This data privacy policy clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online offering and the associated websites, functions and our mobile app. With regard to the terms used, such as "processing" or "person responsible", we refer you to the definitions in Art. 4 of the Data Protection Basic Regulation (DSGVO).

 

Responsible
Crumb UG (haftungsbeschränkt)

c/o Next Commerce Accelerator

Am Sandtorkai 27

20457 Hamburg

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Managing directors: Saad Saeed, Stefan Schablowski, Nikolas Bullwinkel 
phone: +491736192974 
Email: info@crumbup.com

Registered at Hamburg Local Court 
Commercial register: HRB 157810 
 

 

TYPES OF DATA PROCESSED
- Inventory data (for example, names, addresses).
- Contact data (e.g., e-mail, telephone numbers).
- Usage data (e.g. preferences, access times).
- Meta/communication data (e.g., device information, IP addresses).

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CATEGORIES OF AFFECTED PERSONS
Visitors and users of the online offer (hereinafter referred to collectively as "users").

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PURPOSE OF PROCESSING
- Answer contact requests and communicate with users.
- Security measures.
- Marketing

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NEWSLETTER
Our newsletter is sent randomly about 2 times a month. You can unsubscribe at any time. 
We will use your data for: 
- Conversion measurement
- Use for a shipping service provider 
- Logging in

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USED TERMS
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter "data subject"); a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier (e.g. a cookie) or to one or more specific characteristics which express the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, is regarded as identifiable.
"Processing" means any operation carried out with or without the aid of automated processes, or set of operations, involving personal data. The term is broad and covers practically every handling of data.
"Pseudonymisation" means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the provision of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures ensuring that the personal data are not attributed to an identified or identifiable natural person.
"Profiling" means any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to the work performance, economic situation, health, personal preferences, interests, reliability, conduct, whereabouts or movements of that natural person.
The "controller" is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
"processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

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RELEVANT LEGAL BASES
In accordance with Art. 13 DSGVO we inform you about the legal basis of our data processing. If the legal basis is not mentioned in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 DSGVO, the legal basis for processing in order to fulfil our services and carry out contractual measures as well as answer inquiries is Art. 6 para. 1 lit. b DSGVO, the legal basis for processing in order to fulfil our legal obligations is Art. 6 para. 1 lit. c DSGVO, and the legal basis for processing in order to safeguard our legitimate interests is Art. 6 para. 1 lit. f DSGVO. In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 para. 1 lit. d DSGVO serves as the legal basis.

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SECURITY MEASURES
In accordance with Art. 32 DSGVO, we take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk, taking into account the situation, the implementation costs and the nature, extent, circumstances and purposes of the processing as well as the different probability of occurrence and severity of the risk to the rights and freedoms of natural persons.
Such measures shall include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to, inputting, disclosure, securing and separation of data. In addition, we have established procedures to ensure the exercise of data subjects' rights, the deletion of data and the response to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and data protection-friendly default settings (Art. 25 DSGVO).

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COOPERATION WITH PROCESSORS OF ORDERS AND THIRD PARTIES
Insofar as we disclose data to other persons and companies (contract processors or third parties) within the scope of our processing, transfer them to them or otherwise grant them access to the data, this shall only take place on the basis of legal permission (e.g. if a transfer of the data to third parties, such as payment service providers, pursuant to Art. 6 Para. 1 lit. b DSGVO is necessary for the performance of the contract), if you have consented to this, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we commission third parties with the processing of data on the basis of a so-called "order processing contract", this is done on the basis of Art. 28 DSGVO.

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TRANSFERS TO THIRD COUNTRIES
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of the use of third-party services or disclosure or transfer of data to third parties, this will only occur if it is done to fulfil our (pre)contractual obligations, on the basis of your consent, a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or allow the data to be processed in a third country only if the special requirements of Art. 44 ff. of the German Data Protection Act are met. DSGVO. This means that the processing takes place, for example, on the basis of special guarantees, such as the officially recognised determination of a data protection level corresponding to the EU (e.g. for the USA by the "Privacy Shield") or compliance with officially recognised special contractual obligations (so-called "standard contractual clauses").

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RIGHTS OF THE PERSONS CONCERNED
You have the right to request confirmation as to whether the data in question will be processed and to be informed of this data and to receive further information and a copy of the data in accordance with Art. 15 DSGVO.
You have accordingly. In accordance with Art. 16 DSGVO, you have the right to request the completion of data concerning you or the rectification of incorrect data concerning you.
Pursuant to Art. 17 DSGVO, you have the right to demand that the data concerned be deleted immediately or, alternatively, to demand that the processing of the data be restricted pursuant to Art. 18 DSGVO.
You have the right to demand that the data concerning you which you have provided to us be received in accordance with Art. 20 DSGVO and that it be transferred to other responsible parties.
Pursuant to Art. 77 DSGVO, you also have the right to file a complaint with the competent supervisory authority.

