Privacy policy

1. introduction

In the following, we provide information about the processing of personal data when using

- our website https://www.wordspark.de/

- our profiles in social media.

Personal data is all data that can be related to a specific natural person, e.g. their name or IP address.

1.1 Contact details‍

The controller pursuant to Art. 4 (7) of the EU General Data Protection Regulation (GDPR) is

more life FZCO
IFZA Business Park, DDP
Dubai, United Arab Emirates

E-mail: info@wordspark.de

1.2 Scope of data processing, purposes of processing and legal basis‍

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

Art. 6 para. 1 sentence 1 it. a GDPR serves as the legal basis for processing operations for which we obtain consent.

Art. 6 para. 1 sentence 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for them. This legal basis also applies to processing that is necessary for pre-contractual measures, for example in the case of inquiries about our products or services.

Art. 6 para. 1 sentence 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case in tax law, for example.

Art. 6 para. 1 sentence 1 lit. f GDPR serves as the legal basis if we can rely on legitimate interests to process personal data, e.g. for cookies that are required for the technical operation of our website.

1.3 Data processing outside the EEA

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

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

The transfer of data to third parties in the United Kingdom of Great Britain and Northern Ireland is currently based on the transitional arrangements in the Trade and Cooperation Agreement between the European Union and the United Kingdom.

1.4 Storage period

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted, i.e. the data will be blocked and not processed for other purposes. This applies, for example, to data that we must retain for commercial or tax law reasons.

1.5 Rights of the data subjects

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

Right to information,

Right to rectification or erasure,

Right to restriction of processing,

Right to object to the processing,

Right to data portability,

Right to withdraw consent at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data.

1.6 Obligation to provide data

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

Mandatory information is marked as such.

1.7 No automated decision-making in individual cases

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

1.8 Making contact

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

1.9 Customer surveys

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

2nd Newsletter

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

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

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

3. data processing on our website

3.1 Informational use of the website

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

These data are:

IP address

Date and time of the request

Time zone difference to Greenwich Mean Time (GMT)

Content of the request (specific page)

Access status/HTTP status code

Amount of data transferred in each case

Website from which the request comes

Browser

Operating system and its interface

Language and version of the browser software.

This data is also stored in log files. They are deleted when their storage is no longer required, at the latest after 14 days.

3.2 Web hosting and provision of the website

Squarespace Ireland Limited, Squarespace House, Ship Street Great, Dublin 8, Ireland, D08 N12C (Privacy Policy: https://de.squarespace.com/data-privacy). The provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data. It is our legitimate interest to provide a website, so that the legal basis for data processing is Art. 6 para. 1 sentence 1 lit. f GDPR.

3.3 Contact form

When you contact us via the contact form on our website, we store the data requested there and the content of the message.

The legal basis for the processing is our legitimate interest in responding to inquiries addressed to us. The legal basis for the processing is therefore Art. 6 para. 1 sentence 1 lit. f GDPR. We delete the data arising in this context after storage is no longer necessary, or restrict processing if there are statutory retention obligations.

3.4 Third-party tools

3.4.1 Microsoft Advertising (Bing Ads)

We use the Microsoft Advertising (Bing Ads) tool for analysis and advertising. The provider is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. The provider processes meta/communication data (e.g. device information, IP addresses) and usage data (e.g. websites visited, interest in content, access times) in the USA. The legal basis for processing is Art. 6 para. 1 sentence 1 lit. a GDPR. Processing is carried out on the basis of consent. Data subjects can withdraw their consent at any time, e.g. by contacting us using the contact details provided in our privacy policy. The revocation does not affect the legality of the processing until the revocation. The legal basis for the transfer to a country outside the EEA is . We delete the data when the purpose for which it was collected no longer applies. Further information can be found in the provider's privacy policy at https://privacy.microsoft.com/de-de/privacystatement

3.4.2 Facebook Custom Audiences

We use the Facebook Custom Audiences tool for advertising. The provider is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) in the USA. The legal basis for processing is Art. 6 para. 1 sentence 1 lit. a GDPR. Processing is carried out on the basis of consent. Data subjects can withdraw their consent at any time, e.g. by contacting us using the contact details provided in our privacy policy. The revocation does not affect the legality of the processing until the revocation. The legal basis for the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed in accordance with the review procedure pursuant to Art. 93 para. 2 GDPR standard data protection clauses (Art. 46 para. 2 lit. c GDPR), which we have agreed with the provider. We delete the data when the purpose for which it was collected no longer applies. Further information can be found in the provider's privacy policy at https://www.facebook.com/policy.php

