Data protection - VIFOREAL

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Privacy policy
This privacy policy explains the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the associated websites, functions and content as well as external online presences, such as our social media profile (hereinafter jointly referred to as “online offer”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Responsible
VIFOREAL EOOD
Entract 127
127 Georgi S. Rakovski St.
1000 Sofia
- Contact data (e.g., e-mail, telephone numbers).
- Content data (e.g., text entries, photographs, videos).
- Usage data (e.g., websites visited, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).
- Responding to contact requests and communicating with users.
- Security measures.
- Reach measurement/marketing
“Processing” means any operation or set of operations which is performed on personal data, whether or not by automated means. The term is broad and covers practically any handling of data.
“Pseudonymization” means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

Types of data processed:
- Inventory data (e.g., names, addresses).

Categories of data subjects
Visitors and users of the online offer (hereinafter we also refer to the data subjects collectively as “users”).

Purpose of the processing
- Provision of the online offering, its functions and content.

Terminology used
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as ‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Profiling” means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Relevant legal bases
In accordance with Art. 13 GDPR, we inform you of the legal basis of our data processing. If the legal basis is not stated in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 GDPR, the legal basis for processing for the performance of our services and implementation of contractual measures as well as responding to inquiries is Art. 6 para. 1 lit. b GDPR, the legal basis for processing to fulfill our legal obligations is Art. 6 para. 1 lit. c GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 para. 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.

Security measures
We take appropriate technical and organizational measures in accordance with Art. 32 GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons, in order to ensure a level of security appropriate to the risk.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the access, input, disclosure, safeguarding of availability and separation of the data. We have also set up procedures to ensure that data subjects' rights are exercised, data is deleted and we respond to data threats. Furthermore, we take the protection of personal data into account as early as the development and selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and data protection-friendly default settings (Art. 25 GDPR).

Cooperation with processors and third parties
If we disclose data to other persons and companies (processors or third parties) as part of our processing, transfer it to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g. if the transfer of data to third parties, such as payment service providers, is necessary for the performance of a contract pursuant to Art. 6 para. 1 lit. b GDPR), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we commission third parties with the processing of data on the basis of a so-called “order processing contract”, this is done on the basis of Art. 28 GDPR.

Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure or transfer of data to third parties, this will only take place if it is done to fulfill our (pre)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 et seq. GDPR are met. This means, for example, that the processing takes place on the basis of special guarantees, such as the officially recognized determination of a level of data protection corresponding to the EU (e.g. for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).

Rights of the data subjects
You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with Art. 15 GDPR.

You have accordingly. Art. 16 GDPR, you have the right to request the completion of data concerning you or the rectification of inaccurate data concerning you.

In accordance with Art. 17 GDPR, you have the right to demand that the data in question be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with Art. 18 GDPR.

You have the right to request to receive the data concerning you that you have provided to us in accordance with Art. 20 GDPR and to request its transfer to other controllers.

You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 GDPR.

Right of withdrawal
You have the right to withdraw your consent in accordance with Art. 7 (3) GDPR with effect for the future

Right to object
You can object to the future processing of data concerning you in accordance with Art. 21 GDPR at any time. In particular, you may object to processing for direct marketing purposes.

Cookies and the right to object to direct advertising
“Cookies” are small files that are stored on users' computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online service. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes their browser. The content of a shopping cart in an online store or a login status, for example, can be stored in such a cookie. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent”. For example, the login status can be saved if the user visits the website after several days. The interests of users can also be stored in such a cookie and used for reach measurement or marketing purposes. “Third-party cookies” are cookies that are offered by providers other than the controller who operates the online service (otherwise, if they are only the controller's cookies, they are referred to as ‘first-party cookies’).

We may use temporary and permanent cookies and provide information about this in our privacy policy.

If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that you may then not be able to use all the functions of this website.

Deletion of data
The data processed by us will be deleted or its processing restricted in accordance with Art. 17 and 18 GDPR. Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.

