a contact form or the subscription to a newsletter. Google reCAPTCHA serves to protect IT security, ensure the stability of our website and prevent misuse.

In some cases, the data may also be processed on servers in the USA. In the event that personal data is transferred to the USA or other third countries, this is done on the basis of Art. 49 (1) p. 1 lit. b DSGVO to enable the fulfillment of a contract with you or the implementation of pre-contractual measures. For more information, please refer to section 6 ("Data transfer to third countries").

For more information, please refer to the privacy policy and terms of use of Google.

3.3 Functional tools

 

Functional tools are used to improve the user experience on our website and to offer you more features ("functional tools"). While these are not strictly necessary for the basic functionality of the website, they can bring significant benefits to users, especially in terms of user experience and the provision of additional communication, display or payment channels.

- We do not currently use functional tools -

3.4 Analysis tools

 

In order to improve our website, we use tools for statistical collection and analysis of general usage behavior based on access data ("analysis tools"). We also use analytics services to evaluate the use of our various marketing channels.

Legal basis for the analytics tools is - unless otherwise stated - your consent according to Art. 6 para. 1 p. 1 lit. a DSGVO. For revocation of your consent, see 3.1.3: "Revoking your consent or changing your selection". In the event that personal data is transferred to the USA or other third countries, your consent expressly extends to the data transfer (Art. 49 (1) p. 1 lit. a DSGVO). Please refer to section 6("Data transfer to third countries") for the associated risks.

3.4.1 Google Analytics

 

Our website uses Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). According to Google, the contact for all data protection issues is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics uses cookies and similar technologies to analyze and improve our website based on your user behavior. Google will process the information obtained for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. The data generated in this context may be transferred by Google to a server in the USA for evaluation and stored there.

We have made the following data protection settings for Google Analytics:

IP anonymization (shortening of the IP address before evaluation so that no conclusions can be drawn about your identity)

Automatic deletion of old logs / limitation of the storage period

Deactivated advertising function (including target group remarketing by GA Audience)

Deactivated personalized ads

Deactivated Measurement Protocol

Deactivated cross-page tracking (Google signals)

Deactivated data sharing with other Google products and services

The following data is processed by Google Analytics:

Anonymized IP address;

Referrer URL (previously visited page);

Pages viewed (date, time, URL, title, time spent);

Files downloaded;

Links clicked to other websites;

If applicable. Achievement of specific goals (conversions);

Technical information: Operating system; browser type, version and language; device type, brand, model and resolution;

Approximate location (country and city, if applicable, based on anonymized IP address).

Google Analytics sets the following cookies for the specified purpose with the respective storage period:

"_ga" for 2 years and "_gid" for 24 hours (both to recognize and distinguish website visitors by a user ID);

"_gat" for 1 minute (to reduce requests to the Google servers);

We have concluded an order processing agreement with Google for the use of Google Analytics as well as standard contractual clauses in the event that personal data is transferred to the USA or other third countries.

For more information, please refer to Google's privacy policy.

3.5 Marketing tools

 

We also use tools for advertising purposes ("marketing tools"). Some of the access data collected when using our website is used for interest-based advertising. By analyzing and evaluating this access data, it is possible for us to present you with personalized advertising, i.e. advertising that corresponds to your actual interests and needs, on our website and on the websites of other providers.

The legal basis for the marketing tools is your consent pursuant to Art. 6 (1) sentence 1 lit. a DSGVO. For revocation of your consent, see 3.1.3: "Revoking your consent or changing your selection". In the event that personal data is transferred to the USA or other third countries, your consent expressly extends to the data transfer (Art. 49 (1) p. 1 lit. a DSGVO). Please refer to Section 6 ("Data transfer to third countries") for the associated risks.

In the following section, we would like to explain these technologies and the providers used for this purpose in more detail. The data collected may include in particular:

the IP address of the device;

the identification number of a cookie;

the device ID of mobile devices;

referrer URL (previously visited page);

pages viewed (date, time, URL, title, duration of visit);

files downloaded;

links clicked to other websites;

if applicable, achievement of certain goals (conversions);

technical information: Operating system; browser type, version, and language; device type, brand, model, and resolution;

Approximate location (country and, if applicable, city).

However, the data collected is stored exclusively pseudonymously, so that no direct conclusions can be drawn about individuals.


