1) Preamble

Welcome to our website! Protecting your data and your privacy is very important to us. Below we wish to outline what data we process, when, for what purpose and on what legal basis. We shall explain to you how our services work and how the protection of your personal data is guaranteed.

As defined in Art. 4 No. 1 of the General Data Protection Regulation (GDPR), personal data is all information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified directly or indirectly. Further information can be found in Art. 4 No. 1 GDPR.

This Privacy Policy can be retrieved, saved and printed at any time at https://spicture-app.com/wordpress/?page_id=2159

Where we cite our legitimate interest or the legitimate interest of a third party (Art. 6 para. 1 lit. f GDPR) as the legal basis for the processing of personal data, you have the right to object pursuant to Art. 21 GDPR:

According to Art. 21 GDPR you have the right to object to the processing of your personal data at any time. We will then no longer process the personal data for purposes of direct marketing or any related profiling.

Neither will we process your personal data for other purposes after an objection, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims (cf. Art. 21 para. 1 GDPR, so-called „restricted right to object“). In this case, you must state grounds for the objection which result from your particular situation.

You may also object to the processing of your personal data for reasons arising from your particular situation where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Art. 89 Para. 1 GDPR, unless such processing is necessary for the performance of a task in the public interest (cf. Art. 21 Para. 6 GDPR).

We will also inform you separately about your right to object in the individual sections (e.g. by stating: „You have the right to object“) where this right exists. Here you will also find further information on how to exercise your right to object.

In order to keep the following Privacy Policy clear, we refer at various points by links to information and privacy notices located on external websites (see also the section „Social Networks & External Links“ in this Privacy Policy). We make every effort to keep the links listed in this Privacy Policy up to date. Nevertheless, due to the constant updating of the web pages, the possibility that links do not function correctly cannot be excluded. If you notice such a link, we would be happy if you inform us so that we can insert the current link.

This privacy policy has been prepared in the German language. The German version shall be definitive and binding, even where an English translation has been produced.

2)    Responsible party

The responsible party as defined by Art. 4 No. 7 GDPR for the processing of personal data is:

dawin® gmbh

Authorized representative manager: Jan Dreßler

Belgische Allee 50
D-53842 Troisdorf/Spich
Germany

T +49 2241 397 198-0
F +49 2241 397 198-9

Email: info@dawin.de

3)    Contact person for data protection

If you have any questions regarding the processing of your personal data or your data protection rights, please contact:

Stephan Seidenberg

Belgische Allee 50
53842 Troisdorf
Germany

datenschutz@dawin.de

+4922413971980

4) Log files

Each time you visit our website, we automatically collect data and information from your device’s system and store it in server log files. This data is information that relates to an identified or identifiable natural person (here: website visitor). The data is transferred automatically by your browser when you visit our website. It includes the following information:

  • The time when our website was accessed (request to the server of the host provider)
  • The URL of the website from which you accessed our website
  • The operating system you are using
  • The type and version of the browser you are using,
  • The IP address of your computer

The purpose of this data processing is to make our website accessible from your device and to enable our website to be displayed correctly on your device or in your browser. The data is also used to optimise our website and to ensure the security of our systems. This data will not be evaluated for marketing purposes.

Legal basis for the processing is Art. 6 Para. 1 lit. f GDPR. We have a legitimate interest in providing you with a website optimised for your browser and enabling you to communicate between our server and your device. For the latter, it is necessary in particular to process your IP address.

We store this data for 7 days.

The recipient of the data is our server host, working for us within the framework of an order data agreement.

Right to object

You have the right to object. You can send or inform us of your objection at any time (e.g. by email to datenschutz@dawin.de).

The provision of personal data is neither required by law nor by contract, nor is it necessary to conclude a contract. You are also not obliged to provide the personal data. However, failure to do so may result in your inability to use our website or to use its full functionality.

5) Cookies

Our website uses cookies. Cookies are text files that are stored on your device in order, for example, to make the use of a website more convenient or to recognise the user’s device and save settings or similar items. Entries and settings on a website can be stored in cookies so that you do not have to re-enter them each time you visit a website. Cookies contain a so-called cookie ID, which makes it possible to identify the device on which the cookie was stored. Specifically, we use the following cookies:

  • Cookies that contain a randomly generated, concrete identification number that makes you or your device identifiable during your visit to our website. These cookies are automatically deleted at the end of your visit.

The purpose of this data processing is to make it easier for you to use our website and to offer you the opportunity to save your settings.

Legal basis for the processing is Art. 6 Para. 1 lit. f GDPR. We have a legitimate interest in providing you with a website that stores your personal preferences and makes it easier for you to visit our website.

Right to object

You have the right to object.

