PRIVACY POLICY
1. PRIVACY AT A GLANCE
General information
The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to personally identify you. For detailed information about data protection, please refer to our privacy policy listed below this text.
Data collection on this website
Who is responsible for data collection on this website?
Data processing on this website is carried out by the website operator. You can find their contact details in the section “Information about the Controller” in this privacy policy.
How do we collect your data?
Your data is collected in one way when you provide it to us. This could be, for example, data that you enter into a contact form. Other data is automatically collected or collected with your consent when you visit the website by our IT systems. This is primarily technical data (e.g., internet browser, operating system, or time of page access). This data is collected automatically as soon as you enter our website.
What do we use your data for?
Part of the data is collected to ensure error-free provision of the website. Other data may be used to analyze your user behavior.
What rights do you have regarding your data?
You have the right to receive information about the origin, recipient, and purpose of your stored personal data free of charge at any time. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can revoke this consent at any time for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.
You can contact us at any time regarding this and other questions about data protection.
ANALYSIS TOOLS AND THIRD-PARTY TOOLS
When visiting this website, your surfing behavior may be statistically analyzed. This is done primarily with analysis programs.
Detailed information about these analysis programs can be found in the following privacy policy.
2. HOSTING AND CONTENT DELIVERY NETWORKS (CDN)
We host the contents of our website with the following provider:
External hosting
This website is externally hosted. The personal data collected on this website is stored on the servers of the host/hosts. This may include, in particular, IP addresses, contact requests, meta and communication data, contract data, contact details, names, website access and other data generated through a website.
External hosting is carried out for the purpose of contract fulfillment vis-à-vis our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of secure, fast, and efficient provision of our online offering by a professional provider (Art. 6(1)(f) GDPR). Where corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.
Our host(s) will only process your data to the extent necessary to fulfill their performance obligations and follow our instructions concerning this data.
We use the following host(s):
united-domains AG Gautinger Strase 10 82319 Starnberg Germany
Order processing
We have concluded a contract for order processing (DPA) for the use of the above-mentioned service. This is a contract required by data protection law, which ensures that they process the personal data of our website visitors only according to our instructions and in compliance with the GDPR.
Cloudflare
We use the “Cloudflare” service. The provider is Cloudflare Inc, 101 Townsend St., San Francisco, CA 94107,
USA (hereinafter referred to as “Cloudflare”). Cloudflare offers a globally distributed content delivery network with DNS. The
information transfer between your browser and our website is technically routed via the Cloudflare network. The
enables Cloudflare to analyze the data traffic between your browser and our website
and to serve as a filter between our servers and potentially malicious data traffic from the Internet.
Cloudflare may also use cookies or other technologies to recognize Internet users
, but these are used solely for the purpose described here. The use of Cloudflare is based on our legitimate interest in providing our website as error-free and
secure as possible (Art. 6 para. 1 lit. f GDPR). Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details
can be found here: https://www.cloudflare.com/privacypolicy/. Further information on security and data protection at Cloudflare can be found here: https://
www.cloudflare.com/privacypolicy/. The company is certified according to the “EU-US Data Privacy Framework” (DPF). The DPF is
an agreement between the European Union and the USA, which is intended to ensure compliance with European
data protection standards for data processing in the USA. Every
company certified under the DPF undertakes to comply with these data protection standards. For more information, please contact the provider at
using the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt0000000GnZKAA0&status=Active
Order processing
We have concluded a contract for order processing (DPA) for the use of the above-mentioned service. This is a contract required by data protection law, which ensures that they process the personal data of our website visitors only according to our instructions and in compliance with the GDPR.
3. GENERAL INFORMATION AND MANDATORY DISCLOSURES
Data protection
The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with statutory data protection regulations and this privacy policy.
When you use this website, various personal data is collected. Personal data is data that can be used to personally identify you. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this happens.
We point out that data transmission over the Internet (e.g., when communicating via email) may have security vulnerabilities. Complete protection of data against access by third parties is not possible.
