§1 – General note and mandatory information
Purpose of the privacy policy
This privacy policy informs users about the type, scope and purpose of the collection and use of personal data by Novafy on this website.
We would like to point out that data transmission over the Internet (e.g. when communicating by e-mail) can have security gaps. Complete protection of data against access by third parties is not possible.
Designation of the responsible entity
The responsible body for data processing on this website is:
NOVAFY DIGITAL SOLUTIONS SL
Calle Braille 16, 28034 Madrid, Spain
The responsible body decides alone or jointly with others on the purposes and means of processing personal data (e.g. names, contact details, etc.).
Storage period
Unless a more specific storage period has been specified in this Privacy Policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a justified 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. retention periods under tax or commercial law); in the latter case, the deletion will take place after these reasons no longer apply.
Revocation of your consent to data processing
Some data processing operations are only possible with your express consent. You can withdraw your consent at any time. An informal notification by e-mail is sufficient for the revocation. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
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 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR, insofar as special categories of data are processed in accordance with Art. 9 para. 1 GDPR. In the event of express consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49 para. 1 lit. a GDPR. If you have consented to the storage of cookies or access to information in your end device (e.g. via device fingerprinting), the data processing is also carried out on the basis of Section 25 (1) TTDSG. Consent can be revoked at any time. If your data is required to fulfill the contract or to carry out pre-contractual measures, we process your data on the basis of Art. 6 para. 1 lit. b GDPR. Furthermore, we process your data if this is necessary to fulfill a legal obligation on the basis of Art. 6 para. 1 lit. c GDPR. Data processing may also be carried out on the basis of our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR. Information on the relevant legal bases in each individual case is provided in the following paragraphs of this privacy policy.
Note on data transfer to the USA and other third countries
We use tools from companies based in the USA or other third countries that are not secure under data protection law. If these tools are active, your personal data may be transferred to these third countries and processed there. We would like to point out that a level of data protection comparable to that in the EU cannot be guaranteed in these countries. For example, US companies are obliged to hand over personal data to security authorities without you as the data subject being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g. secret services) may process, evaluate and permanently store your data on US servers for surveillance purposes. We have no influence on these processing activities.
Right to object to the collection of data in special cases and to direct marketing (Art. 21 GDPR)
If data processing is carried out on the basis of Art. 6 para. 1 lit. 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 personal data concerned 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 defense of legal claims (objection pursuant to Art. 21 (1) GDPR).
If your personal data are 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 advertising; this also applies to profiling insofar as it is associated with such direct marketing. If you object, your personal data will subsequently no longer be used for the purpose of direct marketing (objection pursuant to Art. 21 (2) GDPR).
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 to do this. The right to restriction of processing exists in the following cases:
- If you dispute the accuracy of your personal data stored by us, we generally need time to check this. For the duration of the review, you have the right to request the restriction of the processing of your personal data.
- If the processing of your personal data was/is carried out unlawfully, you can request the restriction of data processing instead of erasure.
- If we no longer need your personal data, but you need it for the exercise, defense or assertion of legal claims, you have the right to request the restriction of the processing of your personal data instead of its erasure.
- If you have lodged an objection in accordance with Art. 21 para. 1 GDPR, a balance must be struck between your interests and ours. As long as it has not yet 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 establishment, 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 of a Member State.
Right to lodge a complaint with the competent supervisory body
As a data subject, you have the right to lodge a complaint with the competent supervisory authority in the event of a breach of data protection law. The right to lodge a complaint may be exercised in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement. The right to lodge a complaint exists without prejudice to any other administrative or judicial remedy.
Right to data portability
You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another person responsible, this will only take place insofar as it is technically feasible.
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 transmit to us cannot be read by third parties.
Encrypted payments on this website
If there is an obligation to provide us with your payment data (e.g. account number for direct debit authorization) after the conclusion of a fee-based contract, this data is required for payment processing.
Payment transactions using common means of payment (Visa/MasterCard, direct debit) are made exclusively via an encrypted SSL or TLS connection. 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.
With encrypted communication, the payment data you transmit to us cannot be read by third parties.
Information, deletion and correction
Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipient and the purpose of data processing and, if applicable, a right to correction or deletion of this data. For this purpose and for further questions on the subject of personal data, you can contact us at any time.
§2 – Hosting
We host the content of our website with the following provider:
IONOS
The provider is IONOS SE, Elgendorfer Str. 57, 56410 Montabaur (hereinafter referred to as IONOS). When you visit our website, IONOS collects various log files including your IP addresses. Details can be found in the IONOS privacy policy: https://www.ionos.de/terms-gtc/terms-privacy.
The use of IONOS is based on Art. 6 para. 1 lit. f GDPR. We have a legitimate interest in displaying our website as reliably as possible. 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.
DPA
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract prescribed by data protection law, which ensures that it processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.
§3 – General notes and mandatory information
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 the statutory data protection regulations and this privacy policy.
When you use this website, various personal data is collected. Personal data are data with which you can be personally identified. 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 would like to point out that data transmission on the Internet (e.g. when communicating by e-mail) can have security gaps. Complete protection of data against access by third parties is not possible.
Note on the responsible office
The responsible body for data processing on this website is:
NOVAFY DIGITAL SOLUTIONS SL
Calle Braille 16, 28034 Madrid, Spain
The responsible body is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (e.g. names, e-mail addresses, etc.).
