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PRIVACY POLICY

1. Introduction

We ("us", "our") take the protection of the personal data of the users ("user" or "you") of our website (the "website", the "services", the "digital assets" ) very seriously and we are committed to protecting the information that users make available to us using our website. Furthermore, we are committed to protecting and using your information in accordance with applicable law. This privacy policy explains our practices regarding the collection, use and disclosure of your information through the use of our Services when you access the Services through your devices. Please read the privacy policy carefully and ensure you fully understand our practices regarding your information before using our Services. If you have read and fully understood this policy and do not agree with our practices, you must stop using our digital assets and services. By using our services, you accept the terms of this privacy policy. Continued use of the Services constitutes your acceptance of this privacy policy and any changes thereto. In this privacy policy you will learn:

  • How we collect data;

  • What data we collect;

  • Why we collect this data;

  • Who we share the data with;

  • Where the data is stored;

  • How long the data is stored;

  • How we protect the data;

  • About updates or changes to the privacy policy.

2. What data do we collect?

Below is an overview of the data we may collect:

 

  • Unidentified and non-identifiable information that you provide during the registration process or that is collected through the use of our Services ("non-personally identifiable information"). Non-personal data do not allow any conclusions as to whom it was collected from. Non-personally identifiable information that we collect consists primarily of technical and aggregate usage information.

  • Individually identifiable information, that is the data from which you can be identified or could be identified with reasonable effort ("personal data"). The personal data that we collect through our Services may include information requested from time to time, such as names, email addresses, addresses, phone numbers, IP addresses and more. If we combine personal data with non-personal data, we treat it as personal data for as long as it is combined.

3. How do we collect data?

Below are the main methods we use to collect data:

  • We collect data when you use our services. Therefore, when you visit our digital assets and use the Services, we may collect, record and store data about sessions and related information. 

  • We collect data and documents that you provide to us yourself, for example if you contact us directly via any communication channel.

  • We may collect information from third party sources as described below.

  • We collect information that you provide to us when you log into our Services through a third party such as Facebook or Google.

3.1. Cookies

Our website uses so-called "cookies". Cookies are small data packages. They are stored at your device either temporarily for the duration of a session (session cookies) or permanently (persistent cookies). Session cookies are automatically deleted after your visit. Persistent cookies remain stored on your device until you delete them or until they are automatically deleted by your web browser. In some cases, cookies from third-party companies can also be stored at your end device when you use our site (third-party cookies). These enable us or you to use certain services of the third-party company (e.g., cookies for processing payment services). Cookies have different functions. Numerous cookies are technically necessary because certain website functions would not work without them. Other cookies are used to evaluate user behavior or to display advertising. Cookies that are required to carry out the electronic communication process, to provide certain functions or to optimize the website (e.g., cookies for measuring web audience) are called the necessary cookies and are stored on the basis of Article 6 (1) (f) GDPR, unless another legal basis is specified. The website operator has a legitimate interest in the storage of necessary cookies for the technically error-free and optimized provision of its services. If you consented to the use of cookies, the processing of your data occurs on the basis of this consent (Art. 6 (1) (a) GDPR and § 25 (1) TTDSG); the consent can be revoked at any time. You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, reject cookies for certain cases or in general and activate the automatic deletion of cookies when the browser is closed. If cookies are deactivated, the functionality of this website may be restricted.

3.2. Server logfiles

We automatically collect and store information in so-called server logfiles, which your browser automatically transmits to us. These are: browser type and browser version, operating system, 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 Article 6 (1) (f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of his website - the server log files must be recorded for this purpose.

3.3. Inquiry form

If you send us inquiries via the inquiry form, your details from the inquiry form, including the contact details you provided there, will be stored by us for the purpose of processing the inquiry and in the event of follow-up questions. We do not pass on this data without your consent, except as provided by clause 4.5.1. of this privacy policy. This data is processed on the basis of Article 6 (1) (b) GDPR if your request is related to the fulfillment of a contract or is necessary to carry out pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of inquiries addressed to us (Art. 6 (1) (f) GDPR) or on your consent (Art. 6 (1) (a) GDPR); the consent can be revoked at any time. The data you enter in the contact form will be stored until you ask us to delete it, revoke your consent or the purpose for data storage no longer applies (e.g., after your request has been processed). Mandatory legal provisions remain unaffected.

