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Privacy Policy

1. General Information

The Appinio website www.appinio.com is provided by APPINIO GmbH (hereinafter "we"). When visiting this website, we may collect, process and use personal data. Personal data is any data that can be related to a specific natural person, such as their name or IP address.

 

1.1. Responsible Body/Contact

APPINIO GmbH
Große Theaterstraße 31
20354 Hamburg

Represented by the Managing Directors Jonathan Kurfess, Kai Granaß, Max Honig, Dr. Tizian Bonus

Contact: privacy@appinio.com

 

1.2. Data Protection Officer

Contact details of the data protection officer: 

ePrivacy GmbH
Prof. Dr. Christoph Bauer
Große Bleichen 21
20354 Hamburg

Reference: APPINIO GmbH.

If you have any questions or suggestions regarding data protection, please feel free to contact us by email at privacy@appinio.com.

 

1.3. Scope of data processing, processing purposes and legal bases

We detail the scope of data processing, processing purposes and legal bases below. In principle, the following come into consideration as the legal basis for data processing:

  • Art. 6 para. 1 p. 1 it. a GDPR serves as our legal basis for processing operations for which we obtain consent.
  • Art. 6 para. 1 s. 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 him. This legal basis also applies to processing that is necessary for pre-contractual measures, such as in the case of inquiries about our products or services.
  • Art. 6 para. 1 s. 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case, for example, in tax law.
  • Art. 6 para. 1 S. 1 lit. f GDPR serves as the legal basis when we can rely on legitimate interests to process personal data, e.g. for cookies that are necessary for the technical operation of our website.

 

1.4. 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 the transfer is guaranteed by adequacy decisions of the EU Commission, insofar as they exist (e.g. for Great Britain) (Art . 45 para. 3 GDPR).

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

 

1.5. Storage duration

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

 

1.6. Rights of data subjects

Data subjects have the following rights against us with regard to their personal data:

  • Right of access
  • Right to correction or deletion
  • Right to limit processing
  • Right to object to the processing
  • Right to data transferability
  • Right to revoke a given 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.

 

1.7. Obligation to provide data

Unless this is expressly stated, the provision of the data is not required or obligatory.

 

1.8. No automatic decision-making in individual cases

As a matter of principle, we do not use a fully automated decision-making process in accordance with Article 22 GDPR to establish and implement the business or other relationship. Should we use these procedures in individual cases, we will inform of this separately if this is required by law.

 

1.9. Contact

When contacting us, e.g. by email, phone or chat, the data provided to us (e.g. names and email addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 p. 1 lit. f GDPR) to answer inquiries directed to us. We delete the data accruing in this context after the storage is no longer necessary or restrict the processing if there are legal retention obligations.

2. Newsletter

We inform existing customers from time to time by email about our offers, if they have not objected to this. The legal basis for this data processing is Art. 6 para. 1 s. 1 lit. f GDPR. Our legitimate interest is to conduct direct advertising (recital 47 GDPR). Customers can object to receiving the Newsletter without incurring additional costs, by clicking the link at the end of each email.
Other recipients of the newsletter have filled out the registration form to receive newsletters. Subscription takes place by selecting the corresponding field on our website, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 para . p. 1 lit. a GDPR. Consent can be revoked at any time, e.g. by clicking the corresponding link in the newsletter or notifying our email address given above. The processing of the data until revocation remains lawful even in the event of revocation.
We send newsletters using HubSpot, a software company from the USA with a branch office in Ireland.

Contact:
HubSpot,2nd Floor 30 North Wall Quay, Dublin 1, Ireland
Telephone: +353 1 5187500.

The provider processes content, usage, meta/communication data and contact data.

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

3. Telephone Marketing

Insofar as a potential business customer (B2B) has given their presumed consent for us to make promotional calls, we will also offer them our services by telephone call (telemarketing). We assume a corresponding presumed consent if you have contacted us and provided us with your telephone number, e.g. in the context of a newsletter registration.

Data categories:

  • Name
  • Phone number
  • Company/organisation
  • Existence of marketing consent
  • Time of contact

Purpose is personal presentation of the service portfolio and booking conditions in a telephone conversation with potential customers whose consent for a call is presumed. The legal basis is presumed consent within the meaning of § 7 para. 2 no. 2 UWG.

4. Data processing on our website

4.1. Informative use of our website

During the informative use of the website, i.e. when site visitors do not separately transmit information to us, 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 that the legal basis is Art. 6 para. 1 s. 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 necessary, at the latest after 7 days.

 

4.2. Web hosting and provision of the website

Our website is hosted by HubSpot Inc., USA, contact within the EU: One Dockland Central, Dublin 1, Irland (Privacy Policy) on the basis of a data processing agreement (Art. 28 GDPR). The provider thereby processes the personal data transmitted via the website, e.g. on 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 s. 1 lit. f GDPR.

