Data protection

1. INTRODUCTION

In the following, we provide information about the processing of personal data when using our website https://vyndo.io and our social media profiles. Personal data is all data that can be related to a specific natural person, e.g. their name or IP address.

1.1. CONTACT DATA

The controller pursuant to Art. 4 (7) of the EU General Data Protection Regulation (GDPR) is UpReach GmbH, Keithstraße 2-4, 10787 Berlin, Germany, email: mail@upreach.com. We are legally represented by Danny Fandrich.

Our data protection officer is heyData GmbH, Kantstr. 99, 10627 Berlin, www.heydata.eu, e-mail: datenschutz@heydata.eu.

1.2. SCOPE OF DATA PROCESSING, PURPOSES OF PROCESSING AND LEGAL BASIS

The scope of data processing, processing purposes and legal bases are explained in detail below. The following legal bases for data processing can generally be considered:

Art. 6 para. 1 sentence 1 it. a GDPR serves as the legal basis for processing operations for which we obtain consent. Art. 6 para. 1 sentence 1 lit. b GDPR is the legal basis if the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for them. This legal basis also applies to processing that is necessary for pre-contractual measures, for example in the case of inquiries about our products or services.Art. 6 para. 1 sentence 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case in tax law, for example.Art. 6 para. 1 sentence 1 lit. f GDPR serves as the legal basis if we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.

1.3. DATA PROCESSING OUTSIDE THE EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, the security of the data during transfer is guaranteed by adequacy decisions of the EU Commission (Art. 45 para. 3 GDPR), if available (e.g. for Great Britain, Canada and Israel).

If no adequacy decision exists (e.g. for the USA), the legal basis for data transfer is usually standard contractual clauses, i.e. unless we indicate otherwise. These are a set of rules adopted by the EU Commission and form part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they guarantee the security of data transfer. Many of the providers have provided contractual guarantees that go beyond the standard contractual clauses and protect the data beyond the standard contractual clauses. These are, for example, guarantees regarding the encryption of the data or regarding the obligation of the third party to inform the data subject if law enforcement agencies wish to access data.

1.4. STORAGE PERIOD

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, i.e. the data will be blocked and not processed for other purposes. This applies, for example, to data that we must retain for commercial or tax law reasons.

1.5. RIGHTS OF THE PERSONS CONCERNED

Data subjects have the following rights vis-à-vis us with regard to their personal data:

Right of access, right to rectification or erasure, right to restriction of processing, right to object to processing, right to data portability, right to withdraw consent at any time. Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities are available here ‍.

1.6. OBLIGATION TO PROVIDE DATA

In the context of a business relationship or other relationship, customers, interested parties or third parties must only provide us with the personal data that is necessary for the establishment, execution and termination of the business relationship or for the other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude a contract or provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory information is marked as such.

1.7. NO AUTOMATED DECISION MAKING IN INDIVIDUAL CASES

In principle, we do not use fully automated decision-making in accordance with Article 22 GDPR to establish and implement a business relationship or other relationship. If we use these procedures in individual cases, we will provide separate information about this if this is required by law.

1.8. CONTACT

When you contact us, e.g. by email or telephone, the data you provide us with (e.g. names and email addresses) will be stored by us in order to answer your questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 sentence 1 lit. f GDPR) in answering inquiries addressed to us. We delete the data collected in this context after storage is no longer necessary or restrict processing if there are statutory retention obligations.

1.9. CUSTOMER SURVEYS

From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We delete the data once the results of the surveys have been evaluated.

2. NEWSLETTER

We reserve the right to inform customers who have already used our services or purchased goods about our offers from time to time by email or other electronic means if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest lies in direct advertising (Recital 47 GDPR). Customers can object to the use of their email address for advertising purposes at any time at no additional cost, for example via the link at the end of each email or by sending an email to our email address stated above.

Interested parties have the option of subscribing to a free newsletter. We process the data provided during registration exclusively for the purpose of sending the newsletter. Registration takes place by selecting the corresponding field on our website, by ticking the corresponding field in a paper document or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 para. 1 sentence 1 lit. a GDPR. Consent can be withdrawn at any time, e.g. by clicking on the corresponding link in the newsletter or by sending a message to the email address provided above. The processing of the data until revocation remains lawful even in the event of revocation.