3.4. Inquiry by email or phone

 

If you contact us by e-mail, telephone or fax, your inquiry including all resulting personal data (name, documents etc.) will be stored and processed by us for the purpose of processing your request. We do not pass on this data without your consent, except as provided by clause 4.5.1. of this privacy policy. This data is processed on the basis of Article 6 (1) (b) GDPR if your request is related to the fulfillment of a contract or is necessary to carry out pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of inquiries addressed to us (Art. 6 (1) (f) GDPR) or on your consent (Art. 6 (1) (a) GDPR); the consent can be revoked at any time. The data you sent to us via contact requests will be stored until you ask us to delete it, revoke your consent or the purpose for data storage no longer applies (e.g., after your request has been processed). Mandatory legal provisions remain unaffected.

4. Collection and processing of personal data.

4.1. Extent of processing of personal data

We only process the personal data of our users to the extent that this is necessary to provide a functional website content and services. Otherwise, the data is only collected for the purposes and to the extent described below. The processing of personal data of our users takes place regularly only with the consent of the user. An exception applies in such cases in which it is not possible to obtain prior consent for actual reasons and the processing of the data is permitted by statutory provisions.

 

4.2. Legal basis for processing personal data


4.2.1. If we obtain the consent for the processing of personal data, Article 6 (1) (a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis.

4.2.2. Article 6 (1) (b) GDPR serves as the legal basis for the processing of personal data required to fulfill contracts our users. This also applies to processing operations that are necessary to carry out pre-contractual measures.

4.2.3. If processing of personal data is necessary to fulfill a legal obligation of our company, Article 6 (1) (c) GDPR serves as the legal basis.

4.2.4. If vital interests of our users or another person require the processing of personal data, Article 6 (1) (d) GDPR serves as the legal basis.

4.2.5. If the processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and fundamental freedoms of the person concerned do not outweigh the first interest, Article 6 (1) (f) GDPR serves as the legal basis for the processing.

4.3. Storage period

Unless a specific storage period has been specified in this privacy policy, your personal data will be stored until the purpose for data processing no longer exists. Please note that we retain the information we collect for as long as is necessary to provide our services, comply with our legal and contractual obligations to you, resolve disputes and enforce our agreements. We can correct, complete or delete incorrect or incomplete data at any time at our own discretion. If you claim a legitimate 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., tax or commercial law retention periods); in the latter case, the data will be deleted once these reasons have ceased to exist.

4.4. We may use your data for the following purposes:

4.4.1. Provision of the website and creation of log files

Each time our website is accessed, our system automatically collects data and information from the computer system of the accessing computer. The following data is collected here:

(1) Information about the browser type and version used;
(2) The user's operating system;
(3) The user's internet service provider;
(4) The IP address of the user;
(5) Date and time of access;
(6) Websites from which the user's system accesses our website;
(7) Websites accessed by the user's system through our website.

The data is also stored in the log files of our system. This data is not stored together with other personal data of the user. The legal basis for the temporary storage of the data and the log files is Article 6 (1) (f) GDPR.

4.4.2. Inquiry form, e-mail contact and other contact

There is an inquiry form on our website which can be used to contact us electronically. If a user takes advantage of this option or if the user contacts us via e-mail or in any other way, the data entered in the input mask or other data communicated will be transmitted to us and stored.
This data may include:

(1) First and last name​;
(2) Company name;
(3) Phone number;
(4) E-mail address;
(5) Billing address;

(6) Tax number;
(7) User's message and/or communication history including any attached files and documents and previous requests.