As soon as website visitors use login or contact functions we use a content delivery network to help provide our website. The provider is Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855, Luxembourg (Privacy Policy). The provider thereby processes the personal data transmitted via the website, e.g. on 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 s. 1 lit. f GDPR.

 

4.3. Meeting request

If you send us a meeting request, we save the data requested there and the content of the meeting request. The legal basis for the processing is Art. 6 (1) sentence 1 lit. b GDPR because this precontractual measure takes place at your request. We delete the data arising in this context after the storage is no longer necessary, or restrict the processing if there are statutory storage obligations.

 

4.4. Technically necessary cookies

Our website sets cookies. Cookies are small text files that are stored in the web browser on the end device of a site visitor. Cookies help to make the offer more user-friendly, effective and secure. Insofar as these cookies are necessary for the operation of our website or its functions (hereinafter "Technically Necessary Cookies"), the legal basis for the associated data processing is Art. 6 para. 1 s. 1 lit. f GDPR. We have a legitimate interest in providing customers and other site visitors with a functional website.

 

4.5. Third parties

4.5.1. Google Tag Manager

We use Google Tag Manager for analytics and for advertisement. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) in the USA.


The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time by contacting us, for example, using the contact details provided in our privacy policy. The revocation does not affect the lawfulness of the processing until the revocation.


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


We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy policy

 

4.5.2. HubSpot

We use HubSpot technology as a central database for managing our customers. This includes contract and invoice data and communication with the customer (e.g. via the chat function and via email).

Further this includes the registration form when you create an account on our website. HubSpot automatically supplements the core data of our customers with information on the usage history of our digital offerings. In this way, we can more easily assign the use of our services and any problems that may arise to individual customers and can present our customers with suitable offers for the further use of our services.
HubSpot is a software company from the USA with a branch office in Ireland.

Contact:
HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland
Telephone: +353 1 5187500.


The collection of usage behavior takes place via cookies. HubSpot accesses its own cookies for this purpose and combines this data with other data that we have collected via other analysis services in order to be able to provide as complete a customer profile as possible.
The direct HubSpot cookies are: _hs_opt_out (cookie consent), _hssc, _hssrc, _hstc, _HubSpotutk
For a stable provision of the HubSpot internet pages, HubSpot uses the content delivery network Cloudflare, which sets the following cookies: _cfduid, _cfruid
More information about the Privacy Policy can be found here.
More information about Hubspots regarding the EU-Data Protection Regulations can be found here.
More Information about HubSpots Cookies can be found here and here.

As part of the optimization of our marketing activities, Hubspot may collect and process the following data:

  • Geographical position
  • Browser type
  • Navigation information
  • Reference URL
  • Performance data
  • Information about how often the application is used
  • Mobile apps data
  • HubSpot subscription service credentials
  • Files that are displayed on site
  • Domain names
  • Viewed pages
  • Aggregated use
  • Version of the operating system
  • Internet service provider
  • IP address
  • Device identification
  • Duration of the visit
  • Where the application was downloaded from
  • Operating system
  • Events that occur within the application
  • Access times
  • Clickstream data
  • Device model and version

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. b GDPR for contractual steps and Art. 6 para.1.s. 1 lit a GDPR for the use of cookies (see more information on cookies in the cookie policy).

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

The data will be stored for as long as it is necessary for the purpose of the procession. The data will be deleted as soon as it is no longer needed for the processing purposes.

 

4.5.3. Google Analytics

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

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time in the cookie settings. The revocation does not affect the lawfulness of the processing until the revocation.

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

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy.

 

4.5.4. LinkedIn Analytics

Our internet pages set cookies from LinkedIn. By doing so, we provide LinkedIn with data about your use of our site. In this way, we enable LinkedIn to provide advertisements for us within LinkedIn in a more target group-specific manner.
The names of the LinkedIn cookies are: UserMatchHistory, bcookie, bscookie, lang, lidc, lissc


These data are:
  • IP address via which the device goes online
  • Location or country linked to the IP address and Internet service provider for Internet access
  • Date and time of access
  • Objects on our website that are called up (clicked on) in the browser
  • Type and version of the Internet browser
  • Type and version of the operating system
  • Websites from which the user has accessed our website
  • Websites that the user calls up from our website
  • LinkedIn ID stored in the cookie

The purpose of passing on data to LinkedIn is to be able to provide ads on LinkedIn that are as target group-specific as possible. The legal basis is your consent, which you have given via our cookie manager (Art. 6 (1) a GDPR). Data subjects may revoke their consent at any time in the cookie settings. The revocation does not affect the lawfulness of the processing until the revocation.

The storage period is the responsibility of LinkedIn. It is not necessary for us to delete your data, as we do not collect any data from you through the use of LinkedIn cookies.

 

4.5.5. LinkedIn Insight Tag

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time in the cookie settings. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy.

 

4.5.6. Facebook Pixel

We use Facebook Pixel for analytics. The provider is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes usage data (e.g. web pages visited, interest in content, access times) in the USA.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time in the cookie settings. The revocation does not affect the lawfulness of the processing until the revocation.