INFORMATION ABOUT THE CONTROLLER
The controller responsible for data processing on this website is:
Alecto Capital, LLC
1625 W. Tillicum Avenue,
Wasilla, 99654 Alaska, USA
Phone: +49 (0) 6151-73475-907
Email: contact-bia@alecto-capital.info
The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, e-mail addresses, etc.).
STORAGE DURATION
Unless a more specific storage period has been specified within this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will occur after these reasons cease to exist.
GENERAL INFORMATION ON THE LEGAL BASIS FOR DATA PROCESSING ON THIS WEBSITE
If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR if special categories of data according to Art. 9(1) GDPR are processed. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25(1) TTDSG. The consent can be revoked at any time. If your data is required for contract performance or for implementing pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, we process your data if this is necessary for compliance with a legal obligation based on Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of our legitimate interest according to Art. 6(1)(f) GDPR. Information about the relevant legal bases in each individual case is provided in the following paragraphs of this privacy policy.
RECIPIENTS OF PERSONAL DATA
As part of our business activities, we work together with various external bodies. In some cases, it is also necessary to transfer personal data to these external bodies. We only pass on personal data to external bodies if this is necessary for the fulfillment of a contract, if we are legally obliged to do so (e.g. passing on data to tax authorities), if we have a legitimate interest in the transfer in accordance with Art. 6 para. 1 lit. f GDPR or if another legal basis permits the transfer of data. When using processors, we only pass on our customers’ personal data on the basis of a valid contract for order processing. In the case of joint processing, a joint processing agreement is concluded.
Revocation of your consent to data processing
IF DATA PROCESSING IS BASED ON ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE PURPOSE OF ASSERTING, EXERCISING OR DEFENDING LEGAL CLAIMS (OBJECTION UNDER ART. 21(1) GDPR).
IF YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT MARKETING PURPOSES (OBJECTION UNDER ART. 21(2) GDPR).
RIGHT TO FILE COMPLAINTS WITH REGULATORY AUTHORITIES
In the event of violations of the GDPR, data subjects have the right to file a complaint with a supervisory authority, particularly in the Member State of their habitual residence, their place of work, or the place of the alleged violation. This right to file complaints is without prejudice to other administrative or judicial remedies.
RIGHT TO DATA PORTABILITY
You have the right to receive data that we process automatically on the basis of your consent or in fulfillment of a contract, in a common, machine-readable format, or to have it transferred to a third party. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.
INFORMATION, RECTIFICATION, AND DELETION
Within the scope of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipients, and the purpose of data processing, and, if applicable, a right to rectification or deletion of this data. For this as well as for further questions about personal data, you can contact us at any time.
Within the scope of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipients, and the purpose of data processing, and, if applicable, a right to rectification or deletion of this data. For this as well as for further questions about personal data, you can contact us at any time.
RIGHT TO RESTRICTION OF PROCESSING
You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restriction of processing exists in the following cases:
- If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
- If the processing of your personal data happened/happens unlawfully, you can request the restriction of data processing instead of deletion.
- If we no longer need your personal data, but you need it for exercising, defending, or asserting legal claims, you have the right to request restriction of the processing of your personal data instead of deletion.
- If you have filed an objection under Art. 21(1) GDPR, a balancing of your and our interests must be carried out. As long as it has not been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.
If you have restricted the processing of your personal data, this data – apart from its storage – may only be processed with your consent or for the assertion, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.
SSL OR TLS ENCRYPTION
For security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.
If SSL or TLS encryption is activated, the data you transfer to us cannot be read by third parties.
OBJECTION TO PROMOTIONAL EMAILS
We hereby object to the use of contact data published within the framework of the imprint obligation for sending unsolicited advertising and information materials. The site operators expressly reserve the right to take legal action in the event of unsolicited sending of advertising information, such as through spam emails.
4. DATA COLLECTION ON THIS WEBSITE
COOKIES
Our websites use “cookies”. Cookies are small data packages and cause no harm to your device. They are stored either temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your device. Session cookies are automatically deleted after your visit ends. Permanent cookies remain stored on your device until you delete them yourself or until they are automatically deleted by your web browser.
Cookies can originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services from third-party companies within websites (e.g., cookies for processing payment services).