Based on the consent of the recipients (Art. 6 para. 1 sentence 1 lit. a GDPR), we also measure the opening and click rate of our newsletters in order to understand which content is relevant for our recipients.

We send newsletters using the HubSpot tool from the provider HubSpot, Inc, 25 1st Street Cambridge, MA 0214, USA (privacy policy: here). The provider processes content, usage, meta/communication data and contact data in the EU.

3. DATA PROCESSING ON OUR WEBSITE

3.1. INFORMATIONAL USE OF THE WEBSITE

When using the website for informational purposes, i.e. when visitors to the site do not send us information separately, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so the legal basis is Art. 6 para. 1 sentence 1 lit. f GDPR.

These data are:

IP addressDate and time of the requestTime zone difference to Greenwich Mean Time (GMT)Content of the request (specific page)Access status/HTTP status codeAmount of data transferredWebsite from which the request originatesBrowserOperating system and its interfaceLanguage and version of the browser softwareThis data is also stored in log files. They are deleted when their storage is no longer required, at the latest after 14 days.

3.2. WEBHOSTING AND PROVISION OF THE WEBSITE

Our website is hosted by Webflow. The provider is Webflow, Inc, 398 11th St., Floor 2, San Francisco, CA 94103, USA. The provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data, in the USA. Further information can be found in the provider's privacy policy here.

It is our legitimate interest to provide a website, so that the legal basis for the data processing described is Art. 6 para. 1 sentence 1 lit. f GDPR.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses issued in accordance with the review procedure pursuant to Art. 93 para. 2 GDPR (Art. 46 para. 2 lit. c GDPR), which we have agreed with the provider.

3.3. CONTACT FORM

When contacting us via the contact form on our website, we store the data requested there and the content of the message.the legal basis for the processing is our legitimate interest in answering inquiries addressed to us. The legal basis for the processing is therefore Art. 6 para. 1 sentence 1 lit. f GDPR We delete the data arising in this context after the storage is no longer necessary, or restrict the processing if there are legal storage obligations.

3.4. JOB ADVERTISEMENTS

We publish job vacancies in our company on our website, on pages linked to the website or on third-party websites, and the data provided as part of the application is processed in order to carry out the application process. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88 para. 1 GDPR in conjunction with Section 26 para. 1 BDSG. We have marked the data required to carry out the application process accordingly or refer to it. If applicants do not provide this data, we will not be able to process the application. Further data is voluntary and not required for an application. If applicants provide further information, this is based on their consent (Art. 6 para. 1 sentence 1 lit. a GDPR).

We ask applicants to refrain from providing information on political opinions, religious beliefs and similar sensitive data in their CV and cover letter. They are not required for an application. If applicants nevertheless provide such information, we cannot prevent their processing as part of the processing of the CV or cover letter. Their processing is then also based on the consent of the applicants (Art. 9 para. 2 lit. a GDPR).

Finally, we process applicants' data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 sentence 1 lit. a GDPR.

We pass on the applicants' data to the responsible employees in the HR department, to our processors in the area of recruiting and to the other employees involved in the application process.

If we enter into an employment relationship with the applicant following the application process, we will only delete the data after the employment relationship has ended. Otherwise, we will delete the data no later than six months after rejecting an applicant.

If applicants have given us their consent to use their data for further application procedures, we will only delete their data one year after receipt of the application.

3.5. OFFER OF GOODS AND SERVICES

We offer goods and services via our website. We process the following data as part of the order process:

Company Telephone E-mail address The data is processed for the performance of the contract concluded with the respective site visitor (Art. 6 para. 1 sentence 1 lit. b GDPR).

We pass on the aforementioned data to messenger Transport + Logistik GmbH, Martin-Luther-Str. 7, 10777 Berlin, Germany, insofar as this is necessary in the context of the order.

The legal basis for processing is Art. 6 para. 1 sentence 1 lit. b GDPR, as it is necessary for the performance of the contract.

