Privacy policy

Thank you for visiting our website and using our Services. UP42 respects Your privacy and is committed to transparent privacy practices. This Privacy Policy explains how UP42 GmbH (collectively “UP42“, or “we“, or “us“, or “our“) collects, uses and shares Your Personal Data in connection with Your use of our website www.up42.com and our Services and explains Your choices for how we handle Your Personal Data. For convenience, the website and our services are collectively also referred to as the “Service.”

This Privacy Policy provides information on how we collect, store, process, use and protect Your Personal Data. It explains in particular what information we collect and why we collect it, how we use that information and Your rights in relation to the information provided. For the purpose of this Privacy Policy, "Personal Data" means any information relating to an identified or identifiable natural person; 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 or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

1. Controller and data protection officer

The controller who is responsible for the data processing according to the terms of the EU General Data Protection Regulation (hereinafter referred as GDPR) is:

UP42 GmbH
Ohlauer Strasse 43
10999 Berlin 

Email:		[email protected]

If You have any questions regarding the processing of Your Personal Data, please do not hesitate to contact us. You are also welcome to direct Your data protection concerns to our data protection officer by sending an email to the above mentioned email address. Please note that not only our data protection officer will get your request. If you wish to contact solely our data protection officer and/ or if you wish to send confidential information, please refer in your email to the data protection officer and please ask for contacting you.

We also have appointed an external Data Protection Officer (DPO):

ISICO Datenschutz GmbH,
Am Hamburger Bahnhof 4,
10557 Berlin.

2. Our Commitments regarding your Personal data

We undertake to comply with the regulations applicable to all processing of personal data that we implement, in particular the provisions of the General Data Protection Regulation (EU Regulation 2016/679) or "GDPR".

In particular, we are committed to the following principles:

Your personal data is processed lawfully, fairly and transparently (lawfulness, fairness, transparency).
Your personal data is collected for specific, explicit and legitimate purposes, and is not further processed in a manner incompatible with these purposes (purpose limitation).
Your personal data is collected in an adequate and relevant manner and is limited to the purposes for which it is processed (data minimisation).
Your personal data is accurate, kept up to date and every reasonable step is taken to ensure that inaccurate data, having regard to the purposes for which it is processed, is deleted or updated (accuracy).

We are committed to implementing the appropriate internal procedures in order to raise the awareness of all our employees and to ensure compliance with these rules within our organisation.

3. What data do we collect?

We collect Your Personal Data in order to provide and continually improve our products and services. In general, we may collect information that identifies you, information about how you use our Service, and the information that you create while you interact with our Service.

Personal Data that we collect from You may include the following:

inventory data, such as e.g. names, addresses
contact data, such as e.g. email addresses, phone numbers
content data, such as e.g. text entries, photographs, videos
usage data, such as e.g. web sites visited, particularly interesting content, date and time of access (“time stamp”)
meta-data/communications data, such as e.g. information about equipment, IP addresses
Job applicant details, such as e.g. name, postal and contact addresses and the documents pertaining to the application and the information contained therein, such as cover letter, curriculum vitae, certificates, etc., as well as other information on the person or qualifications of applicants provided with regard to a specific job or voluntarily by applicants.

4. How do we collect your data?

UP42 may directly collect Your Personal Data You provide us, when You:

Use or view our Website via your browser’s cookies;
Fill in contact form or send us an email;
Register for our login area and Set up an Account in order to use our website’s full range of functions;
Subscribe to our newsletter in which we inform You about current products and services;
Apply for a position via our applicant management system;
Complete a customer survey or provide feedback on any of our contact forms or via email;
Complete transactions through our Website, such as fulfilling an order for our Service;
Perform search queries on our Websites;
Request assistance from our Support team;
Register for or attend our Marketing events;

During each of your interactions with us, we collect information about Your connection and Your browsing. Different technologies can be used to collect those data. We refer to them generically as a "cookie". For more explanation, please refer to our cookies policy.