In your browser settings you can restrict or completely prevent the storage of cookies. You can also have cookies automatically deleted when the browser window is closed.

You can find out how to delete cookies in the most common browsers and how to change your cookie settings here:

The provision of personal data is neither required by law nor by contract, nor is it necessary to conclude a contract. You are also not obliged to provide the personal data. However, failure to do so may result in your inability to use our website or to use its full functionality.

Other services used by us also use cookies. We inform you separately about the use of cookies for the individual services.

6) Information about Google services

On our website we use various services of Google LLC („Google“), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

You will find more detailed information about the specific Google services that we use on this website in this Privacy Policy.

Google may collect and process information (including personal data) through the integration of Google services. The possibility that Google may also transfer the information to a server in a third country cannot be ruled out.

As stated in Google’s Privacy Shield certification (available at https://www.privacyshield.gov/list under the search term „Google“), Google is committed to complying with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework for the collection, use and storage of personal data from EU member states and Switzerland. Google, including Google LLC and its wholly owned subsidiaries in the US, has been certified to comply with the Privacy Shield Principles. Further information can be found at https://www.google.de/policies/privacy/frameworks/.

We ourselves cannot influence what data Google actually collects and processes. However, Google states that the following information (including personal data) may be processed among others:

  • Protocol data (in particular the IP address)
  • Location-related information
  • Unique application numbers
  • Cookies and similar technology

If you are signed in to your Google Account, Google may add the information we process to your account and treat it as personal information, depending on your account preferences. On this point, see in particular https://www.google.de/policies/privacy/partners/.

Google does the following, among other things:

“We may combine the information we collect among our services and across your devices for the purposes described above. For example, if you watch videos of guitar players on YouTube, you might see an ad for guitar lessons on a site that uses our ad products. Depending on your account settings, your activity on other sites and apps may be associated with your personal information in order to improve Google’s services and the ads delivered by Google” (https://policies.google.com/privacy?hl=en-GB)

You can prevent this information from being added directly by logging out of your Google Account or by adjusting your Google Account settings accordingly. You may also prevent the installation of cookies – insofar as Google generates them – by adjusting your browser settings accordingly. However, please note that if you do this you may not be able to use the full functionality of this website.

You can find out how to delete cookies in the most common browsers here:

For more information, please refer to Google’s privacy policy, which can be found here:

 https://www.google.com/policies/privacy/    

You can find information about Google’s privacy settings at https://privacy.google.com/take-control.html

7) Google Analytics

On our website we use Google Analytics, a web analysis service of Google LLC („Google“), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Google Analytics uses „cookies“, which are text files placed on your device, to help the website analyse how visitors use the site. Google Analytics may also use so-called web beacons (invisible graphics). These web beacons can be used to evaluate information such as visitor traffic to websites. The information generated by cookies and web beacons about the use of our website (including the user’s IP address) will be transmitted to and stored by Google on servers in the United States or other third countries. This information may be disclosed by Google to Google’s contract partners.

For information about Google’s existing Privacy Shield certification and other relevant information about Google’s data processing activities when you use Google services, please see section 6) of this Privacy Policy: „Information about Google services“.

  • The following data types are processed by Google:
  • Online identifiers (including cookie identifiers)
  • IP address
  • Device identifiers

In addition, you can find more detailed information about the information processed at https://policies.google.com/privacy?hl=en#infocollect under „Information we collect as you use our services“ and at https://privacy.google.com/businesses/adsservices/.

We only use Google Analytics with IP anonymization enabled („anonymise IP“). This will cause Google to truncate your IP address within member states of the European Union or other states party to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the US and truncated there.

Furthermore, we have concluded an order processing agreement with Google for the use of Google Analytics (Art. 28 GDPR). Google processes the data on our behalf in order to evaluate your use of the website, compile reports on website activity for us and provide us with other services relating to website activity and internet usage. Google may transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.

By integrating Google Analytics, our purpose is to analyse user behaviour on our website so that we can respond accordingly. This enables us to continuously improve our offering.

Legal basis for the processing of personal data described here is Art. 6 Para. 1 lit. f GDPR. Our justified interest in this is the great benefit that the functions described above have for our offering. The statistical evaluation of user behaviour enables us in particular to respond and optimise our services in line with the interests of our customers.

Within the scope of order processing, Google is entitled to commission subcontractors. A list of these subcontractors can be found at https://privacy.google.com/businesses/subprocessors/.

Right to object

You have the right to object. You can prevent your data from being processed by Google by downloading and installing the browser plug-in available at the following link:

https://tools.google.com/dlpage/gaoptout?hl=en

You can also prevent Google Analytics from collecting data by clicking on the following link.

