PRIVACY POLICY
DATA PROTECTION CONDITIONS
1) Information about the Collection of Personal Data and Contact Details of the Controller
1.1 We are pleased that you are visiting our website and thank you for your interest. Below we inform you about the
handling of your personal data when using our website. Personal data is all data with which you can be personally
identified.
1.2 The controller for data processing on this website within the meaning of the General Data Protection Regulation
(GDPR) is COMMUNICATION VENTURES PTE. LTD.
68 Circular Road #02-01, Singapur 049422
[email protected]
1.3 For security reasons and to protect the transmission of personal data and other confidential content (e.g.,
orders or inquiries to the controller), this website uses SSL or TLS encryption. You can recognize an encrypted
connection by the string "https://" and the lock symbol in your browser line.
2) Data Collection When Visiting Our Website
When you use our website for informational purposes only, i.e., if you do not register or otherwise transmit
information to us, we only collect the data that your browser transmits to our server (so-called "server log
files"). When you visit our website, we collect the following data, which is technically necessary for us to display
the website to you:
- Our visited website
- Date and time at the time of access
- Amount of data sent in bytes
- Source/reference from which you reached the page
- Browser used
- Operating system used
- IP address used (if applicable: in anonymized form)
The processing is carried out in accordance with Art. 6 (1) lit. f GDPR on the basis of our legitimate interest in
improving the stability and functionality of our website. The data is not passed on or used in any other way.
However, we reserve the right to check the server log files subsequently if there are concrete indications of
illegal use.
3) Cookies
To make visiting our website attractive and to enable the use of certain functions, we use so-called cookies on
various pages. These are small text files that are stored on your device. Some of the cookies we use are deleted
again after the end of the browser session, i.e., after you close your browser (so-called session cookies). Other
cookies remain on your device and enable us or our partner companies (third-party cookies) to recognize your browser
on your next visit (persistent cookies). If cookies are set, they collect and process certain user information such
as browser and location data as well as IP address values to an individual extent. Persistent cookies are
automatically deleted after a specified period, which may vary depending on the cookie.
If personal data is processed by individual cookies implemented by us, the processing is carried out in accordance
with Art. 6 (1) lit. b GDPR either for the performance of the contract or in accordance with Art. 6 (1) lit. f GDPR
to safeguard our legitimate interests in the best possible functionality of the website and a customer-friendly and
effective design of the page visit.
We may work with advertising partners who help us to make our internet offering more interesting for you. For this
purpose, cookies from partner companies are also stored on your hard drive when you visit our website (third-party
cookies). If we work with the aforementioned advertising partners, you will be informed individually and separately
about the use of such cookies and the scope of the information collected in each case within the paragraphs
below.
Please note that you can set your browser to inform you about the setting of cookies and to decide individually about
their acceptance or to exclude the acceptance of cookies for certain cases or in general. Each browser differs in
the way it manages cookie settings. This is described in the help menu of each browser, which explains how you can
change your cookie settings. You can find this for the respective browsers under the following links:
Internet Explorer: http://windows.microsoft.com/de-DE/windows-vista/Block-or-allow-cookies
Firefox: https://support.mozilla.org/de/kb/cookies-erlauben-und-ablehnen
Chrome: http://support.google.com/chrome/bin/answer.py?hl=de&hlrm=en&answer=95647
Safari: https://support.apple.com/de-de/guide/safari/sfri11471/mac
Opera: http://help.opera.com/Windows/10.20/de/cookies.html
Please note that if you do not accept cookies, the functionality of our website may be limited.
4) Contacting Us
When you contact us (e.g., via contact form or email), personal data is collected. Which data is collected in the
case of a contact form can be seen from the respective contact form. This data is stored and used solely for the
purpose of responding to your request or for contacting you and the associated technical administration. The legal
basis for the processing of this data is our legitimate interest in responding to your request in accordance with
Art. 6 (1) lit. f GDPR. If your contact aims at the conclusion of a contract, the additional legal basis for the
processing is Art. 6 (1) lit. b GDPR. Your data will be deleted after your request has been processed. This is the
case when the circumstances indicate that the matter in question has been finally clarified and provided that there
are no statutory retention obligations to the contrary.
5) Online Marketing
Use of Google Ads Conversion Tracking
This website uses the online advertising program "Google Ads" and, as part of Google Ads, the conversion tracking of
Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"). We use the Google Ads
service to draw attention to our attractive offers on external websites with the help of advertising media
(so-called Google Adwords). We can determine how successful the individual advertising measures are in relation to
the data of the advertising campaigns. We pursue the interest of showing you advertising that is of interest to you,
making our website more interesting for you, and achieving a fair calculation of the advertising costs incurred.