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REVOKING RIGHT
You have the right to revoke consents granted pursuant to Art. 7 para. 3 DSGVO with effect for the future.

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RIGHT TO OBJECT
You may object at any time to the future processing of the data concerning you in accordance with Art. 21 DSGVO. In particular, you may object to the processing of your data for the purposes of direct marketing.

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COOKIES AND RIGHT TO OBJECT TO DIRECT ADVERTISING
"Cookies" are small files that are stored on the user's computer. Different data can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after the user's visit to an online service. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offer and closes his browser. The content of a shopping basket in an online shop or a login status, for example, can be stored in such a cookie. Cookies are referred to as "permanent" or "persistent" and remain stored even after the browser is closed. For example, the login status can be saved if users visit it after several days. The interests of the users who are used for range measurement or marketing purposes can also be stored in such a cookie. Third party cookies" are cookies that are offered by providers other than the person responsible for operating the online service (otherwise, if they are only the latter's cookies, they are referred to as "first party cookies").
We may use temporary and permanent cookies and explain this in our privacy policy.
If users do not wish cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of your browser. The exclusion of cookies can lead to functional restrictions of this online offer.
A general objection to the use of cookies for online marketing purposes can be raised for a large number of services, especially in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/ . In addition, cookies can be saved by deactivating them in the browser settings. Please note that in this case not all functions of this online offer can be used.

DELETION OF DATA
The data processed by us will be deleted or their processing restricted in accordance with Art. 17 and 18 DSGVO. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and there are no legal obligations to retain them. If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons.
According to legal requirements in Germany, data is stored for 10 years in accordance with §§ 147 para. 1 AO, 257 para. 1 nos. 1 and 4, para. 4 HGB (German Commercial Code) (books, records, management reports, accounting records, commercial books, documents relevant for taxation, etc.) and 6 years in accordance with § 257 para. 1 nos. 2 and 3, para. 4 HGB (German Commercial Code) (commercial letters).
In accordance with legal requirements in Austria, the documents are kept in particular for 7 years in accordance with § 132 para. 1 BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, list of income and expenses, etc.), for 22 years in connection with real estate and for 10 years for documents in connection with electronically provided services, telecommunications, radio and television services which are provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.

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AGENCY SERVICES
We process the data of our customers within the scope of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development / consulting or maintenance, implementation of campaigns and processes / handling, server administration, data analysis / consulting services and training services.
We process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of contract, term), payment data (e.g., bank details, payment history), usage and metadata (e.g., within the scope of evaluating and measuring the success of marketing measures). We do not process any special categories of personal data, unless they are part of a commissioned processing. Affected parties include our customers, interested parties and their customers, users, website visitors or employees as well as third parties. The purpose of the processing is the provision of contractual services, billing and our customer service.  The legal basis for the processing results from Art. 6 Para. 1 lit. b DSGVO (contractual services), Art. 6 Para. 1 lit. f DSGVO (analysis, statistics, optimisation, security measures). We process data which are necessary for the justification and fulfilment of the contractual services and point out the necessity of their specification. Disclosure to external parties shall only take place if it is necessary within the framework of an order. When processing the data provided to us within the framework of an order, we shall act in accordance with the instructions of the customer and the statutory requirements for order processing pursuant to Art. 28 DSGVO and shall not process the data for purposes other than those specified in the order.
We delete the data after the expiry of statutory warranty and comparable obligations. The necessity of storing the data is reviewed every three years; in the case of statutory archiving obligations, deletion takes place after their expiry (6 years, in accordance with § 257 para. 1 HGB, 10 years, in accordance with § 147 para. 1 AO). In the case of data which has been disclosed to us by the client within the scope of an order, we delete the data in accordance with the specifications of the order, in principle after the end of the order.

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CONTRACTUAL SERVICES
We process the data of our contractual partners and interested parties as well as other clients, customers, clients, clients or contractual partners (uniformly referred to as "contractual partners") in accordance with Art. 6 para. 1 lit. b. DSGVO in order to provide them with our contractual or pre-contractual services. The data processed, the type, scope and purpose and the necessity of their processing are determined by the underlying contractual relationship.
The processed data includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g. e-mail addresses and telephone numbers) as well as contract data (e.g., services used, contract contents, contractual communication, names of contact persons) and payment data (e.g., bank details, payment history).
We do not process any special categories of personal data, unless they are part of a commissioned or contractual processing.
We process data which are necessary for the justification and fulfilment of the contractual services and point out the necessity of their indication, if this is not evident for the contracting parties. Disclosure to external persons or companies will only take place if it is necessary within the framework of a contract. When processing the data provided to us within the framework of an order, we act in accordance with the instructions of the client and the legal requirements.
Within the scope of using our online services, we can save the IP address and the time of the respective user action. The storage takes place on the basis of our justified interests, as well as the interests of the users in the protection from abuse and other unauthorized use. A passing on of these data to third parties does not take place in principle, unless it is necessary for the pursuit of our claims according to art. 6 para. 1 lit. f. DSGVO is necessary or there is a legal obligation to do so pursuant to Art. 6 Para. 1 lit. c. DSGVO.
The data will be deleted when the data is no longer required for the fulfilment of contractual or statutory welfare obligations and for the handling of any warranty and comparable obligations, whereby the necessity of storing the data is reviewed every three years; otherwise the statutory storage obligations apply.