The legal basis for processing the data is Article 6 (1) (a) GDPR if the user has given their consent. The legal basis for the processing of data transmitted in the course of sending an email is Article 6 (1) Letter f GDPR. If the e-mail contact is aimed at concluding a contract, the additional legal basis for the processing is Art. 6 (1) (b) GDPR.​

4.5. How do we share your personal data:

We may share your personal data with service providers and third parties (or otherwise provide them with access to the data), but only in the following ways and in the following cases:

4.5.1. Processing and translation of data and documents

The data transmitted as part of inquiries and translation orders are stored by us and handed over to the translator for processing. We reserve the right to employ freelance translators from both the EU and non-EU countries unless expressly agreed otherwise.

The legal basis for processing the documents you have sent for translation is Article 6(1) (b) GDPR.

4.5.2. Hosting and technical support

We may share your data with our service providers in order to operate our services (e.g., storing data via third-party hosting services, providing technical support, etc.).

4.5.3. Miscellaneous

We may also disclose your data under the following circumstances: (i) to investigate, detect, prevent or address unlawful activity or other wrongdoing; (ii) to establish or exercise our rights of defense; (iii) to protect our rights, property or personal safety, or the safety of our users or the public; (iv) in the event of a change of control of our company or any of our affiliated companies (by way of a merger, acquisition or purchase of (substantially) all assets, etc.); (v) to collect, hold and/or manage your data using authorized third party service providers (e.g. cloud service providers) as appropriate for business purposes; (vi) to work collaboratively with third parties to improve your user experience. To avoid misunderstandings, we would like to point out that we can transfer or pass on non-personal data to third parties or use them in any other way at our own discretion.

5. Cookies and similar Technologies

When you visit or access our Services, we authorize third parties to use web beacons, cookies, pixel tags, scripts, and other technologies and analytics services ("Tracking technologies"). These Tracking technologies may enable third parties to collect your information automatically in order to improve the browsing experience on our digital assets, to optimize their performance and to ensure a customized user experience, as well as for security and fraud prevention purposes.

We may provide advertising, which may also be tailored to you, through our Services and our digital assets (including websites and applications that use our Services), such as: ads based on your recent browsing behavior on websites, devices or browsers.

In order to provide these advertisements to you, we may use cookies and/or JavaScript and/or web beacons (including clear GIFs) and/or HTML5 local storage and/or other technologies. We may also use third parties' services such as network advertisers (i.e., third parties who serve ads based on your website visits) to serve targeted ads. Third-party ad network providers, advertisers, sponsors and/or website traffic measurement services may also use cookies and/or JavaScript and/or web beacons (including clear GIFs) and/or Flash cookies and/or other technologies to improve effectiveness measure your ads and customize ad content for you. These third-party cookies and other technologies are governed by the specific privacy policy of the third party and not this one.

6. Third party websites, social media and Messengers

6.1. Third party websites

Our Services may contain links to other websites or services. We are not responsible for the privacy practices of those websites or services. We encourage you to be aware when you leave our Services and to read the privacy statements of each individual website and service you visit before providing your personal information. This Privacy Policy does not apply to such linked third-party websites and services.

6.2. WhatsApp

We offer our customers the opportunity to contact us via the WhatsApp messenger service. Its functions are offered by WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

If you contact us via the WhatsApp messenger service, you will automatically send us your mobile number and other data, e.g., content data that you send us as messages via WhatsApp and meta data of the messenger service.

The messenger provider is responsible for data processing by WhatsApp. We would like to point out that WhatsApp also stores user data in third countries outside the EU when using the broadcast and exchanges it with other services of the provider. We have no influence on this. The terms of use and data protection notices of WhatsApp apply:

https://www.whatsapp.com/legal

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here:

https://www.whatsapp.com/legal/business-data-transfer-addendum-20210927

For more information, see WhatsApp's privacy policy:

https://www.whatsapp.com/privacy

6.3. Telegram

We offer our customers the opportunity to contact us via the Telegram messenger service. Its functions are offered by Telegram Messenger LLP, 71-75 Shelton Street, Covent Garden, London, Great Britain.