3.6. PAYMENT SERVICE PROVIDERS

To process payments, we use Stripe Payments Europe, Ltd, Ireland, which is itself a data controller within the meaning of Art. 4 No. 7 GDPR. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfill the contract concluded with our customers (Art. 6 para. 1 sentence 1 lit. b GDPR).

3.7. THIRD PARTY PROVIDERS

3.7.1 HubSpot

We use HubSpot to manage customer relationships. The provider is HubSpot, Inc, 25 1st Street Cambridge, MA 0214, USA. The provider processes usage data (e.g. websites visited, interest in content, access times), content data (e.g. entries in online forms) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We have a legitimate interest in managing data in a simple and inexpensive way.

The data will be deleted if the purpose of its collection no longer applies and there are no retention obligations to the contrary. Further information can be found in the provider's privacy policy here.

3.7.2 Webflow

We use Webflow to create websites. The provider is Webflow, Inc, 398 11th St., Floor 2, San Francisco, CA 94103, USA. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We have a legitimate interest in setting up and maintaining a website and thus presenting ourselves to the outside world.

We delete the data when the purpose for which it was collected no longer applies. Further information can be found in the provider's privacy policy here.

3.7.3 Google Analytics

We use Google Analytics for analysis. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for processing is Art. 6 para. 1 sentence 1 lit. a GDPR. Processing is carried out on the basis of consent. Data subjects can withdraw their consent at any time, e.g. by contacting us using the contact details provided in our privacy policy. The revocation does not affect the legality of the processing until the revocation.

The data will be deleted if the purpose of its collection no longer applies and there is no obligation to retain it. Further information can be found in the provider's privacy policy here.

3.7.4 Microsoft Clarity

We use Microsoft Clarity to identify business potential and for analysis purposes. This service is provided by Microsoft Ireland Operations, Ltd, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland. User data such as pages visited, areas of interest, times of access as well as meta and communication data such as device information and IP addresses are processed within the EU.

Data processing is based on Art. 6 para. 1 sentence 1 lit. a GDPR and is carried out with your consent. This consent can be withdrawn at any time, for example by contacting us via the channels specified in our privacy policy. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

The data will be deleted as soon as the purpose for which it was collected no longer applies and there are no statutory retention periods to prevent this. Detailed information can be found in the privacy policy Further information can be found in the provider's privacy policy here.
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4. DATA PROCESSING ON SOCIAL MEDIA PLATFORMS

We are represented in social media networks in order to present our company and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to display advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. For this purpose, the network operators store information on user behavior in cookies on the user's computer. It is also possible that the operators may combine this information with other data. Users can find further information and information on how users can object to processing by the site operators in the privacy policies of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, meaning that they process data there. This may result in risks for users, e.g. because the enforcement of their rights is made more difficult or government agencies gain access to the data.

When users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so the legal basis is Art. 6 para. 1 sentence 1 lit. f GDPR.

4.1 FACEBOOK

We maintain a profile on Facebook. The operator is Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here. One way to object to data processing is via settings for advertisements. We are jointly responsible for processing the data of visitors to our profile on the basis of an agreement with Facebook within the meaning of Art. 26 GDPR. Facebook explains exactly which data is processed here. Data subjects can exercise their rights both against us and against Facebook. However, according to our agreement with Facebook, we are obliged to forward requests to Facebook. Data subjects will therefore receive faster feedback if they contact Facebook directly.

4.2 INSTAGRAM

We maintain a profile on Instagram. The operator is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here.

4.3 TWITTER

We maintain a profile on Twitter. The operator is Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The privacy policy is available here. You can object to data processing via the settings for advertisements.

4.4 LINKEDIN

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here. You can object to data processing via the settings for advertisements.

4.5 XING

We maintain a profile on Xing. The operator is New Work SE, Dammtorstraße 29-32, 20354 Hamburg. The privacy policy is available here.

5. CHANGES TO THIS PRIVACY POLICY

We reserve the right to amend this privacy policy with effect for the future. A current version is always available here.

6. QUESTIONS AND COMMENTS

If you have any questions or comments regarding this privacy policy, please do not hesitate to contact us using the contact details above.