5. How will we process Your Personal Data?

By using the Website, our Service or subscribing to our marketing communications, UP42 will collect and process your Personal Data for the following purposes (hereinafter referred as: the ‘Purposes’):

Promotion of our Products/Services and Brand (i.e. newsletters, testimonials, email marketing campaigns, location-based marketing, digital marketing campaigns, response to enquiries, events, webinars, public relations activities etc)
Consumer Profiling (non-automated, track online behavior, marketing analytics, user feedback, track website usage etc)

Prospects Generation (Gather data about potential leads from individuals, gather data about potential leads from public sources, nurture and manage the relationship etc)

→ The legal basis of the above processing is Your consent pursuant to Art. 6(1)(a) GDPR.

Access to our Service
Sending you informational messages about our Service
Onboarding & Maintenance Emails (i.e You will automatically receive, after You finalized the sign-up and creation of Your UP42 Account, "Learn & Improve" emails that may include Product onboarding tips, Products and Services updates to help You to access and use the Platform in order to meet Your needs. Such emails are part of the contract You concluded with UP42)
Enforcement of our rights and obligations that arise from the contract entered into between You and Us, including for billing and collection
Notification about Your account and/or subscription, including expiration and renewal notices
IT Services (Provide and manage electronic communication interfaces e.g. API, provide IT support, test products, systems and applications, manage software and applications)

Customer Support (i.e. Manage user accounts, verify identity)

→ The legal basis for this data processing is the performance of contractual obligation, pursuant to Art. 6(1) (b) GDPR.

Interaction with Us through the usage of sign-up forms and questionnaires. Those will help Us to provide better services to You;
Manage Customer Profitability (manage customer profiles, plan and forecast sales, track conversion actions etc)
Research and Development (i.e. track product performance, deploy bug fixes, offer online products/services etc)
To protect us and others. Where We believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of policies, terms, and other policies.
To perform customer survey and improve our products and services. We research general trends in the use of our services as well as on the behavioural trends and preferences of our customers. We use the results of our survey to develop better services and offers for our customers, provide better customer service and improve the design and content of our websites.

→ Legal basis for the processing is our legitimate and shared interest to provide services to You, pursuant to Art. 6 (1) (f) GDPR

Legal compliance. We use Your Personal Data to comply with applicable legal obligations, including responding to an authority or court order or discovery request.
Recruitment : through our applicant management system

We will use Your Personal Data for the above Purposes, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose (for preserving particular evidence under the applicable Data Protection Laws and Regulations, or in the context of legal statutes of limitation for example). If we need to use Your Personal Data for an unrelated purpose, we will notify You prior to this further Personal Data processing and provide You the relevant privacy information notice.

6. What is the legal basis for processing Your Personal Data?

The EU GDPR requires a legal basis for our use of personal information. Our basis varies depending on the specific purpose for which we use Your Personal Data.

We use:

Your consent when we ask for Your consent to process Your Personal Data for a specific purpose that we communicate to You. When You consent to our processing Your Personal Data for a specified purpose, You may withdraw your consent at any time and we will stop processing of your data for that purpose. (Article 6 paragraph 1 lit. a and Article 7 GDPR)
Performance of a contract when we provide You with Services, or communicate with You about them. This includes when we use Your Personal data to take and handle orders, deliver products and Services, send You "Learn & Improve" emails that may include Product onboarding tips, Products and Services updates to help You to access and use the Platform in order to meet Your needs or even process payments. (Article 6 para. 1 lit. b GDPR)
Our legitimate business interests and the interests of our customers when we improve our Services, when we detect and prevent fraud and abuse in order to protect the security of our customers, ourselves, or others, and when we provide You with interest-based advertising. (Article 6 para. 1 lit. f GDPR)
Compliance with a legal obligation when we use our Personal Data to comply with laws. (Article 6 para. 1 lit. c GDPR)
Selection of applicants for the possible establishment of an employment relationship : Art. 6 (1) Sentence 1(b), 88 GDPR, Section 26 (1) Sentence 1, (4) BDSG

7. How do we store Your Personal data and for how long?

UP42 uses technical and organisational security measures in order to protect the Personal Data we have under our control against accidental or intentional manipulation, loss, destruction and against access by unauthorised persons. Our security procedures are continually enhanced as new technology becomes available.

