Privacy Policy
Preamble
With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as "data") that we process, for what purposes, and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the provision of our services and in particular on our websites, mobile applications, and external online presences, such as our social media profiles (hereinafter collectively referred to as "online offering").
The terms used are not gender-specific.
As of: October 5, 2023
Table of Contents
- Preamble
- Controller
- Overview of Processing Activities
- Legal Bases for Processing
- Security Measures
- Transfer of Personal Data
- Data Processing in Third Countries
- Deletion of Data
- Use of Cookies
- Provision of the Online Offering and Web Hosting
- Contact and Inquiry Management
- Modification and Update of the Privacy Policy
- Rights of Data Subjects
- Definitions
Controller
unframe GmbH
Viktoriaallee 4
16547 Birkenwerder
Represented by:
Tim Ebert
Maximilian Hackbarth
Sebastian Wloch
Contact:
Phone: +49 (0) 3303 8172815
Email: info@unframe.io
Overview of Processing Activities
The following overview summarizes the types of data processed and the purposes of their processing, and refers to the data subjects.
Types of processed data
- Contact details.
- Content data.
- Usage data.
- Meta, communication, and procedural data.
Categories of data subjects
- Communication partners.
- Users.
Purposes of processing
- Contact inquiries and communication.
- Security measures.
- Management and response to inquiries.
- Feedback.
- Provision of our online offering and user-friendliness.
- Information technology infrastructure.
Legal Bases for Processing
Below, we provide an overview of the legal bases of the GDPR on which we process personal data. Please note that in addition to the provisions of the GDPR, national data protection regulations may apply in your or our country of residence or domicile. Furthermore, if more specific legal bases are applicable in individual cases, we will inform you of these in the privacy policy.
- Consent (Art. 6 (1) (a) GDPR) - The data subject has given consent to the processing of his or her personal data for one or more specific purposes.
- Performance of a contract and pre-contractual inquiries (Art. 6 (1) (b) GDPR) - Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
- Legitimate interests (Art. 6 (1) (f) GDPR) - Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
Security Measures
We implement appropriate technical and organizational measures in accordance with legal requirements, taking into account the state of the art, the implementation costs, and the nature, scope, context, and purposes of processing as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons.
These measures include, in particular, ensuring the confidentiality, integrity, and availability of data by controlling physical and electronic access to the data as well as the access, input, disclosure, availability, and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data, and the response to data threats. We also take into account the protection of personal data when developing or selecting hardware, software, and procedures, in accordance with the principle of data protection through technology design and data protection-friendly default settings.
TLS encryption (https): To protect your data transmitted via our online offering, we use TLS encryption. You can recognize encrypted connections by the prefix https:// in the address line of your browser.
Transfer of Personal Data
As part of our processing of personal data, it may be necessary to transfer the data to other entities, companies, legally independent organizational units, or individuals or to disclose them to them. These recipients may include, for example, IT service providers or providers of services and content that are integrated into a website. In such cases, we comply with legal requirements and, in particular, conclude appropriate contracts or agreements with the recipients of your data that serve to protect your data.
Data Processing in Third Countries
If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities, or companies, this will only occur in accordance with legal requirements.
Subject to express consent or contractual or legal transfer, we process or have the data processed only in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications, or binding internal data protection regulations (Articles 44 to 49 GDPR, Information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_en).
Deletion of Data
The data processed by us will be deleted or their processing restricted in accordance with legal requirements as soon as their storage is no longer necessary for the purposes for which they were collected or if you revoke your consent. If the data is not deleted because it is required for other and legally permissible purposes, its 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 retained for commercial or tax reasons or that is necessary for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person.
Our privacy policy may also provide further information on the retention and deletion of data that is specific to the respective processing activities.
Use of Cookies
Cookies are small text files or other storage technologies that store and retrieve information on your device. For example, to store the login status in a user account, the contents of a shopping cart in an online store, or the visited pages and used functions of an online offering. Cookies can also be used for different purposes, such as functionality, security, and convenience of online offerings, as well as for analyzing visitor traffic.