An opt-out cookie will be set to prevent your data from being collected when you visit this website in the future. Deactivate Google Analytics.

In addition, you can prevent the collection of data by web beacons by downloading and installing the add-on for your browser available at the following link:

https://adblockplus.org/ 

You may also prevent the installation of cookies by adjusting your browser settings accordingly. However, please note that if you do this you may not be able to use the full functionality of this website.

You can find out how to delete cookies and change the cookie settings in the most common browsers here:

The processed information will be stored for 26 months and will be automatically deleted at the end of this period.

For more information on data handling in connection with Google Analytics, please refer to Google’s privacy policy:

https://support.google.com/analytics/answer/6004245?hl=en   

For Google’s privacy settings, see https://privacy.google.com/take-control.html?categories_activeEl=sign-in

The provision of personal data is neither required by law nor by contract, nor is it necessary to conclude a contract. You are also not obliged to provide the personal data. However, failure to do so may result in your inability to use our website or to use its full functionality.

8) Use of Google Web Fonts

On our website we use external fonts, so-called Google Fonts. Google Fonts is a service of Google LLC („Google“), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

The web fonts are integrated via an interface („API“) to the Google services. Google may collect and process information (including personal data) through the integration of web fonts. The possibility that Google may also transfer the information to a server in a third country cannot be ruled out.

For information about Google’s existing Privacy Shield certification and other relevant data relating to Google’s processing of data when using Google services, please see section 6) of this Privacy Policy: „Information about Google services“.

We ourselves do not collect any data within the scope of the provision of Google Fonts.

By incorporating Google Fonts, our purpose is to display consistent fonts on your device.

Legal basis for the processing of personal data described here is Art. 6 Para. 1 lit. f GDPR. Our legitimate interest in this is the great benefit offered by a uniform presentation of fonts. By using the option of such a uniform presentation, we reduce the complexity of design compared to having to adapt our own graphically adapted websites to the font standards of different operating systems or browsers. Google also has a legitimate interest in the (personal) data collected in order to improve its own services.

Right to object

You have the right to object. You can send or inform us of your objection at any time (e.g. by email to datenschutz@dawin.de).

The provision of personal data is neither required by law nor by contract, nor is it necessary to conclude a contract. You are also not obliged to provide the personal data. However, failure to do so may result in your inability to use our website or to use its full functionality. It may also result in our website being displayed differently.

For more information, please see Google’s privacy policy, which can be found here:

You can find information about Google’s privacy settings at https://privacy.google.com/take-control.html?categories_activeEl=sign-in

9) Use of YouTube

We use videos from YouTube and YouTube plug-ins on our website. YouTube is a service of YouTube LLC („YouTube“), 901 Cherry Ave, San Bruno, CA 94066, USA and is provided by YouTube LLC. YouTube LLC is a subsidiary of Google Inc. („Google“), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

The integration of YouTube takes place by embedding the service on our website using a so-called „iFrame“. YouTube or Google may collect and process information (including personal data) when you load this iFrame. The possibility that Google may also transfer the information to a server in a third country cannot be ruled out.

For information about Google’s existing Privacy Shield certification and other relevant information about Google’s data processing activities when you use Google services, please see section 6) of this Privacy Policy: „Information about Google services“.

We do not collect any data ourselves when you watch a YouTube video on our site.

By integrating YouTube, our purpose is to provide you with various videos on our website so that you can view them directly on our website.

Legal basis for the processing of personal data described here is Art. 6 Para. 1 lit. f GDPR. Our justified interest in this is the great benefit that YouTube offers. By integrating external videos, we reduce the load on our servers and can use the corresponding resources for other purposes. Among other things, this can increase the stability of our servers. In addition, YouTube and/or Google has a justified interest in the collected (personal) data in order to improve its own services.

Right to object

You have the right to object. You can send or inform us of your objection at any time (e.g. by email to datenschutz@dawin.de).

The provision of personal data is neither required by law nor by contract, nor is it necessary to conclude a contract. You are also not obliged to provide the personal data. However, failure to do so may result in your inability to use our website or to use its full functionality.

For more information, please refer to Google’s privacy policy, which can be found here: https://www.google.com/policies/privacy/

You can find information about Google’s privacy settings at https://privacy.google.com/take-control.html

10) Contact form

On our website you will find a contact form which you can use to contact us electronically. If you contact us via this contact form, the data entered in the input fields will be processed by us.

The following data are included as mandatory data:

  • Email Address
  • The information that is derived from the message text

In addition, you can add further data as voluntary information. This may simplify and speed up the processing of your request. The following data is potentially relevant:

  • Name
  • The information that is derived from the message text

Mandatory and voluntary information are treated equally by us. The mandatory information is necessary in order to contact you and process your request.