Cookies have various functions. Many cookies are technically necessary because certain website functions would not work without them (e.g., the shopping cart function or the display of videos). Other cookies may be used to evaluate user behavior or for advertising purposes.
Cookies that are necessary for carrying out the electronic communication process, for providing certain functions you want (e.g., for the shopping cart function), or for optimizing the website (e.g., cookies for measuring web audience) (necessary cookies) are stored on the basis of Art. 6(1)(f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of its services. If consent for the storage of cookies and similar recognition technologies has been requested, processing takes place exclusively on the basis of this consent (Art. 6(1)(a) GDPR and § 25(1) TTDSG); this consent can be revoked at any time.
You can set your browser to inform you about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or generally, and activate the automatic deletion of cookies when closing the browser. When cookies are deactivated, the functionality of this website may be limited.
You can find out which cookies and services are used on this website in this privacy policy.
CONSENT WITH COMPLIANZ
Our website uses Complianz consent technology to obtain your consent for storing certain cookies on your device or using certain technologies and to document this in compliance with data protection regulations. The provider of this technology is Complianz B.V., Kalmarweg 14-5, 9723 JG Groningen, Netherlands (hereinafter “Complianz”).
Complianz is hosted on our servers, so no connection is established to the servers of the Complianz provider. Complianz stores a cookie in your browser to be able to assign the consents given or their revocation to you. The data collected in this way is stored until you request us to delete it, delete the Complianz cookie yourself, or the purpose for data storage ceases to apply. Mandatory statutory retention obligations remain unaffected.
Complianz is used to obtain the legally required consents for the use of cookies. The legal basis for this is Art. 6(1)(c) GDPR.
CONTACT FORM
If you send us inquiries via the contact form, your information from the inquiry form, including the contact details you provided there, will be stored by us for processing the inquiry and in case of follow-up questions. We do not share this data without your consent.
The processing of this data is based on Art. 6(1)(b) GDPR if your request is related to the fulfillment of a contract or is necessary for carrying out pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; the consent can be revoked at any time.
The data you enter in the contact form remains with us until you request us to delete it, revoke your consent to storage, or the purpose for data storage ceases to apply (e.g., after completed processing of your request). Mandatory statutory provisions – particularly retention periods – remain unaffected.
INQUIRIES VIA EMAIL, TELEPHONE, OR FAX
If you contact us via email, telephone, or fax, your inquiry including all resulting personal data (name, inquiry) will be stored and processed by us for the purpose of handling your request. We do not share this data without your consent.
The processing of this data is based on Art. 6(1)(b) GDPR if your request is related to the fulfillment of a contract or is necessary for carrying out pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; the consent can be revoked at any time.
The data you send to us via contact requests remains with us until you request us to delete it, revoke your consent to storage, or the purpose for data storage ceases to apply (e.g., after your request has been processed). Mandatory statutory provisions – particularly statutory retention periods – remain unaffected.
5. NEWSLETTER
NEWSLETTER DATA
If you would like to receive the newsletter offered on the website, we need an email address from you as well as information that allows us to verify that you are the owner of the specified email address and agree to receive the newsletter. No additional data is collected, or only on a voluntary basis. For the handling of newsletters, we use newsletter service providers, which are described below.
BREVO
This website uses Brevo for sending newsletters. The provider is Sendinblue GmbH, Köpenicker Straße 126, 10179 Berlin, Germany.
Brevo is a service that can be used to organize and analyze newsletter distribution. The data you enter for newsletter subscription purposes is stored on Sendinblue GmbH’s servers in Germany.
Data Analysis by Brevo
With the help of Brevo, we can analyze our newsletter campaigns. For example, we can see if a newsletter message was opened and which links were clicked. This way, we can determine which links were clicked particularly often.
Furthermore, we can detect whether certain predefined actions were carried out after opening/clicking (conversion rate). For example, we can see if you made a purchase after clicking on the newsletter.
Brevo also allows us to divide newsletter recipients into various categories (“cluster”). For instance, newsletter recipients can be categorized by age, gender, or location. This enables better adaptation of newsletters to the respective target groups.