Consent Notice: We use cookies in accordance with legal requirements. Therefore, we obtain prior consent from users, unless it is not required by law. Consent is not required, in particular, if the storage and retrieval of information, including cookies, is absolutely necessary to provide users with an expressly requested telemedia service (i.e., our online offering). Cookies that are absolutely necessary usually include cookies with functions that serve the display and functionality of the online offering, load balancing, security, storage of user preferences and choices, or similar purposes related to the provision of the main and ancillary functions of the online offering requested by users. The revocable consent is clearly communicated to users and includes information about the specific use of cookies.
Legal Bases for Data Processing: The legal basis for processing personal data using cookies depends on whether we ask users for consent. If users give their consent, the legal basis for processing their data is the declared consent. Otherwise, the data processed using cookies is based on our legitimate interests (e.g., in the economic operation of our online offering and the improvement of its usability) or, if the use of cookies is necessary to fulfill our contractual obligations, on the performance of a contract. We will inform users about the purposes for which we process cookies as part of this privacy policy or as part of our consent and processing procedures.
Storage Duration: With regard to the storage duration, the following types of cookies are distinguished:
- Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed his browser or mobile application.
- Persistent cookies: Persistent cookies remain stored even after closing the device. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, data collected using cookies can be used for reach measurement. If we do not provide explicit information about the type and duration of cookies (e.g., as part of obtaining consent), users should assume that cookies are persistent and can have a storage duration of up to two years.
General Notice on Revocation and Objection (Opt-Out): Users can revoke their consent at any time and also object to the processing of their data in accordance with the legal requirements of Art. 21 GDPR. Users can also declare their objection through the settings of their browser, for example, by deactivating the use of cookies (which may also restrict the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.
Further Information on Processing Procedures, Procedures, and Services:
Provision of the Online Offering and Web Hosting
We process user data to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary to transmit the contents and functions of our online services to the user's browser or device.
- Processed data types: Usage data (e.g., websites visited, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of our online offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); Security measures.
- Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).
Further Information on Processing Procedures, Procedures, and Services:
Contact and Inquiry Management
When contacting us (e.g., by post, contact form, email, telephone, or via social media) and in the context of existing user and business relationships, the information provided by the inquiring individuals is processed to the extent necessary to respond to the contact inquiries and any requested measures.
Further Information on Processing Procedures, Procedures, and Services:
Modification and Update of the Privacy Policy
We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as changes in 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.
If we provide addresses and contact information of companies and organizations in this privacy policy, we ask you to note that the addresses may change over time and to check the information before contacting us.
Rights of Data Subjects
As data subjects, you have various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
Our privacy policy may also provide further information on the retention and deletion of data that is specific to the respective processing activities.
Use of Cookies
Cookies are small text files or other storage markers that store information on end devices and read information from end devices. For example, to store the login status in a user account, the contents of a shopping cart in an e-shop, the accessed content, or the used functions of an online offering. Cookies can also be used for various purposes, such as ensuring the functionality, security, and convenience of online offerings, as well as creating analyses of visitor traffic.
Consent Notice: We use cookies in accordance with legal requirements. Therefore, we obtain prior consent from users, unless it is not required by law. Consent is not necessary, in particular, if storing and reading the information, including cookies, is absolutely necessary to provide users with a telemedia service expressly requested by them (i.e., our online offering). Cookies that are absolutely necessary usually include cookies with functions that serve the display and functionality of the online offering, load balancing, security, storage of user preferences and choices, or similar purposes related to the provision of the main and ancillary functions of the online offering requested by users. The revocable consent is clearly communicated to users and contains information about the respective cookie usage.
Information on the Legal Bases of Data Processing: The legal basis on which we process users' personal data using cookies depends on whether we ask users for consent. If users give their consent, the legal basis for processing their data is the declared consent. Otherwise, the data processed using cookies is based on our legitimate interests (e.g., in the commercial operation of our online offering and improving its usability) or, if the use of cookies is necessary to fulfill our contractual obligations, the legal basis is the performance of a contract. We will clarify the purposes for which we process cookies in the course of this privacy policy or as part of our consent and processing procedures.
Storage Duration: With regard to the storage duration, the following types of cookies are distinguished:
- Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user has left an online offering and closed his browser or mobile application.
- Persistent cookies: Persistent cookies remain stored even after closing the device. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, data collected using cookies can be used for reach measurement. If we do not provide explicit information about the type and duration of cookies (e.g., as part of obtaining consent), users should assume that cookies are persistent and can have a storage duration of up to two years.