The conversion tracking cookie is set when a user clicks on an Ads ad served by Google. Cookies are small text files
that are stored on your device. These cookies usually lose their validity after 30 days and are not used for
personal identification. If the user visits certain pages of this website and the cookie has not yet expired, Google
and we can recognize that the user clicked on the ad and was redirected to this page. Each Google Ads customer
receives a different cookie. Cookies cannot therefore be tracked via the websites of Google Ads customers. The
information collected using the conversion cookie is used to generate conversion statistics for Google Ads customers
who have opted for conversion tracking. The customers learn the total number of users who clicked on their ad and
were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that
can be used to personally identify users.
If you do not wish to participate in tracking, you can block this use by disabling the Google conversion tracking
cookie via your internet browser under the keyword "user settings". You will then not be included in the conversion
tracking statistics.
We use Google Ads based on our legitimate interest in targeted advertising in accordance with Art. 6 (1) lit. f GDPR.
As part of the use of Google Ads, personal data may be transmitted to the servers of Google LLC. in the USA. You can
obtain further information about Google's data protection regulations at the following Internet address: https://www.google.de/policies/privacy/
You can permanently object to the setting of cookies by Google Ads conversion tracking by downloading and installing
the browser plug-in available at the following link: https://www.google.com/settings/ads/plugin?hl=de
Please note that certain functions of this website may not be available or may be limited if you have disabled the
use of cookies.
Where legally required, we have obtained your consent for the processing of your data as described above in
accordance with Art. 6 (1) lit. a GDPR. You can revoke your consent at any time with effect for the future. To
exercise your revocation, deactivate this service in the "Cookie Consent Tool" provided on the website or follow the
alternative option described above to object.
6) Web Analysis Services
Google (Universal) Analytics
This website uses Google (Universal) Analytics, a web analysis service of Google Ireland Limited, Gordon House, 4
Barrow St, Dublin, D04 E5W5, Ireland ("Google"). Google (Universal) Analytics uses so-called "cookies", which are
text files stored on your device, to analyze your use of the website. The information generated by the cookie about
your use of this website (including the shortened IP address) is usually transmitted to a Google server and stored
there; this may also involve transmission to the servers of Google LLC. in the USA.
This website uses Google (Universal) Analytics exclusively with the extension "_anonymizeIp()", which ensures
anonymization of the IP address by shortening it and excludes direct personal reference. Through the extension, your
IP address will be shortened by Google within member states of the European Union or in other contracting states of
the Agreement on the European Economic Area beforehand. Only in exceptional cases will the full IP address be
transmitted to a Google LLC. server in the USA and shortened there. On our behalf, Google will use this information
to evaluate your use of the website, to compile reports on website activity, and to provide us with other services
related to website and internet use. The IP address transmitted by your browser as part of Google (Universal)
Analytics will not be merged with other Google data.
Google Analytics enables, via a special function, the so-called "demographics", the creation of statistics with
statements about the age, gender, and interests of page visitors based on an evaluation of interest-based
advertising and using information from third parties. This allows the definition and differentiation of user groups
of the website for the purpose of targeting marketing measures in a target group-optimized manner. However, data
records collected via "demographics" cannot be assigned to a specific person.
All processing described above, in particular the setting of Google Analytics cookies for reading information on the
end device used, will only be carried out if you have given us your express consent to do so in accordance with Art.
6 (1) lit. a GDPR. Without this consent, Google Analytics will not be used during your visit to the site. You can
revoke your consent at any time with effect for the future. To exercise your revocation, please deactivate this
service in the "Cookie Consent Tool" provided on the website.
We have concluded an order processing agreement with Google for the use of Google Analytics, which obliges Google to
protect the data of our site visitors and not to pass it on to third parties. For the transfer of data from the EU
to the USA, Google relies on so-called standard data protection clauses of the European Commission, which are
intended to ensure compliance with the European level of data protection in the USA.
Further information on Google (Universal) Analytics can be found here: https://policies.google.com/privacy?hl=de&gl=de
7) Retargeting/Remarketing/Recommendation Advertising
Criteo (Criteo SA)
On this website, information about the surfing behavior of website visitors is collected, stored, and evaluated in
pseudonymized form using the technology of Criteo SA, 32 Rue Blanche, 75009 Paris, France ("Criteo") via cookie text
files, based on our legitimate interest in displaying personalized advertising in accordance with Art. 6 (1) lit. f
GDPR. Criteo analyzes the surfing behavior using an algorithm and can then display targeted product recommendations
as personalized advertising banners on other websites (so-called publishers). Under no circumstances can the
collected data be used to personally identify the visitor of this website. The data will not be used for any other
purpose or passed on to third parties.
