a)
External Hosting Our website is hosted on Google Cloud, Gordon House, Barrow Street, Dublin 4, Ireland. For this reason, all personal data collected on our website is stored on the servers of our hosting provider, unless an external service of a third party is involved. This may include the IP address, email address, communication data, or similar information. The specific personal data involved will be explained in more detail in the descriptions of the individual functions and services provided by us. If we use an external service provided by a third party, this will be clearly indicated in the description of the respective service or tool.
The hosting provider processes your data only on our behalf and to the extent necessary to fulfill the services on the website. The hosting provider does not process the data for its own purposes. We have entered into a data processing agreement with the hosting provider.
b)
When visiting the website When you access our website, your browser automatically sends information to the server of our website and this information is temporarily stored in a log file. The following information is collected without your intervention and stored until it is automatically deleted:
- IP address of the requesting computer
- Date and time of access
- Name and URL of the retrieved file
- Website from which the access is made (referrer URL)
- Browser type and operating system of your computer, as well as the name of your access provider
We process the aforementioned data for the following purposes:
- Ensuring a smooth connection setup of the website
- Ensuring convenient use of our website
- Evaluating system security and stability
- Error analysis
- Further administrative purposes
Data that could potentially identify you, such as the IP address, will be deleted no later than 7 days after collection. If we store the data beyond this period, it will be pseudonymized so that it can no longer be associated with you.
The legal basis for data processing is Article 6(1)(f) of the GDPR. Our legitimate interest arises from the purposes of data collection listed above. Under no circumstances do we use the collected data to draw conclusions about your person.
c)
Sales For the sale of our products and services, we use the online sales platform elopage provided by elopage GmbH, Kurfürstendamm 208, 107179 Berlin. Therefore, when you click on a product button on our website, you will be redirected to our sales page on elopage, where we also provide you with all further information regarding the processing of your data in the context of sales and payment processing.
We have entered into a data processing agreement with elopage.
For more information about elopage and the processing of personal data by elopage, please visit
https://elopage.com/privacy?locale=de.
d)
Newsletter Content of the Newsletter and Registration Data The delivery of our newsletter, as well as the conducting of statistical surveys and analyses, and the logging of the registration process, only take place if you subscribe to it and have given your consent in accordance with Art. 6(1)(a) of the GDPR, § 25(1) of the TTDSG.
The content of the newsletter is specifically described during the newsletter registration process. To subscribe to the newsletter, providing your email address is sufficient. If you voluntarily provide additional information such as your name and/or gender, they will be used exclusively for personalizing the newsletter sent to you.
Double Opt-In and Logging For newsletter registration, we use the double opt-in procedure for security reasons, so that no one can register with someone else's email address. Therefore, after registering for our newsletter, you will receive an email asking you to confirm your registration. Your registration only becomes effective upon confirmation.
Furthermore, your newsletter registration is logged, including the storage of the registration and confirmation timestamps, the data you provided, and your IP address. If you make changes to your data, these changes will also be logged.
Withdrawal If you no longer wish to receive our newsletter, you can revoke your consent at any time for future newsletters. To do so, you can click on the unsubscribe link at the end of each newsletter or send us an email to the following email address:
team@growingabroad.de.
The revocation of consent does not affect the legality of data processing based on the consent before its withdrawal.
Use of ActiveCampaign We send our newsletter using the newsletter service "ActiveCampaign," operated by ActiveCampaign, LLC (1 North Dearborn St, 5th Floor, Chicago, IL 60602, USA).
The email addresses of our newsletter subscribers, as well as their other data described in these notices, are stored on ActiveCampaign's servers in the USA. ActiveCampaign uses this information to send and evaluate the newsletter on our behalf.
Furthermore, according to ActiveCampaign, this data may be used in pseudonymous form, i.e., without assigning it to a specific user, for optimizing or improving their own services, such as technical optimization of newsletter delivery and display or statistical purposes to determine the countries from which the recipients originate. However, the email service provider does not use the data of our newsletter subscribers to contact them directly or share it with third parties. You can find ActiveCampaign's privacy policy here:
https://www.activecampaign.com/legal/privacy-policy .