 

3.5.1 Google Marketing Platform and Ad Manager (formerly DoubleClick)

 

Our website uses the Google Marketing Platform and the Google Ad Manager, services which are offered for users from the European Economic Area and Switzerland by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland and for all other users by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (together "Google").

These services use cookies and similar technologies to present you with advertisements that are relevant to you. The use of the services enables Google and its partner websites to display ads based on previous visits to our website or other websites on the Internet.

The data generated in this context may be transmitted by Google to a server in the USA for analysis and stored there. In the event that personal data is transferred to the USA, we have concluded standard contractual clauses with Google.

If you have not consented to the use of Google Marketing Platform and Ad Manager, Google will only display general advertising that has not been selected on the basis of the information collected about you on this website. In addition to withdrawing your consent, you also have the option of deactivating personalized advertising in Google's advertising settings.

The following cookies are set by Google:

"IDE" for 12 months.

For more information, please refer to Google's privacy policy.

3.6 Social media plugins and external media

 

We also use social network tools that are used to log in to the website with existing user accounts or to share posts and content via these networks ("social media plugins"), as well as other external media, such as embedded videos or maps.

Unless otherwise stated, the legal basis for this is your consent pursuant to Art. 6 (1) p. 1 lit. a DSGVO, which you give via the cookie banner or with the respective tool itself by individually allowing its use via a banner (overlay) placed over it. For the revocation of your consent, see 4.1.3: "Revoking your consent or changing your selection". In the event that personal data is transferred to the USA or other third countries, your consent expressly extends to the data transfer (Art. 49 (1) p. 1 lit. a DSGVO). Please refer to section 6("Data transfer to third countries") for the associated risks.

4. Online presence in social networks

 

We maintain online presences in social networks in order to communicate there with customers and interested parties, among other things, and to inform them about news from VENMATE.

The data of the users are usually processed by the social networks concerned for market research and advertising purposes. Thus, usage profiles can be created based on the interests of the users. For this purpose, cookies and other identifiers are stored on the users' computers. Based on these usage profiles, advertisements, for example, are then placed within the social networks but also on third-party websites.

As part of the operation of our online presences, it is possible that we can access information such as statistics on the use of our online presences, which are provided by the social networks. These statistics are aggregated and may include, in particular, demographic information and data on interaction with our online presences and the posts and content distributed through them. For details and links to the data of the social networks that we as operators of the online presences can access, please refer to the list below.

Legal basis for data processing is Art. 6 para. 1 p. 1 lit. f DSGVO, based on our legitimate interest in effective information of users and communication with users, respectively Art. 6 para. 1 p. 1 lit. b DSGVO, in order to stay in contact with and inform our customers, as well as to carry out pre-contractual measures with future customers and interested parties.

For the legal basis of the data processing carried out by the social networks on their own responsibility, please refer to the privacy notices of the respective social network. The links below also provide you with further information on the respective data processing as well as the options to object.

We would like to point out that data protection requests can be asserted most efficiently with the respective provider of the social network, as only these providers have access to the data and can take appropriate measures directly. Below is a list with information on the social networks on which we operate online presences:

 

5. disclosure of data

 

The data we collect will only be disclosed if:

you have given your express consent pursuant to Art. 6 (1) sentence 1 lit. a DSGVO,

the disclosure pursuant to Art. 6 (1) sentence 1 lit. f DSGVO is necessary for the assertion, exercise or defense of legal claims and there is no reason to believe that you have an overriding legitimate interest in not having your data disclosed,

we are legally obligated to disclose your data pursuant to Art. 6 (1) sentence 1 lit. c DSGVO or this is legally permissible and required for the processing of contractual relationships pursuant to Art. 6 (1) sentence 1 lit. b DSGVO. 6 para. 1 p. 1 lit. c DSGVO we are legally obliged to disclose your data or

this is legally permissible and necessary according to Art. 6 para. 1 p. 1 lit. b DSGVO for the processing of contractual relationships with you or for the implementation of pre-contractual measures, which are carried out at your request.

Part of the data processing may be carried out by our service providers. In addition to the service providers mentioned in this privacy policy, this may include, in particular, data centers that store our website and databases, software providers, IT service providers that maintain our systems, agencies, market research companies, group companies and consulting companies. If we pass on data to our service providers, they may only use the data to perform their tasks. The service providers have been carefully selected and commissioned by us. They are contractually bound to our instructions, have suitable technical and organizational measures in place to protect the rights of the data subjects, and are regularly monitored by us.