To object to the data collection and the creation of pseudonymized user profiles in the future, you can download the
following so-called opt-out cookie: Criteo Opt-Out (https://www.criteo.com/de/privacy/)
Further information about Criteo's technology can be found in the Criteo privacy policy: https://www.criteo.com/de/privacy/
Where legally required, we have obtained your consent for the processing of your data as described above in
accordance with Art. 6 (1) lit. a GDPR. You can revoke your consent at any time with effect for the future. To
exercise your revocation, please follow the option described above to object.
Google Ads Remarketing
Our website uses the functions of Google Ads Remarketing, which allows us to advertise for this website in Google
search results and on third-party websites. The provider is Google Ireland Limited, Gordon House, 4 Barrow St,
Dublin, D04 E5W5, Ireland ("Google"). For this purpose, Google sets a cookie in the browser of your terminal device,
which automatically enables interest-based advertising by means of a pseudonymous cookie ID and based on the pages
you visit. The processing is based on our legitimate interest in the optimal marketing of our website in accordance
with Art. 6 (1) lit. f GDPR. Further data processing will only take place if you have agreed with Google that your
Internet and app browser history will be linked to your Google account and that information from your Google account
will be used to personalize ads that you view on the web. If you are logged in to Google during your visit to our
website, Google will use your data together with Google Analytics data to create and define target group lists for
cross-device remarketing. For this purpose, your personal data will be temporarily linked by Google with Google
Analytics data to form target groups.
As part of the use of Google Ads Remarketing, personal data may be transmitted to the servers of Google LLC. in the
USA.
You can permanently disable the setting of cookies for ad preferences by downloading and installing the browser
plug-in available at the following link: https://www.google.com/settings/ads/onweb/
Alternatively, you can inform yourself about the setting of cookies and make settings via the Digital Advertising
Alliance at the Internet address www.aboutads.info. Finally, you can set
your browser so that you are informed about the setting of cookies and decide individually about their acceptance or
exclude the acceptance of cookies for certain cases or in general. If cookies are not accepted, the functionality of
our website may be limited.
Further information and the data protection regulations regarding advertising and Google can be viewed here: https://www.google.com/policies/technologies/ads/
Where legally required, we have obtained your consent for the processing of your data as described above in
accordance with Art. 6 (1) lit. a GDPR. You can revoke your consent at any time with effect for the future. To
exercise your revocation, please follow the option described above to object.
Outbrain Pixel
Within our online offering, we use the "Outbrain Pixel" from Outbrain, Inc., 39 W 13th St, New York 10011, USA
("Outbrain"). The Outbrain Pixel sets a cookie on your computer if you came to our website via an advertisement or
other campaign. Cookies are small text files that are stored on your end device. If the user visits certain pages of
this website, we can recognize that the user clicked on the advertisement and was redirected to this page
(conversion page). If personal data is processed in the process, this is done in accordance with Art. 6 (1) lit. f
GDPR on the basis of our legitimate interest in effective marketing. The information collected using the conversion
cookie is used to create conversion statistics, i.e., to record how many users reach a conversion page after
clicking on an ad. We learn the total number of users who clicked on our ad and were redirected to a page tagged
with a conversion tracking tag. However, we do not receive any information that can be used to personally identify
users.
If you do not wish to participate in tracking, you can object to this by deactivating the Outbrain Pixel cookie via
your Internet browser under user settings. You can check whether Outbrain advertising cookies are set in your
browser and deactivate them.
Where legally required, we have obtained your consent for the processing of your data as described above in
accordance with Art. 6 (1) lit. a GDPR. You can revoke your consent at any time with effect for the future. To
exercise your revocation, please follow the option described above to object or use the deactivation options in the
cookie settings of this website.
Further information on Outbrain's privacy policy can be found at https://www.outbrain.com/de/legal/privacy.
Taboola
This website uses the retargeting technology of Taboola Inc., 16 Madison Square West 7th Floor, New York, NY 10010,
USA ("Taboola"). This allows us to target visitors to our web pages with further own or third-party content in the
form of banners based on usage behavior, which are likely to correspond to the respective user interest. The display
of this content is based on a cookie-based analysis of previous usage behavior, but no personal data is stored. For
this interest-based content determination, a cookie is stored on your computer or mobile device to collect
pseudonymized data about your surfing behavior and thus individually adapt the content to the stored
information.