Statistical Surveys and Analyses The newsletters sent via ActiveCampaign contain a so-called "web beacon," a pixel-sized file that is retrieved from the server of the email service provider when opening the newsletter. In the context of this retrieval, technical information such as browser and system information, as well as your IP address and the time of retrieval, are initially collected.
These details are used for the technical improvement of the services based on the technical data or the target groups and their reading behavior based on the retrieval locations (determinable through the IP address) or the access times.
Statistical surveys also include determining whether newsletters are opened, when they are opened, and which links are clicked. These pieces of information can be attributed to individual newsletter recipients for technical reasons. However, it is neither our intention nor ActiveCampaign's to monitor individual users. The evaluations serve us primarily to recognize the reading habits of our users and to adapt our content to them or send different content according to the interests of our users.
We have entered into a data processing agreement with ActiveCampaign in accordance with Article 26 of the GDPR, as well as the standard contractual clauses.
e)
Contact Form We provide a form on our website for you to contact us at any time. To use the contact form, it is necessary to provide a name for personal addressing and a valid email address for communication, so that we know who the inquiry is from and can process it accordingly.
If you send us inquiries through the contact form, your information from the inquiry form, including the contact details you provided, as well as your IP address, will be processed in accordance with Art. 6(1)(b) and (f) of the GDPR for the purpose of carrying out pre-contractual measures based on your request or for the exercise of our legitimate interest, namely the conduct of our business activities.
The inquiries and the associated data will be deleted no later than 6 months after receipt, unless they are required for further contractual relationships.
We use SendGrid, an email delivery service, for our contact form. The service provider is the American company Twilio Inc, 889 Winslow St, Redwood City, California 94063, USA.
SendGrid also processes data from you in the USA, among other places. We would like to point out that according to the opinion of the European Court of Justice, there is currently no adequate level of protection for the transfer of data to the USA. This may be associated with various risks to the lawfulness and security of data processing.
As a basis for data processing with recipients located in third countries (outside the European Union, Iceland, Liechtenstein, Norway, i.e. especially in the USA) or a data transfer there, SendGrid uses so-called standard contractual clauses (= Art. 46. para. 2 and 3 DSGVO). Standard Contractual Clauses (SCC) are templates provided by the EU Commission and are intended to ensure that your data comply with European data protection standards even if they are transferred to third countries (such as the USA) and stored there. Through these clauses, SendGrid undertakes to comply with the European level of data protection when processing your relevant data, even if the data is stored, processed and managed in the USA. These clauses are based on an implementing decision of the EU Commission. You can find the decision and the corresponding standard contractual clauses here, among other places: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?locale=de
The Data Processing Addendum, which corresponds to the standard contractual clauses, can be found at
https://www.twilio.com/legal/data-protection-addendum.
You can learn more about the data processed through the use of SendGrid in the Privacy Policy at
https://www.twilio.com/legal/privacy.
f)
Application Form We provide a form on our website for you to apply to us. Your personal data from the application will be processed in accordance with our privacy policy for applicants. When uploading your resume, you can create an account through which you can manage and edit all your uploaded documents. The creation and management of your account is based on your consent pursuant to Art. 6(1)(a) of the GDPR.
g)
Google Tag Manager We use the Google Tag Manager on our website, provided by Google (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland). The Google Tag Manager is a management and administration tool that allows for central management and deployment of other tracking and/or statistical tools.
When you visit our website and give your consent in accordance with Art. 6(1)(a) of the GDPR, the Google Tag Manager collects and processes your IP address, which may also be transferred to the USA. However, the Google Tag Manager does not create user profiles or perform any analyses itself.
You can find the Google Privacy Policy here: [https://www.google.com/policies/privacy/?hl=en]