General Notice on Revocation and Objection (Opt-Out): Users can revoke their consent at any time and also object to the processing of their data in accordance with the legal requirements of Art. 21 GDPR. Users can also declare their objection through the settings of their browser, for example, by deactivating the use of cookies (which may also restrict the functionality of our online services). An objection to the use of cookies for online marketing purposes can also be declared via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/.
- Legal Bases: Legitimate interests (Art. 6 (1) (f) GDPR); Consent (Art. 6 (1) (a) GDPR).
Further Information on Processing Procedures, Procedures, and Services:
Provision of the Online Offering and Web Hosting
We process user data to provide them with our online services. For this purpose, we process the IP address of the user, which is necessary to transmit the contents and functions of our online services to the user's browser or device.
- Processed data types: Usage data (e.g., websites visited, interest in content, access times); Meta, communication, and procedural data (e.g., IP addresses, time information, identification numbers, consent status).
- Data subjects: Users (e.g., website visitors, users of online services).
- Purposes of processing: Provision of our online offering and user-friendliness; Information technology infrastructure (operation and provision of information systems and technical devices (computers, servers, etc.)); Security measures.
- Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).
Further Information on Processing Procedures, Procedures, and Services:
- Provision of online offering on rented storage space: For the provision of our online offering, we use storage space, computing capacity, and software that we rent or otherwise obtain from a corresponding server provider (also known as "web hoster"); Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR).
- Collection of access data and log files: Access to our online offering is logged in the form of so-called "server log files". Server log files may include the address and name of the accessed websites and files, date and time of access, transferred data volumes, message about successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), and usually IP addresses and the requesting provider. Server log files can be used for security purposes, for example, to avoid overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure the load balancing and stability of the servers; Legal bases: Legitimate interests (Art. 6 (1) (f) GDPR); Data deletion: Log file information is stored for a maximum of 30 days and then deleted or anonymized. Data whose further storage is necessary for evidentiary purposes is excluded from deletion until the respective incident has been finally clarified.
Contact and Inquiry Management
When contacting us (e.g., by post, contact form, email, telephone, or via social media) and in the context of existing user and business relationships, the information provided by the inquiring individuals is processed to the extent necessary to respond to the contact inquiries and any requested measures.
Further Information on Processing Procedures, Procedures, and Services:
- Contact form: When users contact us via our contact form, email, or other communication channels, we process the data provided to us in this context to process the respective request; Legal bases: Performance of a contract and pre-contractual inquiries (Art. 6 (1) (b) GDPR), Legitimate interests (Art. 6 (1) (f) GDPR).
Modification and Update of the Privacy Policy
We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy policy as soon as changes in 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.
If we provide addresses and contact information of companies and organizations in this privacy policy, we ask you to note that the addresses may change over time and to check the information before contacting us.
Rights of Data Subjects
As data subjects, you have various rights under the GDPR, which arise in particular from Art. 15 to 21 GDPR:
- Right to object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on Article 6(1)(e) or (f) GDPR, including profiling based on those provisions. If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
- Right to withdraw consent: You have the right to withdraw your consent at any time.
- Right to information: You have the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and further information and a copy of the data in accordance with legal requirements.
- Right to rectification: You have the right to obtain the rectification of inaccurate personal data concerning you and to have incomplete personal data completed in accordance with legal requirements.
- Right to erasure and restriction of processing: You have the right, in accordance with legal requirements, to obtain the erasure of personal data concerning you without undue delay or alternatively to obtain restriction of processing of the data.
- Right to data portability: You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used, and machine-readable format or to request the transmission of that data to another controller in accordance with legal requirements.
- Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.
Definition of Terms
In this section, you will find an overview of the terms used in this privacy policy. Many of the terms are taken from the law and are primarily defined in Art. 4 GDPR. The legal definitions are binding. The following explanations are intended to help understand the terms. The terms are sorted alphabetically.
- Personal data: "Personal data" means any information relating to an identified or identifiable natural person (hereinafter referred to as the "data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g., a cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
- Controller: 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.
- Processing: "Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means. The term is broad and includes practically any handling of data, such as collection, analysis, storage, transmission, or deletion.