We will delete Your Personal Data when the purpose of the processing has been achieved unless further statutory retention periods exist, e. g. we still need Your Personal Data to fulfil contractual or legal obligations (accounting, tax reasons, etc.).

Even after the service has been provided or after termination of the contract, it may be necessary to continue to store personal data in order to comply with contractual or legal obligations.

8. Who might receive Your Personal Data?

In the context of our processing of Your Personal Data, it may happen that the data is transferred to other places, companies or persons or that it is disclosed to them.

We only transfer Your Personal Data to third parties if there is an appropriate legal basis for doing so, in particular if:

You have given your explicit consent to this in accordance with Art. 6 (1) sentence 1 lit. a GDPR
This is necessary for the performance of the contract with You in accordance with Art. 6 (1) sentence 1 lit. b GDPR
There is a legal obligation for the disclosure pursuant to Art. 6 (1) sentence 1 lit. c GDPR
The transfer is necessary in accordance with Art. 6 para. 1 p. 1 lit. f GDPR for the purposes of legitimate interests, as well as for the establishment, exercise or defence of legal claims and there is no reason to assume that you have an overriding legitimate interest to not transfer your data.
External service providers process data on our behalf pursuant to Art. 28 GDPR.

Recipients of your Personal Data may include, for example, data centres that store our website and databases, IT service providers that maintain our systems or provide CRM functionalities and consulting firms, payment service provider within the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are embedded in a website. If we pass data on to our service providers, they may use the data exclusively for the fulfilment of their tasks. We have carefully selected and commissioned the service providers.

In such a case, the legal requirements will be respected and in particular corresponding contracts or agreements, which serve the protection of your data, will be concluded with the recipients of your data.

We use the rating service of Checkmarket developed by Medallia, Inc., SUITE 1850, 575, MARKET STREET, SAN FRANCISCO, CA 94105, USA ( “Checkmarket”). Checkmarket will provide distribution, reporting and analysis of emails and surveys.

This enables us to receive feedback from you in order to be able to improve our offer or our services or to design it according to customer wishes. After placing an order, you will receive an e-mail from Checkmarket with a link which, when clicked, will take you to dedicated website. There you can then submit a rating. The submission of a rating is of course voluntary. Details regarding the data collection by Checkmarket on their platform can be found in the corresponding privacy policy.

9. Data transfer to third countries

We would like to inform you that the EU-US Privacy Shield (adequacy decision) has been declared invalid and that in case of data transfers to insecure third countries (here: USA), there is no adequate level of data protection according to EU standards. In particular, there is a risk that your data may be processed by U.S. authorities, for control and for monitoring purposes, possibly also without any legal remedy. In the case of data processing in the context of the use of analysis tools, the data processing is based on your consent which you can revoke at any time with effect for the future, Art. 49 paragraph 1 lit. a GDPR. Furthermore, we concluded with service providers which are based in third countries either a data processing agreement according to Art. 28 GDPR or a joint controllership according to Art. 26 GDPR as well as standard contractual clauses, depending on the contractual constellation.

10. Analytics Tools

In order to improve our website, we use tools for the statistical recording and analysis of general usage behavior on the basis of access data ("analysis tools"). We also use analysis services to evaluate the use of our various marketing channels. Unless otherwise stated, the legal basis for the analysis tools is your consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR. In the event that personal data is transferred to the USA or other third countries, your consent expressly extends to the transfer of data (Art. 49 pararaph 1 sentence 1 lit.a GDPR). The associated risks can be found in section 5 (“Data transfer to third countries”).

1. Google Analytics Our website uses Google Analytics, which is offered to their customers from Europe, the Middle East and Africa (EMEA) by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics uses cookies and similar technologies to analyse and improve our website based on Your user behavior. Google will process the information obtained in order to evaluate Your use of the website, to compile reports on website activity for website operators and to provide other services related to website activity and internet usage. The data generated in this context can be transmitted by Google to a server in the USA for evaluation and stored there.