If you contact us via the Telegram messenger service, you will automatically send us your mobile number and other data, e.g., content data that you send us as messages via Telegram and meta data of the messenger service.

The messenger provider is responsible for data processing by Telegram. We would like to point out that Telegram also stores user data in third countries outside the EU when using the broadcast and exchanges it with other services of the provider. We have no influence on this. The terms of use, data protection notices of Telegram and further information is to be found here:

https://www.telegram.org/privacy

7. Plugins und Tools

7.1. Google Maps

This site uses the map service Google Maps. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

In order to use the functions of Google Maps, it is necessary to save your IP address. This information is usually transmitted to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer. If Google Maps is activated, Google can use Google Fonts for the purpose of uniform display of fonts. When you call up Google Maps, your browser loads the required web fonts into your browser cache in order to display text and fonts correctly.

Google Maps is used in the interest of an effective presentation of our online offers and to make it easier to find the places we have indicated on the website. This represents a legitimate interest within the meaning of Article 6 (1) (f) GDPR. If a corresponding consent has been requested, the processing takes place exclusively on the basis of Article 6 (1) (a) GDPR and Article 25 (1) TTDSG, insofar as the consent includes the storage of cookies or access to information in the user's device (e.g., device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.

 

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here:

https://privacy.google.com/businesses/gdprcontrollerterms/

https://privacy.google.com/businesses/gdprcontrollerterms/sccs/

More information on handling users' data can be found in Google's privacy policy:

https://policies.google.com/privacy

8. Where do we store the data? (Hosting)

We host the content of our website with the following provider: Wix.com Ltd., 40 Namal Tel Aviv St., Tel Aviv 6350671, Israel (hereinafter „WIX“).

 

WIX is a tool for creating and hosting websites. When you visit our website, WIX analyzes user behavior, visitor sources, website visitor regions and visitor numbers. WIX stores cookies on your browser that are required to display the website and to ensure security (necessary cookies). The data collected via WIX may be stored on various servers around the world. The WIX servers are available i.a. in the USA. Details can be found in the WIX data protection declaration:

https://wix.com/about/privacy

 

According to WIX, data transfer to the USA and other third countries is based on the standard contractual clauses of the EU Commission or comparable guarantees under Art. 46 GDPR. Details can be found here:

https://wix.com/about/privacy-dpa-users

WIX is used on the basis of Article 6 (1) (f) GDPR. We have a legitimate interest in our website being displayed as reliably as possible. If a corresponding consent was requested, the processing takes place exclusively on the basis of Art. 6 (1) (a) DSGVO and § 25 (1) TTDSG. The consent can be revoked at any time.

9. How do we protect the data?

The hosting service of our digital assets provides us with the online platform through which we can offer our services to you. Your data may be stored through our hosting provider's data storage, databases and general applications. The data is stored on secure servers behind a firewall, and secure HTTPS access is offered for most of hosting services.

Notwithstanding the measures and efforts taken by us and our hosting provider, we cannot and do not guarantee the absolute privacy or security of any information you upload, post or otherwise disclose to us or others.

For this reason, we would like to ask you to set strong passwords and, if possible, not to transmit to us or others confidential information, the disclosure of which you believe could cause serious or lasting harm to you. In addition, since email and instant messaging are not considered secure forms of communication, we ask that you do not share any confidential information through any of these communication channels.

10. Your rights

We will only use your personal data for the purposes set out in the Privacy Policy and only when we are sure that:

  • the use of your personal data is necessary to provide you a service or to conclude a contract with you;

  • the use of your personal data is necessary to comply with a relevant legal or regulatory obligation, or

  • the use of your personal data is necessary to support our legitimate business interests (provided that we do so at all times in a way that is proportionate and respects your privacy rights).

You have the right to:

  • request confirmation as to whether or not your personal data is being processed and request access to your stored personal data and certain additional information;

  • request to receive personal data that you have provided to us in a structured, commonly used and machine-readable format;

  • request rectification of your personal data held by us;

  • request erasure of your personal data;

  • object to our processing of your personal data;

  • request the restriction of the processing of your personal data, or

  • lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. If you have general questions about the personal information we collect and how we use it, please contact us as provided below.