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ADMINISTRATION, FINANCIAL ACCOUNTING, OFFICE ORGANIZATION, CONTACT MANAGEMENT
We process data in the context of administrative tasks as well as the organisation of our business, financial accounting and compliance with legal obligations, such as archiving. Here we process the same data that we process within the scope of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. DSGVO, Art. 6 para. 1 lit. f. DSGVO. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks which serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of the data with regard to contractual services and contractual communication corresponds to the data specified in these processing activities.
We disclose or transmit data to the financial administration, consultants, such as tax consultants or auditors, as well as other fee offices and payment service providers.
Furthermore, on the basis of our business interests, we store information on suppliers, organisers and other business partners, e.g. for the purpose of establishing contact at a later date. This data, which is mainly company-related, is stored permanently.

 

CONTACT STORAGE
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the user's details are used to process the contact enquiry and to process it in accordance with Art. 6 Para. 1 lit. b. of the German Data Protection Act. (within the framework of contractual/pre-contractual relationships), Art. 6 Para. 1 lit. f. (other inquiries) DSGVO processed... The user data can be stored in a customer relationship management system ("CRM system") or comparable inquiry organization.
We delete the requests if they are no longer necessary. We check the necessity every two years; furthermore, the legal archiving obligations apply.

 

 

NEWSLETTER
With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures and your rights of objection. By subscribing to our newsletter, you declare your agreement with the receipt and the described procedures.
Content of the newsletter: We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter referred to as "newsletter") only with the consent of the recipient or legal permission. If the contents of the newsletter are specifically described within the scope of registration, they are decisive for the consent of the user. In addition, our newsletters contain information about our services and us.
Double-Opt-In and logging: The registration to our newsletter takes place in a so-called Double-Opt-In procedure. I.e. after registration you will receive an e-mail in which you will be asked to confirm your registration. This confirmation is necessary so that nobody can register with external e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address. Likewise the changes of your data stored with the forwarding party are logged.

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HOSTING AND E-MAIL DISPATCH
The hosting services used by us serve the provision of the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services which we use for the purpose of operating this online service.
Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors to this online service on the basis of our legitimate interests in the efficient and secure provision of this online service in accordance with Art. 6 Para. 1 lit. f DSGVO in connection with Art. 28 DSGVO (conclusion of an order processing contract).
 
COLLECTION OF ACCESS DATA AND LOGFILES
We, and/or our Hostinganbieter, raise on basis of our entitled interests in the sense of the art. 6 Abs. 1 lit. f. DSGVO collects data on each access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Log file information is stored for security reasons (e.g. to clarify abuse or fraud actions) for a maximum period of 7 days and then deleted. Data, the further storage of which is necessary for evidence purposes, are excluded from deletion until the respective incident has been finally clarified.

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GOOGLE ANALYTICS
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer in the sense of Art. 6 Para. 1 lit. f. of the German Civil Code), we act in accordance with the following principles DSGVO) Google Analytics, a web analysis service of Google LLC ("Google"). Google uses cookies. The information generated by the cookie about users' use of the website is generally transmitted to and stored by Google on servers in the United States.
Google is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online services by users, to compile reports on activities within this online service and to provide us with other services related to the use of this online service and the Internet. Pseudonymous user profiles can be created from the processed data.
We use Google Analytics only with activated IP anonymization. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and shortened there.
The IP address transmitted by the user's browser is not merged with other Google data. Users may refuse the use of cookies by selecting the appropriate settings on their browser, they may also refuse the use of cookies by selecting the appropriate settings on their browser, they may refuse the use of cookies by selecting the appropriate settings on their browser, and they may refuse the processing of cookies by selecting the appropriate settings on Google, and they may refuse the processing of cookies by selecting the appropriate settings on Google, and they may refuse the processing of cookies by Google, by downloading and installing the browser plugin available from the following link: http://tools.google.com/dlpage/gaoptout?hl=de .
Further information on the use of data by Google, setting and objection options can be found in Google's data protection declaration (https://policies.google.com/technologies/ads) and in the settings for the display of advertising by Google (https://adssettings.google.com/authenticated).
The personal data of the users will be deleted or anonymized after 14 months.