We have made the following settings for data protection with Google Analytics:

IP anonymization (shortening of the IP address before evaluation, so that no conclusions can be drawn about your identity)
Automatic deletion of old logs / limitation of the storage period
EnabledDisabled advertising feature (including audience remarketing by GA Audience)
Enabled personalized ads
Enabled Measurement Protocol
Enabled cross-page tracking (Google signals)
Enabled data sharing with other Google products and services

The following data is processed by Google Analytics:

Anonymized IP address;
Referrer URL (previously visited page);
Pages accessed (date, time, URL, title, length of stay);
Downloaded files;
Clicked links to other websites;
if necessary, achievement of certain goals (conversions);

Technical information: Operating system; browser type, version and language; device type, make, model and resolution; Approximate location (country and, if applicable, city, based on anonymized IP address).

Google Analytics sets the following cookies for the specified purpose with the respective storage period:

"ga" for 2 years and "_gid" for 24 hours (both to identify and distinguish website visitors by a user ID);
"gat" for 1 minute (to reduce requests to Google's servers);
if applicable, "IDE" for 13 months (third-party cookie for the recognition and differentiation of website visitors by a user ID, for recording the interaction with advertising and in the context of the display of personalized advertising).
"utma" for 2 years (to distinguish between visitors and users?meetings);
"utmb" for 30 minutes (to determine new sessions and the duration of visits);
"utmc" for a session (to determine new sessions and the duration of visits);
"utmt" for 10 minutes (to throttle requests);
"utmz" for 6 months (to store the campaign or the source from which the visitor came);
if applicable, "utmv" for 2 years (to store a user-defined variable).

We have concluded a data processing agreement with Google for the use of Google Analytics as well as standard contractual clauses in the event that personal data is transferred to the USA or other third countries.

Please see also for detailed information Google's privacy policy.

2. Hotjar Our website uses Hotjar, a web analytics service provided by Hotjar Ltd., Elia Zammit Street 3, St Julians STJ 1000, Malta ("Hotjar"). Hotjar is used to create so-called heat maps. Heat maps graphically display statistics about mouse movements and clicks on our site in order to analyse our website with regard to your user behavior. This allows us to recognize frequently used functions of our website and to further improve the page. However, your IP address will be shortened before the usage statistics are evaluated, so that no conclusions can be drawn about your identity. In addition to mouse movements and clicks, information about the operating system, browser, incoming and outgoing references (links), geographical origin as well as resolution and type of device are evaluated for statistical purposes. This information is pseudonymous and will not be passed on to third parties by us or by Hotjar. Data entered by you on form fields on our website will be hidden and not collected using Hotjar.

The following cookies are set and read by Hotjar:

"hjid" for 1 year (usage analysis and storage of the visitor ID);
"hjFirstSeen" for the session (storage of the first page view in a session of a new visitor);
"hjAbsoluteSessionInProgress" for 30 minutes (storage of the first page view in a session);
"hjIncludedInSessionSample" for 30 minutes (usage analysis in connection with the defined session limit);
"hjIncludedInPageviewSample" for 30 minutes (usage analysis in connection with the defined pageview limit).
The following information is set and read out by Hotjar in the local storage:
"hjid" (usage analysis and storage of the visitor ID).

Please see also for detailed information Hotjar's privacy policy.

11. Marketing Tools

We also use tools for advertising purposes ("marketing tools"). By analyzing and evaluating access data during the use of our website, we are able to present you with personalised advertising, i.e. those that meet your actual interests and needs on our website and on the websites of other providers.

The legal basis for the marketing tools is your consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR. In the event that personal data is transferred to the USA or other third countries, your consent expressly extends to the transfer of data (Art. 49 para. 1 sentence 1 lit. a GDPR). The associated risks can be found in section 5 ("Data transfer to third countries").

In the following section, we would like to explain these technologies and the providers used for them in more detail. The data collected may include, in particular:

The IP address of the device;
The identification number of a cookie or information in web storage;
The device identifier of mobile devices (e.B. Device ID);
Referrer URL (previously visited page);
Pages accessed (date, time, URL, title, length of stay);
Downloaded files;Clicked links to other websites;
If necessary, achievement of certain goals (conversions);
Technical information: Operating system; browser type, version and language; device type, make, model and resolution;
Approximate location (country and if applicable City).

However, the data collected is stored exclusively pseudonymously, so that no direct conclusions can be drawn about the persons.