If the collected and evaluated information has a personal reference, the processing is carried out in accordance with
Art. 6 (1) lit. f GDPR on the basis of our legitimate interest in displaying personalized page content and in market
research.
To generally disable the use of cookies on your end device, you can set your Internet browser so that no more cookies
can be stored on your end device in the future or cookies that have already been stored are deleted. Disabling all
cookies may mean that some functions on our Internet pages can no longer be executed.
You can also permanently object to the setting of cookies for advertising purposes by Taboola by using the option
provided on the linked page below to set an opt-out cookie: https://www.taboola.com/privacy-policy#optout
Further information on Taboola's data protection can be found here: https://www.taboola.com/privacy-policy
Where legally required, we have obtained your consent for the processing of your data as described above in
accordance with Art. 6 (1) lit. a GDPR. You can revoke your consent at any time with effect for the future. To
exercise your revocation, please follow the option described above to object.
Facebook Pixel for the Creation of Custom Audiences with Extended Data Matching (without Cookie Consent
Tool)
Within our online offering, the so-called "Facebook Pixel" of the social network Facebook is used in the extended
data matching mode, which is operated by Facebook Ireland Limited, 4 Grand Canal Quay, Dublin 2, Ireland
("Facebook").
Based on his/her explicit consent, when a user clicks on an advertisement placed by us on Facebook, an addition is
appended to the URL of our linked page by the Facebook Pixel. Then, after redirection, this URL parameter is written
into the user's browser via a cookie, which our linked page sets itself. In addition, specific customer data such as
the email address, which we collect on our website linked to the Facebook advertisement during processes such as
purchase completions, account logins, or registrations, is recorded by this cookie (extended data matching). The
cookie is then read by the Facebook Pixel and allows the data, including the specific customer data, to be forwarded
to Facebook.
With the help of the Facebook Pixel with extended data matching, Facebook is able to determine the visitors to our
online offering as a target group for the display of advertisements (so-called "Facebook Ads"). Accordingly, we use
the Facebook Pixel with extended data matching to display the Facebook Ads placed by us only to those Facebook users
who have shown an interest in our online offering or who have certain characteristics (e.g., interests in certain
topics or products determined on the basis of the visited websites) that we transmit to Facebook (so-called "Custom
Audiences"). With the help of the Facebook Pixel with extended data matching, we also want to ensure that our
Facebook Ads correspond to the potential interest of the users and are not annoying. We can also further evaluate
the effectiveness of the Facebook ads for statistical and market research purposes by tracking whether users were
redirected to our website after clicking on a Facebook ad (so-called "conversion").
Compared to the standard version of Facebook Pixel, the extended data matching function helps us to better measure
the effectiveness of our advertising campaigns by capturing more assigned conversions.
All transmitted data is stored and processed by Facebook so that a connection to the respective user profile is
possible and Facebook can use the data for its own advertising purposes in accordance with the Facebook Data Usage
Policy (https://www.facebook.com/about/privacy/). The data may
enable Facebook and its partners to place advertisements on and off Facebook.
These processing operations are carried out exclusively upon granting explicit consent pursuant to Art. 6 (1) lit. a
GDPR. Consent to the use of the Facebook Pixel may only be declared by users older than 13 years of age. If you are
younger, please ask your legal guardians for permission.
The information generated by Facebook is usually transmitted to a Facebook server and stored there; this may also
involve transmission to the servers of Facebook Inc. in the USA.
You can revoke your consent at any time by deactivating the Facebook Pixel tracking. For this purpose, you can set an
opt-out cookie by clicking on the link below, which deactivates the Facebook Pixel tracking: Deactivate Facebook
Pixel
This opt-out cookie only works in this browser and only for this domain. If you delete your cookies in this browser,
you must click the above link again.