Storage period
Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a justified 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. retention periods under tax or commercial law); in the latter case, the deletion will take place after these reasons no longer apply.
General notes 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 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR, insofar as special categories of data are processed in accordance with Art. 9 para. 1 GDPR. In the event of express consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49 para. 1 lit. a GDPR. If you have consented to the storage of cookies or access to information in your end device (e.g. via device fingerprinting), the data processing is also carried out on the basis of Section 25 (1) TTDSG. Consent can be revoked at any time. If your data is required to fulfill the contract or to carry out pre-contractual measures, we process your data on the basis of Art. 6 para. 1 lit. b GDPR. Furthermore, we process your data if this is necessary to fulfill a legal obligation on the basis of Art. 6 para. 1 lit. c GDPR. Data processing may also be carried out on the basis of our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR. Information on the relevant legal bases in each individual case is provided in the following paragraphs of this privacy policy.
Note on data transfer to the USA and other third countries
We use tools from companies based in the USA or other third countries that are not secure under data protection law. If these tools are active, your personal data may be transferred to these third countries and processed there. We would like to point out that a level of data protection comparable to that in the EU cannot be guaranteed in these countries. For example, US companies are obliged to hand over personal data to security authorities without you as the data subject being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g. secret services) may process, evaluate and permanently store your data on US servers for surveillance purposes. We have no influence on these processing activities.
Revocation of your consent to data processing
Many data processing operations are only possible with your express consent. You can withdraw your consent at any time. An informal notification by e-mail is sufficient for the revocation. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
Right to object to the collection of data in special cases and to direct marketing (Art. 21 GDPR)
IF DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6 ABS. 1 LIT. 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 PERSONAL DATA CONCERNED 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 DEFENSE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21 (1) GDPR).
IF YOUR PERSONAL DATA ARE 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 ADVERTISING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS ASSOCIATED WITH SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21 (2) GDPR).
Right to lodge a complaint with the competent supervisory body
In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged violation. The right to lodge a complaint exists without prejudice to any other administrative or judicial remedy.
Right to data portability
You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another person responsible, this will only take place insofar as it is technically feasible.
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 transmit to us cannot be read by third parties.
Information, deletion and correction
Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipient and the purpose of data processing and, if applicable, a right to correction or deletion of this data. For this purpose and for further questions on the subject of 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 to do this. The right to restriction of processing exists in the following cases:
- If you dispute the accuracy of your personal data stored by us, we generally need time to check this. For the duration of the review, you have the right to request the restriction of the processing of your personal data.
- If the processing of your personal data was/is carried out unlawfully, you can request the restriction of data processing instead of erasure.
- If we no longer need your personal data, but you need it for the exercise, defense or assertion of legal claims, you have the right to request the restriction of the processing of your personal data instead of its erasure.
- If you have lodged an objection in accordance with Art. 21 para. 1 GDPR, a balance must be struck between your interests and ours. As long as it has not yet 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 establishment, 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 of a Member State.
§4 – Data collection on this website
Server-Log Files
The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:
- Browser type and browser version
- Operating system used
- Referrer URL
- Host name of the accessing computer
- Time of the server request
- IP address
This data is not merged with other data sources.
This data is collected on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of its website – the server log files must be recorded for this purpose.
Contact form
If you send us inquiries via the contact form, your details from the inquiry form, including the contact details you provide there, will be stored by us for the purpose of processing the inquiry and in the event of follow-up questions. We will not pass on this data without your consent.
This data is processed on the basis of Art. 6 para. 1 lit. b GDPR if your request is related to the fulfillment of a contract or is necessary for the implementation of 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 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested; consent can be revoked at any time.
We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Mandatory statutory provisions – in particular retention periods – remain unaffected.
Request by e-mail or telephone
If you contact us by e-mail or telephone, we will store and process your inquiry, including all personal data (name, inquiry), for the purpose of processing your request. We will not pass on this data without your consent.
This data is processed on the basis of Art. 6 para. 1 lit. b GDPR if your request is related to the fulfillment of a contract or is necessary for the implementation of 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 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested; consent can be revoked at any time.
The data you send to us via contact requests will remain with us until you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your request has been processed). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.
§5 - Analysis-Tools and marketing
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information about visit activity with Google Analytics. For more information about Google's privacy practices, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=de
IONOS WebAnalytics
This website uses the analysis services of IONOS WebAnalytics (hereinafter: IONOS). The provider is 1&1 IONOS SE, Elgendorfer Straße 57, D – 56410 Montabaur. As part of the analyses with IONOS, visitor numbers and behavior (e.g. number of page views, duration of a website visit, bounce rates), visitor sources (i.e. which page the visitor comes from), visitor locations and technical data (browser and operating system versions) can be analyzed. For this purpose, IONOS stores the following data in particular:
- Referrer (previously visited website)
- Requested website or file
- Browser type and browser version
- Operating system used
- Type of device used
- Time of access
- IP address in anonymized form (only used to determine the location of access)
According to IONOS, data collection is completely anonymized so that it cannot be traced back to individual persons. Cookies are not stored by IONOS WebAnalytics.
The data is stored and analyzed on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the statistical analysis of user behavior in order to optimize both its website and its advertising. 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.
Further information on data collection and processing by IONOS WebAnalytics can be found in the IONOS privacy policy at the following link: https://www.ionos.de/terms-gtc/datenschutzerklaerung/
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