1. Microsoft Advertising (formerly Bing Ads) Our website uses Microsoft Advertising, a service of Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA ("Microsoft"). Microsoft uses cookies and similar technologies to show you advertisements that are relevant to you. The use of these technologies allows Microsoft and its partner websites to display ads based on previous visits to our or other websites on the Internet. The data generated in this context may be transmitted by Microsoft to a server in the USA for evaluation and stored there.

In addition to withdrawing your consent, you also have the option of deactivating personalized ads in Microsoft Advertising or in the settings for ads in your Microsoft account.

The following cookies are set by Microsoft Advertising for the specified purpose with the respective storage period:

"uetsid" for 24 hours (session ID);
"uetvid" for 16 days (visitor recognition, usage analysis and display of personalized advertising);
"MUID" for 1 year (visitor recognition, usage analysis and display of personalized advertising).

The following information in local storage is stored by Microsoft Advertising:

"uetsid" and "uetvid" (the same purposes as the corresponding cookies);
"uetsid_exp" and "uetvid_exp" (information about the expiration date of cookies).

For more information, see the Microsoft Advertising Help pages and the Microsoft Privacy Statement.

2. Facebook pixel For marketing purposes, our websites use the service "Facebook pixel" of the social network Facebook, a service offered to users outside the USA and Canada by Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland and for all other users by Facebook Inc., 1601 Willow Road, Menlo Park, California 94025, USA (together "Facebook").

We use Facebook pixel to analyse the general use of our websites and to understand the effectiveness of Facebook advertising ("conversion tracking"). In addition, we use Facebook pixels to show you individualized advertising messages based on your interest in our products ("retargeting"). This also involves target group remarketing by Custom Audience. For this purpose, Facebook processes data that the service collects via cookies, web beacons and comparable storage technologies on our websites.

The following cookies are set by Facebook pixel for the specified purpose with the respective storage period:

"fbp" for 3 months (usage analysis and retargeting)
"fr".

The data generated in this context can be transmitted by Facebook to a server in the USA for evaluation and stored there. In the event that personal data is transferred to the USA, we have entered into standard contractual clauses with Facebook.

If you are a member of Facebook and have allowed Facebook to do so via the privacy settings of your account, Facebook may also link the information collected about your visit to us to your member account and use it for the targeted placement of Facebook ads. You can view and change the privacy settings of your Facebook profile at any time. If you have not consented to the use of Facebook pixels, Facebook will only display general Facebook ads that are not selected on this website based on the information collected about you.

Further information can be found in Facebook's privacy policy.

3. Google Ads-Conversion-Tracking and Ads Remarketing (formerly AdWords) Our website uses the "Google Ads" service, which is offered to users from the European Economic Area and Switzerland by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland and for all other users of Google LLC 1600 Amphitheatre Parkway Mountain View, CA 94043, USA (together "Google").

With Google Ads, customer actions defined by us (such as clicking on an ad, page views, downloads) are recorded and analysed by means of "Google Ads-Conversion-Tracking". We use "Google Ads-Remarketing" to show you individualised advertising messages for our products on Google partner websites. Both services use cookies and similar technologies for this purpose.

The data generated in this context can be transmitted by Google to a server in the USA for evaluation and stored there. In the event that personal data is transferred to the USA, we have entered into standard contractual clauses with Google.

If you're using a Google Account, depending on the settings on file in your Google Account, Google may link your web and app browsing history to your Google Account and use information from your Google Account to personalise ads. If you do not want this assignment to your Google Account, it is necessary that you log out of Google before accessing our website.

If you have not consented to the use of Google Ads, Google will only display general advertisements that have not been selected on this website based on the information collected about you. In addition to revoking your consent, you also have the option of deactivating personalised advertising in the settings for advertising on Google.

The following cookies are set by Google:

"gcl_au" for 90 days
"gcl_aw" for 90 days

Further information can be found in Google's information on data use and privacy policy.

4. Google Marketing Platform and Ad Manager (formerly DoubleClic) Our website uses the Google Marketing Platform and the Google Ad Manager, services offered to users from the European Economic Area and Switzerland by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland and for all other users by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (together "Google").