According to legal requirements in Germany, data is stored in particular for 10 years in accordance with §§ 147 para. 1 AO, 257 para. 1 no. 1 and 4, para. 4 HGB (books, records, management reports, accounting vouchers, commercial books, documents relevant for taxation, etc.) and 6 years in accordance with § 257 para. 1 no. 2 and 3, para. 4 HGB (commercial letters).

According to legal requirements in Austria, the retention period is 7 years in accordance with § 132 para. 1 BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, statement of income and expenses, etc.), 22 years in connection with real estate and 10 years for documents in connection with electronically provided services, telecommunications, radio and television services provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.

Business-related processing
We also process

- Contract data (e.g., subject matter of the contract, term, customer category).
- Payment data (e.g. bank details, payment history)
of our customers, interested parties and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

Administration, financial accounting, office organization, contact management
We process data as part of administrative tasks and the organization of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process as part of the provision of our contractual services. The processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks that serve to maintain our business activities, perform our tasks and provide our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information specified in these processing activities.

We disclose or transmit data to the tax authorities, consultants such as tax advisors or auditors as well as other fee offices and payment service providers.

We also store information on suppliers, event organizers and other business partners on the basis of our business interests, e.g. for the purpose of contacting them at a later date. We generally store this mainly company-related data permanently.

Business analyses and market research
In order to operate our business economically and to identify market trends and the wishes of our contractual partners and users, we analyze the data we have on business transactions, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data and metadata. In doing so, we process inventory data, communication data, contract data, payment data, usage data, metadata on the basis of Art. 6 para. 1 lit. f. GDPR. GDPR, whereby the data subjects include contractual partners, interested parties, customers, visitors and users of our online offering.

The analyses are carried out for the purpose of business evaluations, marketing and market research. In doing so, we can take into account the profiles of registered users with information, e.g. on the services they have used. The analyses help us to increase user-friendliness, optimize our offer and improve business efficiency. The analyses serve us alone and are not disclosed externally, unless they are anonymous analyses with summarized values.

If these analyses or profiles are personal, they are deleted or anonymized when the user terminates the contract, otherwise after two years from the conclusion of the contract. Otherwise, the overall business analyses and general trend determinations are prepared anonymously wherever possible.

Registration function
Users can create a user account. As part of the registration process, the required mandatory information is communicated to the users and processed on the basis of Art. 6 para. 1 lit. b GDPR for the purpose of providing the user account. The processed data includes in particular the login information (name, password and an email address). The data entered during registration is used for the purpose of using the user account and its purpose.

Users may be informed by e-mail about information relevant to their user account, such as technical changes. If users have terminated their user account, their data relating to the user account will be deleted, subject to a statutory retention obligation. It is the responsibility of users to back up their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data stored during the term of the contract.

As part of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. This data is stored on the basis of our legitimate interests as well as those of the user in protection against misuse and other unauthorized use. This data is not passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 para. 1 lit. c GDPR. The IP addresses are anonymized or deleted after 7 days at the latest.

Contacting us
When contacting us (e.g. by contact form, e-mail, telephone or via social media), the user's details are processed to process the contact request and its handling in accordance with Art. 6 para. 1 lit. b) GDPR. The user's details may be stored in a customer relationship management system (“CRM system”) or comparable inquiry organization.

We delete the inquiries if they are no longer required. We review the necessity every two years; the statutory archiving obligations also apply.

Newsletter
With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter, you agree to receive it and to the procedures described.

Content of the newsletter: We only send newsletters, emails and other electronic notifications with advertising information (hereinafter “newsletter”) with the consent of the recipient or with legal permission. If the contents of the newsletter are specifically described when registering for the newsletter, they are decisive for the user's consent. Otherwise, our newsletters contain information about our services and us.

Double opt-in and logging: Registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registering you will receive an e-mail asking you to confirm your registration. This confirmation is necessary so that no-one can register with other people's e-mail addresses. Subscriptions to the newsletter are logged in order to be able to prove the registration process in accordance with legal requirements. This includes storing the time of registration and confirmation as well as the IP address. Changes to your data stored with the mailing service provider are also logged.