In addition, data may be disclosed in connection with official inquiries, court orders, and legal proceedings if this is necessary for legal prosecution or enforcement.

6. data transfer to third countries

 

As explained in this Privacy Policy, we use services whose providers are partly located in so-called third countries (outside the European Union or the European Economic Area) or process personal data there, i.e. countries whose level of data protection does not correspond to that of the European Union. Insofar as this is the case and the European Commission has not issued an adequacy decision (Art. 45 GDPR) for these countries, we have taken appropriate precautions to ensure an adequate level of data protection for any data transfers. These include, among others, the standard contractual clauses of the European Union or binding internal data protection regulations.

Where this is not possible, we base the data transfer on exceptions of Art. 49 DSGVO, in particular your explicit consent or the necessity of the transfer for the performance of the contract or for the implementation of pre-contractual measures.

If a third country transfer is provided for and no adequacy decision or appropriate safeguards are in place, it is possible and there is a risk that authorities in the respective third country (e.g. intelligence services) may gain access to the transferred data in order to collect and analyze it, and that enforceability of your data subject rights cannot be guaranteed. When obtaining your consent via the cookie banner, you will also be informed of this.

7. storage period

 

In principle, we store personal data only as long as necessary to fulfill the purposes for which we collected the data. Thereafter, we delete the data immediately, unless we still need the data until the expiry of the statutory limitation period for evidence purposes for claims under civil law or due to statutory retention obligations.

For evidence purposes, we must retain contractual data for three years from the end of the year in which the business relationship with you ends. Any claims become statute-barred at this point at the earliest in accordance with the standard statutory limitation period.

Even after this, we still have to store some of your data for accounting reasons. We are obliged to do so because of legal documentation obligations that may arise from the German Commercial Code, the German Fiscal Code, the German Banking Act, the German Money Laundering Act and the German Securities Trading Act. The periods specified there for the retention of documents are two to ten years.

8. your rights, in particular revocation and objection

 

You are entitled to the data subject rights formulated in Art. 15 - 21, Art. 77 DSGVO at any time:

Right to withdraw your consent;

Right to object to the processing of your personal data (Art. 21 DSGVO);

Right to information about your personal data processed by us (Art. 15 DSGVO);

Right to correct your personal data stored by us that is incorrect (Art. 16 GDPR);

right to erasure of your personal data (Art. 17 GDPR);

right to restriction of the processing of your personal data (Art. 18 GDPR);

right to data portability of your personal data (Art. 20 GDPR);

right to lodge a complaint with a supervisory authority (Art. 77 GDPR).

To exercise your rights described here, you may contact us at any time using the contact details provided above. This also applies if you wish to receive copies of guarantees demonstrating an adequate level of data protection. Provided that the respective legal requirements are met, we will comply with your data protection request.

Your requests to assert data protection rights and our responses to them will be stored for documentation purposes for a period of up to three years and, in individual cases, for the assertion, exercise or defense of legal claims even longer. The legal basis is Art. 6 ( 1) p. 1 lit. f DSGVO, based on our interest in defending against any civil claims under Art. 82 DSGVO, avoiding fines under Art. 83 DSGVO and fulfilling our accountability obligations under Art. 5 (2) DSGVO.

You have the right to revoke consent you have given to us at any time. This has the consequence that we no longer continue the data processing based on this consent for the future. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

If we process your data on the basis of legitimate interests, you have the right to object to the processing of your data at any time on grounds relating to your particular situation. If it is a matter of objecting to data processing for direct marketing purposes, you have a general right of objection, which will also be implemented by us without giving reasons.

If you wish to exercise your right of revocation or objection, an informal communication to the contact details above will suffice.

Finally, you have the right to complain to a data protection supervisory authority. You can assert this right at a supervisory authority in the member state of your residence, your place of work or the place of the alleged infringement. In Berlin, our headquarters, the competent supervisory authority is: Berlin 

9. changes to the privacy policy

 

We occasionally update this privacy statement, for example, when we adapt our website or when legal or regulatory requirements change.



Version: 1.0 / Status: November 23

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