If you do not want analysis by Brevo, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every newsletter message. For detailed information about Brevo’s functions, please visit: https://www.brevo.com/de/newsletter-software/.
Legal Basis
Data processing is carried out based on your consent (Art. 6(1)(a) GDPR). You can revoke this consent at any time. The lawfulness of data processing operations already carried out remains unaffected by the revocation.
Storage Duration
The data you provide for the purpose of receiving the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and will be deleted from the newsletter distribution list after you unsubscribe. Data stored for other purposes remains unaffected by this.
After you unsubscribe from the newsletter distribution list, your email address may be stored by us or the newsletter service provider in a blacklist if this is necessary to prevent future mailings. The blacklist data will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). The storage in the blacklist is not time-limited. You may object to the storage if your interests outweigh our legitimate interest.
For more information, please see Brevo’s privacy policy at: https://www.brevo.com/de/datenschutz-uebersicht/ and https://www.brevo.com/de/legal/privacypolicy/.
Order Processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law, which ensures that they process the personal data of our website visitors only according to our instructions and in compliance with the GDPR.
NEWSLETTER DISPATCH TO EXISTING CUSTOMERS
If you order goods or services from us and provide your email address, we may subsequently use this email address for sending newsletters, provided we inform you about this in advance. In such cases, the newsletter will only be used for direct advertising of our own similar goods or services. You can cancel the receipt of this newsletter at any time. For this purpose, a corresponding link can be found in every newsletter. The legal basis for sending the newsletter in this case is Art. 6(1)(f) GDPR in conjunction with § 7(3) UWG.
After you unsubscribe from the newsletter distribution list, your email address may be stored by us in a blacklist to prevent future mailings to you. The blacklist data will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). The storage in the blacklist is not time-limited. You may object to the storage if your interests outweigh our legitimate interest.
6. PLUGINS AND TOOLS
GOOGLE FONTS
This site uses so-called Google Fonts, which are provided by Google, for the uniform display of fonts. When you access a page, your browser loads the required fonts into your browser cache in order to display texts and fonts correctly. For this purpose, the browser you are using must connect to Google’s servers. This informs Google that this website has been accessed via your IP address. The use of Google Fonts is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the uniform presentation of the typeface on its website. If a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time. If your browser does not support Google Fonts, a standard font will be used by your computer. Further information on Google Fonts can be found at https://developers.google.com/fonts/faq and in Google’s privacy policy: https://policies.google.com/privacy?hl=de. The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA, which is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards. Further information on this can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/s/participant-search/participant-detail?contact=true&id=a2zt000000001L5AAI&status=Active
GOOGLE RECAPTCHA
We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
The purpose of reCAPTCHA is to verify whether data entry on this website (e.g., in a contact form) is being done by a human or by an automated program. To do this, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis starts automatically as soon as the website visitor enters the website. For the analysis, reCAPTCHA evaluates various information (e.g., IP address, time spent by the website visitor on the website, or mouse movements made by the user). The data collected during the analysis is forwarded to Google.
The reCAPTCHA analyses run entirely in the background. Website visitors are not informed that an analysis is taking place. The storage and analysis of data is carried out on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in protecting their web offerings from abusive automated spying and from SPAM. If corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s end device (e.g., device fingerprinting) as defined in the TTDSG. This consent can be revoked at any time.
For more information about Google reCAPTCHA, please refer to the Google Privacy Policy and the Google Terms of Service at the following links: https://policies.google.com
The company has certification under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA that aims to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF commits to comply with these data protection standards. Further information can be obtained from the provider at the following link: https://www.dataprivacyframework.gov
7. E-COMMERCE AND PAYMENT PROVIDERS
PROCESSING OF CUSTOMER AND CONTRACT DATA
We collect, process, and use personal customer and contract data for the establishment, content design, and modification of our contractual relationships. We only collect, process, and use personal data about the use of this website (usage data) to the extent necessary to enable the user to use the service or for billing purposes. The legal basis for this is Art. 6 (1) (b) GDPR.
The collected customer data will be deleted after completion of the order or termination of the business relationship and expiration of any existing statutory retention periods. Statutory retention periods remain unaffected.