In the course of providing the Services, we may transfer information across borders to affiliates or other third parties and from your country/jurisdiction to other countries/jurisdictions around the world. By using the Services, you consent to the transfer of your information outside of the EU.

If you are a resident of the EU, your personal data will only be transferred to locations outside the EU where we are satisfied that an adequate or comparable level of protection of personal data is in place. We will take appropriate steps to ensure that we have appropriate contractual arrangements in place with our third parties to ensure that appropriate safeguards are in place to minimize the risk of unlawful use, alteration, destruction, loss or theft of your personal information and that such third parties will act in accordance with applicable laws at all times.

Revocation of your consent to data processing

 

Many data processing operations are only possible with your express consent. You can revoke consent that you have already given at any time. The legality of the data processing that took place up until the revocation remains unaffected by the revocation.

 

Right to object to data collection in special cases and to direct advertising (Art. 21 GDPR)

 

If the data processing is based on art. 6 (1) (e) or f GDPR, you have the right at any time to object to the processing of your personal data for reasons that arise 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 affected personal data unless we can demonstrate compelling legitimate grounds for processing that outweigh your interests, rights and freedoms or the processing serves to assert, exercise or defend legal claims (Objection according to Art. 21 (1) GDPR). If your personal data is processed in order to operate direct advertising, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct advertising. If you object, your personal data will then no longer be used for direct marketing purposes (objection according to Art. 21 (2) GDPR).

Right of appeal to the supervisory authority

 

In the event of violations of the GDPR, those affected 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 is 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, to be 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 be done to the extent that it is technically feasible.

Right to information, erasure and correction of data

Within the framework of the applicable legal provisions, you have the right to receive free information about your stored personal data, its origin and recipient and the purpose of the data processing and, if necessary, a right to correction or erasure of this data at any time. You can contact us at any time if you have any further questions on the subject of personal data.

 

Right to restriction of processing of data

You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this. The right to restriction of processing exists in the following cases:

  • the use of your personal data is necessary to fulfill or enter into a contract (e.g., to provide you with the Services themselves or to provide customer or technical support);

  • the use of your personal data is necessary to comply with a relevant legal or regulatory obligation, or

  • the use of your personal data is necessary to support our legitimate business interests (provided that we do so at all times in a way that is proportionate and respects your privacy rights).

  • If you dispute the accuracy of your personal data stored by us, we usually need time to check this. For the duration of the examination, you have the right to request that the processing of your personal data be restricted.

  • If the processing of your personal data happened / is happening unlawfully, you can request the restriction of data processing instead of erasure.

  • If we no longer need your personal data, but you need it to exercise, defend or assert legal claims, you have the right to demand that the processing of your personal data be restricted instead of data being erased.

  • If you have lodged an objection in accordance with Art. 21 (1) GDPR, your interests and ours must be weighed up. As long as it has not yet been determined whose interests prevail, you have the right to demand the processing of your personal data to be restricted.

If you have restricted the processing of your personal data, this data - apart from its storage - may only be used with your consent or to assert, exercise or defend legal claims or to protect the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.

11. Updates or changes to the Privacy Policy

We may, in our sole discretion, revise this Privacy Policy from time to time, the version posted on the Website will always be current (see “As of Date” statement). We encourage you to periodically review this Privacy Policy for changes. If there are any significant changes, we will post a notice on our website. Your continued use of the Services after notification of changes has been posted to our website constitutes your acknowledgment and acceptance of the changes to the Privacy Policy and your agreement to be bound by the terms of those changes.

12. Contacts

The responsible entity and the controller according to the General Data Protection Regulation and other national data protection laws of the member states as well as other data protection regulations is:
Vitalii Galinskii
Teutonenstr. 48
65187 Wiesbaden
Germany

Tel.: +49 611 16861631
E-Mail: info@alleskl.ar

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