Registration data: To register for the newsletter, it is sufficient to enter your e-mail address. Optionally, we ask you to enter a name so that we can address you personally in the newsletter.

The newsletter is sent and its performance measured on the basis of the consent of the recipients in accordance with Art. 6 (1) point a, Art. 7 GDPR in conjunction with Section 7 (2) no. 3 of the German Unfair Competition Act (UWG) or, if consent is not required, on the basis of our legitimate interests in direct marketing in accordance with Art. 6 (1) point f. GDPR in conjunction with Section 7 (3) UWG.

The registration process is recorded on the basis of our legitimate interests in accordance with Art. 6 (1) point f GDPR. Our interest lies in using a user-friendly and secure newsletter system that serves both our business interests and meets user expectations, and also allows us to provide evidence of consent.

Termination/revocation – You can terminate the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to terminate the newsletter at the end of each newsletter. We may store the e-mail addresses provided for up to three years on the basis of our legitimate interests before deleting them in order to be able to prove a previously given consent. The processing of this data is limited to the purpose of a possible defense against claims. An individual request for deletion is possible at any time, provided that the former existence of consent is confirmed at the same time.

Newsletter – performance measurement
The newsletters contain a so-called “web beacon”, i.e. a pixel-sized file that is retrieved from our server when the newsletter is opened or, if we use a mailing service provider, from their server. As part of this retrieval, technical information such as information about the browser and your system, as well as your IP address and the time of the retrieval, are initially collected.

This information is used for technical improvement of the services based on the technical data or the target groups and their reading behavior based on their retrieval locations (which can be determined using the IP address) or access times. The statistical surveys also include determining whether the newsletters are opened, when they are opened and which links are clicked. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is neither our nor, if used, the e-mail service provider's intention to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.

Unfortunately, it is not possible to separately revoke the performance measurement; in this case, the entire newsletter subscription must be canceled.

Hosting and e-mail delivery
The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space and database services, e-mail delivery, security services and technical maintenance services that we use for the purpose of operating this online service.

In doing so, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer in accordance with. Art. 6 para. 1 lit. f DSGVO i.V.m. Art. 28 DSGVO (conclusion of order processing contract).

Collection of access data and log files
We, or rather our hosting provider, collect data on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR, data on every access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g. to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data whose further retention is required for evidentiary purposes are exempt from the deletion until the final clarification of the incident.

Integration of third-party services and content
On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO), we use content or service offers from third-party providers to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as “content”).

This always assumes that the third-party providers of this content can see the user's IP address, since without the IP address they would not be able to send the content to the user's browser. The IP address is therefore required to display this content. We endeavor to use only content from providers who use the IP address solely for the purpose of delivering the content. Third-party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, visit times, and other information regarding the use of our online services. This information may also be linked to similar information from other sources.

Vimeo
We may embed videos from the Vimeo platform provided by Vimeo Inc., Attention: Legal Department, 555 West 18th Street New York, New York 10011, USA. Privacy Policy: https://vimeo.com/privacy. Please note that Vimeo may use Google Analytics and we refer you to the data protection declaration (https://www.google.com/policies/privacy) and opt-out options for Google Analytics (http://tools.google.com/dlpage/gaoptout?hl=de) or Google's settings for data use for marketing purposes (https://adssettings.google.com/.).

YouTube
We embed videos from the YouTube platform provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Google Fonts
We integrate fonts (“Google Fonts”) from Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Google ReCaptcha
We integrate the function for detecting bots, e.g. when entering data into online forms (“ReCaptcha”) from the provider Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/, Opt-Out: https://adssettings.google.com/authenticated.

Typekit fonts from Adobe
On the basis of our legitimate interests (i.e. interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit. f. DSGVO), we use external “Typekit” fonts from Adobe Systems Software Ireland Limited, 4-6 Riverwalk, Citywest Business Campus, Dublin 24, Republic of Ireland. Adobe is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TNo9AAG&status=Active).
Created with Datenschutz-Generator.de by RA Dr. Thomas Schwenke




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