These services use cookies and similar technologies to present you with advertisements that are relevant to you. The use of the services allows Google and its partner websites to serve ads based on previous visits to our or other websites on the Internet.

If you have not consented to the use of Google Marketing Platform and Ad Manager, Google will only display general advertisements that have not been selected on this website based on the information collected about you. In addition to revoking your consent, you also have the option of deactivating personalised advertising in the settings for advertising on Google.

In particular, Google sets the following cookies for the stated purpose with the respective storage period:

"IDE" for 13 months (third-party cookie to recognize and distinguish website visitors by a user ID, to record interaction with advertising and in the context of displaying personalized advertising);
"1P_JAR" for 1 month (optimization of personalized advertising, avoidance of repeated display of the same advertisement);
"DV" for 5 minutes (user preferences, such as language);
"NID" for 6 months (settings for Google services and other functions for advertising purposes).

Further information can be found in Google's privacy policy.

12. Cookies

This website uses cookies and similar technologies (collectively, "Tools") offered either by us or by third parties.

A cookie is a small text file that is stored by the browser on your device. Cookies are not used to run programs or load viruses onto your computer. Comparable technologies are in particular web storage (local / session storage), fingerprints, tags or pixels. If you reject cookies or similar technologies, not all of our offers may work smoothly for you.

In the following, the tools we use are listed by category, whereby we inform you in particular about the providers of the tools, the storage period of the cookies and the transfer of data to third parties.

(if you are not seeing the list, please check the website settings in your browser to allow for pop-ups and embedded scripts to load. See on Chrome, Firefox, Safari, Brave and Edge).

13. Storage duration

In general, we store personal data only as long as necessary to fulfill the purposes for which we collected the data. Thereafter, we delete the data immediately, unless we still need the data until the expiry of the statutory limitation period for evidence purposes, for claims under civil law or due to statutory retention obligations.

For evidentiary purposes, we store contractual data for three years from the end of the year in which the business relationship with you ends.
We may still need to store some of your data for accounting reasons based on a legal obligation (German Commercial Code, the German Fiscal Code) The periods specified there for the retention of documents are two to ten years.

14. Hyperlinks

Our website contains so-called hyperlinks to websites of other providers. If these hyperlinks are activated, you will be redirected from our website directly to the website of the other providers. You can recognize this, among other things, by changing the URL. We cannot accept any responsibility for the confidential handling of your data on these third-party websites, as we have no influence on the fact that these companies comply with the data protection regulations. Please inform yourself about the handling of your personal data by these companies directly on these websites.

15. Your Rights

As data subjects you are entitled to the following rights according to Art. 15 – 21, 77 GDPR which you can address to the above-mentioned contact details:

The Right of access by the data subject (Art. 15 GDPR)
Right to rectification (Art. 16 GDPR)
Right to erasure (“right to be forgotten, Art. 17 GDPR)
Right to restriction of processing (Art. 18 GDPR)
Right to data portability (Art. 20 GDPR)
Right to object (Art. 21 GDPR)
Right to lodge a complaint with a supervisory authority (Art. 77 GDPR).

In case the data processing is based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. In case the data processing is based on our legitimate interest (Art. 6 paragraph 1 sentence 1 lit. f GDPR), you have the right to object, on grounds relating to your situation, at any time. Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.

Your requests for the assertion of data protection rights and our answers to them will be kept for documentation purposes for a period of up to three years and, in individual cases, for the establishment, exercise or defence of legal claims even beyond. The legal basis is Art. 6 paragraph 1 sentence 1 lit. f GDPR, based on our legitimate interest in defending against any civil law claims pursuant to Art. 82 GDPR, the avoidance of fines pursuant to Art. 83 GDPR and the fulfillment of our accountability under Art. 5 para. 2 GDPR.

As a data subject you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR-regulations.

16. Modification of the Privacy Policy

We reserve the right to change this Privacy Policy in accordance with the data protection regulations. The current version can be found here at this point or another place on our website or app that can easily be found. If we intend to process your data for other purposes than those for which it was collected, we will inform you in advance in accordance with the law.

Last amended: July, 13, 2023