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GOOGLE UNIVERSAL ANALYTICS
We use Google Analytics in the form of "universal analytics". "Universal Analytics" refers to a Google Analytics procedure in which user analysis is performed on the basis of a pseudonymous user ID and a pseudonymous profile of the user is thus created with information from the use of various devices (so-called "cross-device tracking").

 

ONLINE PRESENCES IN SOCIAL MEDIA
We maintain online presences within social networks and platforms in order to be able to communicate with customers, interested parties and users active there and to inform them about our services. When calling up the respective networks and platforms, the terms and conditions and data processing guidelines of their respective operators apply.
Unless otherwise stated in our data protection declaration, we process the data of users who communicate with us within the social networks and platforms, e.g. write articles on our online presences or send us messages.

USING FACEBOOK PLUGINS
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer in the sense of Art. 6 Para. 1 lit. f. of the German Civil Code), we make use of the information provided on this website. DSGVO) Social Plugins ("Plugins") of the social network facebook.com, which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"). 
This may include, for example, content such as images, videos or text and buttons with which users can share content from this online service within Facebook. The list and appearance of the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/.

Facebook is certified under the Privacy Shield Agreement and thus offers a guarantee of compliance with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

When a user calls a function of this online service that contains such a plugin, his device establishes a direct connection with Facebook's servers. The content of the plugin is transmitted directly from Facebook to the user's device and integrated into the online service by the user. User profiles can be created from the processed data. We therefore have no influence on the extent of the data that Facebook collects with the help of this plugin and therefore inform the user according to our state of knowledge.

By integrating the plugins, Facebook receives the information that a user has called up the corresponding page of the online offer. If the user is logged in to Facebook, Facebook can assign the visit to his Facebook account. When users interact with the plugins, for example by clicking the Like button or commenting, the corresponding information is transferred directly from your device to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to find out his IP address and save it. According to Facebook, only an anonymous IP address is stored in Germany.

The purpose and scope of the data collection and the further processing and use of the data by Facebook as well as the relevant rights and setting options to protect the privacy of users can be found in Facebook's data protection information: https://www.facebook.com/about/privacy/.

If a user is a Facebook member and does not want Facebook to collect data about him or her via this online service and link it with his or her member data stored on Facebook, he or she must log out of Facebook before using our online service and delete his or her cookies. Further settings and objections to the use of data for advertising purposes are possible within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US page http://www.aboutads.info/choices/ or the EU page http://www.youronlinechoices.com/. The settings are platform-independent, i.e. they are adopted for all devices, such as desktop computers or mobile devices.
 

INSTAGRAM
Within our online offer, functions and contents of the service Instagram, offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, can be integrated. This may include, for example, content such as images, videos or text and buttons with which users can share content from this online offering within Instagram. If the users are members of the Instagram platform, Instagram can assign the call of the above contents and functions to the user profiles there. Instagram Privacy Policy: http://instagram.com/about/legal/privacy/. 

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INTEGRATION OF SERVICES AND CONTENTS OF THIRD PARTIES
Within the scope of our online offer, we act on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 Para. 1 lit. f. of the German Civil Code). DSGVO) content or service offers from third parties in order to integrate their content and services, such as videos or fonts (hereinafter uniformly referred to as "content").
This always presupposes that the third-party providers of this content perceive the IP address of the user, since they would not be able to send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We make every effort to use only those contents whose respective providers only use the IP address to deliver the contents. Third party providers may also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. Pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may contain, among other things, technical information about the browser and operating system, referring web pages, visit times and other information about the use of our online services, as well as may be linked to such information from other sources.

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Special offers of the Sovendus GmbH

In order to select an advantage offer of current regional interest to you, we pseudonymise and encrypt the title, name and hash value of the e-mail address and send it to Sovendus GmbH, Moltkestr. 11, 76133 Karlsruhe (Sovendus) (Art. 6 Para. 1 f DSGVO). The pseudonymised hash value of the e-mail address is also used to take account of any objection to advertising by Sovendus (Art. 21 para. 3, Art. 6 para. 1 c DSGVO). The IP address is used by Sovendus exclusively for data security purposes and is usually anonymized after seven days (Art. 6 para. 1 f DSGVO). When you click on an advantage offer, your name and e-mail address are also transmitted to Sovendus in encrypted form in preparation for the personalized request of the advantage offer from the product provider (Art. 6 para. 1 b, f DSGVO). For further information on the processing of your data by Sovendus, please refer to the online privacy policy at www.sovendus.de/datenschutz.

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