3.4.3 Google Web Fonts

We use the Google Web Fonts tool for fonts on the website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes meta/communication data (e.g. device information, IP addresses) in the USA. The legal basis for the processing is Art. 6 para. 1 sentence 1 lit. a GDPR. Processing takes place on the basis of consent. Data subjects can withdraw their consent at any time, e.g. by contacting us using the contact details provided in our privacy policy. The revocation does not affect the legality of the processing until the revocation. The legal basis for transfer to a country outside the EEA is consent. Further information can be found in the provider's privacy policy at https://policies.google.com/privacy?hl=de

3.4.4 Google Ads

We use the Google Ads tool for advertising. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA. The legal basis for processing is Art. 6 para. 1 sentence 1 lit. a GDPR. Processing takes place on the basis of consent. Data subjects can withdraw their consent at any time, e.g. by contacting us using the contact details provided in our privacy policy. The revocation does not affect the legality of the processing until the revocation. The legal basis for the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed in accordance with the review procedure pursuant to Art. 93 para. 2 GDPR standard data protection clauses (Art. 46 para. 2 lit. c GDPR), which we have agreed with the provider. We delete the data when the purpose for which it was collected no longer applies. Further information can be found in the provider's privacy policy at https://policies.google.com/privacy?hl=de

3.4.5 Google Analytics

We use the Google Analytics tool for analysis. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, D04e5w5, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA. The legal basis for processing is Art. 6 para. 1 sentence 1 lit. a GDPR. Processing takes place on the basis of consent. Data subjects can withdraw their consent at any time, e.g. by contacting us using the contact details provided in our privacy policy. The revocation does not affect the legality of the processing until the revocation. The legal basis for the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed in accordance with the review procedure pursuant to Art. 93 para. 2 GDPR standard data protection clauses (Art. 46 para. 2 lit. c GDPR), which we have agreed with the provider. The data will be deleted if the purpose of its collection no longer applies and there is no obligation to retain it. Further information can be found in the provider's privacy policy at https://policies.google.com/privacy?hl=de

3.4.6 Google Marketing Platform

We use the Google Marketing Platform tool for analysis and advertising. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA. The legal basis for processing is Art. 6 para. 1 sentence 1 lit. a GDPR. Processing takes place on the basis of consent. Data subjects can withdraw their consent at any time, e.g. by contacting us using the contact details provided in our privacy policy. The revocation does not affect the legality of the processing until the revocation. The legal basis for the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed in accordance with the review procedure pursuant to Art. 93 para. 2 GDPR standard data protection clauses (Art. 46 para. 2 lit. c GDPR), which we have agreed with the provider. We delete the data when the purpose for which it was collected no longer applies. Further information can be found in the provider's privacy policy at https://policies.google.com/privacy?hl=de

3.4.7 Google Tag Manager

We use the Google Tag Manager tool for analysis and advertising. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) in the USA. The legal basis for processing is Art. 6 para. 1 sentence 1 lit. a GDPR. Processing is carried out on the basis of consent. Data subjects can withdraw their consent at any time, e.g. by contacting us using the contact details provided in our privacy policy. The revocation does not affect the legality of the processing until the revocation. The legal basis for the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed in accordance with the review procedure pursuant to Art. 93 para. 2 GDPR standard data protection clauses (Art. 46 para. 2 lit. c GDPR), which we have agreed with the provider. We delete the data when the purpose for which it was collected no longer applies. Further information can be found in the provider's privacy policy at https://policies.google.com/privacy?hl=de

3.4.8 Facebook Pixel

We use the Facebook Pixel tool for analysis. The provider is Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) in the USA. The legal basis for processing is Art. 6 para. 1 sentence 1 lit. a GDPR. Processing is carried out on the basis of consent. Data subjects can withdraw their consent at any time, e.g. by contacting us using the contact details provided in our privacy policy. The revocation does not affect the legality of the processing until the revocation. The legal basis for the transfer to a country outside the EEA is standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed in accordance with the review procedure pursuant to Art. 93 para. 2 GDPR standard data protection clauses (Art. 46 para. 2 lit. c GDPR), which we have agreed with the provider. The data will be deleted if the purpose of its collection no longer applies and there is no obligation to retain it. Further information can be found in the provider's privacy policy at https://www.facebook.com/policy.php

4. data processing on social media platforms

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

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

4.1 LinkedIN

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://www.linkedin.com/legal/privacy-policy.

5. changes to this privacy policy

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

Obligations to remove or block the use of information in accordance with general legislation remain unaffected by this. However, liability in this respect is only possible from the time we become aware of a specific infringement. As soon as we become aware of such infringements, we will remove this content immediately.