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

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy

 

4.5.7. Google Ads

We are using the conversion function from Google Ads. This function helps us to determine how successful the individual advertising measures are. The advertising materials are delivered by Google via so-called “Ad Servers”. For this purpose, we use ad server cookies, through which certain parameters for measuring success, such as the insertion of ads or clicks by users, can be measured.

We are using the remarketing function from Google Ads on our website. This function serves to present visitors to the Website with advertisements tailored to their interests, within the framework of the Google advertising network. The Website visitors’ browser stores cookies. On these pages, the user can then be shown advertisements related to content that the visitor has previously accessed on websites which use Google’s remarketing function. You can find further information about Google Remarketing and Google’s Privacy Policy here and here.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time in the cookie settings. The revocation does not affect the lawfulness of the processing until the revocation.

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

 

4.5.8. Google Analytics Advertising Feature

We are using the extended function of Google Analytics (Google Analytics Advertising features). This includes Google Display Network Impression Reporting, Google Analytics Demographics and Interest Reporting, Integrated Services that require Google Analytics to collect data for advertising purposes, including the collection of data via advertising cookies and identifiers. For this we are using the Google Analytics cookie and Google advertising cookies and identifiers together in order to optimize our website.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time in the cookie settings. The revocation does not affect the lawfulness of the processing until the revocation.

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

 

4.5.9. Google Campaign Manager

We use the Campaign Manager service of Google. This service uses cookies to display ads relevant to website visitors and customers, improve campaign performance reports, or to prevent a customer from seeing the same ads more than once. Google uses a cookie ID to track which ads are displayed in which browser and to prevent them from being displayed more than once. In addition, Campaign Manager may use cookie IDs to collect so called conversions related to ad requests.

The legal basis for the processing is Art. 6 para. 1 s. 1 lit. a GDPR. The processing is based on consent. Data subjects may revoke their consent at any time in the cookie settings. The revocation does not affect the lawfulness of the processing until the revocation.

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

 

4.5.10. Facebook Custom Audiences, Google Customer Match

We use the Custom Audiences service of Meta Platforms, Inc. for usage-based online advertising. (1601 S. California Avenue, Palo Alto, CA 94304, USA) and Google Customer Match (a service of Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, Ireland, a subsidiary of the Google LLC, 1600 Amphitheatre Parkway Mountain View, CA, USA). For this purpose, we define target groups of users in the Facebook ad manager or on Google on the basis of certain characteristics, who are subsequently shown ads within the Facebook/Google network. Users are selected by Facebook/Google based on the profile information they provide and other data provided through their use of Facebook/Google. If a user clicks on an advertisement and subsequently arrives on our website, Facebook/Google receives the information that the user has clicked on the advertising banner via the Facebook/Google pixel integrated on our website. Generally, a non-reversible and non-personal checksum (hash value) is generated from your usage data, which is transmitted to Facebook/Google for analysis and marketing purposes. A Facebook/Google cookie is set in the process. This collects information about your activities on our website (e.g. surfing behaviour, sub-pages visited, etc.). Your IP address is also stored and used for the geographical targeting of advertising. Facebook Custom Audiences/Google Customer Match via the customer list is not used by us, nor is the "extended matching" function.

The data is deleted after 720 days at the latest.

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

You can find Facebook's privacy policy here and Google's privacy policy here.

You can object to the collection and use of your data by the Facebook pixel here.

The legal basis for this data processing is the consent pursuant to Art.6 para.1 p.1 lit. a) GDPR. The consent can be revoked at any time with effect for the future by accessing the cookie settings.

The revocation does not affect the lawfulness of the processing until the revocation.

 

4.5.11. Hotjar

We use Hotjar for analytics. The provider is Hotjar Ltd., Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian's, STJ 3141, Malta. The provider processes usage data (e.g. web pages visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for this data processing is the consent pursuant to Art.6 para.1 p.1 lit. a) GDPR. The consent can be revoked at any time with effect for the future by accessing the cookie settings. The revocation does not affect the lawfulness of the processing until the revocation.

The data will be deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy policy.

 

4.5.12. Cookie Administration

Description: For all cookies requiring consent, we ask for our website visitor’s consent before storing them in the website visitor’s browser cache. The decisions will in turn be stored in a cookie on the website visitor’s device so that we do not have to ask for the consent again when visiting our website again. The website visitor can revise the decision at any time by deleting the corresponding cookie from the device via the settings of the browser.

For our HubSpot pages, the cookie is called: _hs_opt_out.

Purpose is the legally compliant consent management for cookies. Legal basis is a legitimate interest according to Art. 6 (1) f GDPR, as saving the cookie decision only slightly restricts the rights of visitors and at the same time simplifies the use of the pages on repeated visits.

Storage duration: Until the corresponding cookie is deleted from the browser cache or until the expiry date of the cookie is reached.

5. Changes to this privacy policy

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

6. Questions and comments

If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact information provided above.