When the message is sent, the following data is also stored:

  • Your IP address
  • Date and time of sending

Please note that the extent of the personal data collected in the contact form also depends on what data you yourself disclose in the message text of the contact form.

The purpose of processing personal data within the scope of the mandatory and voluntary data is to process the contact request and to be able to contact the requesting party in order to respond to the request. The other personal data processed during sending (IP address, date and time of sending) serve to prevent misuse of our contact form.

Legal basis for the processing of personal data described here is Art. 6 Para. 1 lit. f GDPR. It is our legitimate interest to offer you the opportunity to contact us at any time so that we can answer your questions.

The personal data will only be processed for as long as is necessary for the provision of the function.

The additional personal data collected during the sending of the contact form will be deleted after 7 days at the latest.

The recipient of the data is our server host, working for us within the framework of an order data agreement.

Right to object

You have the right to object to the processing of your personal data at any time. You can send or inform us of your objection at any time (e.g. by email to datenschutz@dawin.de).

The provision of personal data is neither required by law nor by contract, nor is it necessary to conclude a contract. You are also not obliged to provide the personal data. However, failure to do so may result in your inability to use our contact form.

11) Contacting us

You have the possibility to contact us by post, telephone, fax or email.

If you contact us by post, we may process, in particular, your address data (e.g. surname, first name, street, city, postal code), date and time of receipt of the mail as well as any information derived from your letter itself.

If you contact us by telephone, we may process, in particular, your telephone number and, if provided in the course of the conversation, your name, email address, the time of your call and details of your request.

If you contact us by fax, we may process, in particular, the fax number or sender identification and the information derived from the fax.

If you contact us by email, your email address, the date and time of the email and the information derived from the message text (including any attachments) will be processed.

The purpose of processing the above-mentioned data is to process the contact request and to be able to contact the requesting party in order to answer the request.

Legal basis for the processing of personal data described here is Art. 6 Para. 1 lit. f GDPR. It is our legitimate interest to give you the opportunity to contact us at any time and answer your questions.

The personal data will be deleted as soon as it is no longer necessary to fulfil the purpose for which it was collected.

Right to object

You have the right to object. You can send or inform us of your objection at any time (e.g. by email to datenschutz@dawin.de).

The provision of personal data is neither required by law nor by contract, nor is it necessary to conclude a contract. You are also not obliged to provide the personal data. However, failure to do so may mean that you are unable to use the provided methods of contacting us, or that we are unable to contact you.

12) Social networks & external links

In addition to this website, we also maintain presences on various social media, which you can reach via the corresponding buttons on our website. If you visit such a presence, personal data may be transmitted to the provider of the social network. It is possible that, in addition to the storage of the data you have specifically entered on this social media platform, other information may also be processed by the social network provider.

In addition, the social network provider may process the basic information about the computer system you are using to access it, such as your IP address, the type of processor you are using and the browser version and plug-ins you are using.

If you are logged into your personal user account of the respective network while visiting such a website, this network can assign the visit to this account.

The purpose and scope of the data collection by the respective social media platform and its further processing of your data, as well as your rights in this regard, can be found in the respective policies of the responsible platforms, e.g. at:

Facebook: https://www.facebook.com/about/privacy/

YouTube: https://support.google.com/youtube/answer/7671399?hl=en

We would also like to point out that our website contains further links to external third-party websites, whereby we have no influence on the processing of data on these external websites.

13) Data security

We secure our website and other systems through technical and organisational measures against loss, destruction, access, alteration and distribution of your data by unauthorised persons. However, despite regular checks, complete protection against all risks is not possible.

14) Modification of the Privacy Policy

Changes in the law or in our internal processes may make it necessary to adapt this Privacy Policy.

In the event of such a change, we will inform you of this at the beginning of the Privacy Policy.

15) Revocation

You have the right to revoke your consent at any time with effect for the future, without affecting the lawfulness of the processing carried out on the basis of your consent until revocation.

16) Rights of data subjects

You have the following basic rights:

  • Right to be informed (Art. 15 GDPR)
  • Right to rectification (Art. 16 GDPR)
  • Right to erasure (Art. 21 GDPR)
  • Right to cancellation (Art. 17 GDPR)
  • Right to restrict processing (Art. 18f. GDPR)
  • Right to data portability (Art. 20 GDPR)

For inquiries of this kind, please contact datenschutz@dawin.de . Please note that we must ensure that such requests are actually submitted by the person concerned.

You have the right to complain to a data protection supervisory authority, without prejudice to any other administrative or judicial remedy.

Automated decision-making does not take place on our website.

Status: 03.08.2018