8) Rights of the Data Subject
8.1 The applicable data protection law grants you comprehensive rights of data subjects (rights of information and
intervention) vis-à-vis the controller with regard to the processing of your personal data, about which we inform
you below:
- Right of access pursuant to Art. 15 GDPR: You have the right to obtain information about your personal data
processed by us, the purposes of the processing, the categories of personal data processed, the recipients or
categories of recipients to whom your data has been or will be disclosed, the planned storage period or the
criteria for determining the storage period, the existence of a right to rectification, erasure, restriction of
processing, objection to processing, complaint to a supervisory authority, the origin of your data if it was not
collected by us from you, the existence of automated decision-making including profiling and, if applicable,
meaningful information about the logic involved and the scope and intended effects of such processing, as well
as your right to be informed of the guarantees pursuant to Art. 46 GDPR when your data is transferred to third
countries;
- Right to rectification pursuant to Art. 16 GDPR: You have the right to obtain without undue delay the
rectification of inaccurate data concerning you and/or the completion of incomplete data stored by us;
- Right to erasure pursuant to Art. 17 GDPR: You have the right to request the erasure of your personal data if
the conditions of Art. 17 (1) GDPR are met. However, this right does not exist in particular if the processing
is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal
obligation, for reasons of public interest, or for the establishment, exercise, or defense of legal claims;
- Right to restriction of processing pursuant to Art. 18 GDPR: You have the right to request the restriction of
the processing of your personal data as long as the accuracy of your data contested by you is verified, if you
refuse the erasure of your data due to inadmissible data processing and instead request the restriction of the
processing of your data, if you need your data for the establishment, exercise, or defense of legal claims after
we no longer need this data after the purpose has been achieved, or if you have lodged an objection for reasons
relating to your particular situation, as long as it has not yet been determined whether our legitimate grounds
override;
- Right to information pursuant to Art. 19 GDPR: If you have asserted the right to rectification, erasure, or
restriction of processing against the controller, the controller is obliged to notify all recipients to whom the
personal data concerning you have been disclosed of this rectification or erasure of the data or restriction of
processing, unless this proves impossible or involves a disproportionate effort. You have the right to be
informed about these recipients.
- Right to data portability pursuant to Art. 20 GDPR: You have the right to receive your personal data that you
have provided to us in a structured, commonly used, and machine-readable format or to request that it be
transmitted to another controller, where technically feasible;
- Right to withdraw consent granted pursuant to Art. 7 (3) GDPR: You have the right to withdraw your consent to
the processing of data at any time with effect for the future. In the event of withdrawal, we will delete the
data concerned immediately, unless further processing can be based on a legal basis for processing without
consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its
withdrawal;
- Right to lodge a complaint pursuant to Art. 77 GDPR: If you consider that the processing of personal data
relating to you infringes the GDPR, you have the right – without prejudice to any other administrative or
judicial remedy – 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.
8.2 RIGHT TO OBJECT
IF WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR LEGITIMATE INTERESTS WITHIN THE FRAMEWORK OF A BALANCING OF
INTERESTS, YOU HAVE THE RIGHT TO OBJECT TO THIS PROCESSING AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR
SITUATION, WITH EFFECT FOR THE FUTURE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, WE RESERVE THE RIGHT TO
FURTHER PROCESSING IF WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR
INTERESTS, FUNDAMENTAL RIGHTS, AND FREEDOMS, OR IF THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE, OR DEFENSE OF
LEGAL CLAIMS.
IF YOUR PERSONAL DATA IS PROCESSED BY US 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 ADVERTISING. YOU CAN EXERCISE THE OBJECTION
AS DESCRIBED ABOVE.
IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.
9) Duration of Storage of Personal Data
The duration of the storage of personal data is measured on the basis of the respective legal basis, the purpose of
processing, and – if relevant – additionally on the basis of the respective statutory retention period (e.g.,
commercial and tax retention periods).
When processing personal data on the basis of explicit consent pursuant to Art. 6 (1) lit. a GDPR, this data is
stored until the data subject withdraws his/her consent.
If there are statutory retention periods for data that is processed within the framework of legal or similar
obligations on the basis of Art. 6 (1) lit. b GDPR, this data will be routinely deleted after the retention periods
have expired, provided that it is no longer necessary for the performance of the contract or the initiation of the
contract and/or there is no legitimate interest on our part in further storage.
When processing personal data on the basis of Art. 6 (1) lit. f GDPR, this data is stored until the data subject
exercises his/her right to object pursuant to Art. 21 (1) GDPR, unless we can demonstrate compelling legitimate
grounds for the processing which override the interests, rights, and freedoms of the data subject, or the processing
serves the establishment, exercise, or defense of legal claims.
When processing personal data for the purpose of direct marketing on the basis of Art. 6 (1) lit. f GDPR, this data
is stored until the data subject exercises his/her right to object pursuant to Art. 21 (2) GDPR.
Unless otherwise stated in the other information in this declaration about specific processing situations, stored
personal data will otherwise be deleted when it is no longer necessary for the purposes for which it was collected
or otherwise processed.
