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(automatically translated from German)

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Privacy policy

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1. Introduction

Okapi Tech GmbH operates the website https://www.pongmasters.app/ and the Pongmasters app.

The Pongmasters app digitizes the sport of table tennis. Players can find each other via the app, exchange popular tables and arrange a match. Offline ranking and matchmaking principles can be used to collect points and players can move up in various rankings.

We treat your data as a valuable asset and give it the best possible protection.

You can find out exactly how we process your data on our website and in the Pongmasters app (hereinafter "offers") in this privacy policy.

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2. General information

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2.1. Processing of personal data and other terms

Data protection applies to the processing of personal data. Personal data means all data with which you can be personally identified. This is, for example, the IP address of the device (PC, laptop, smartphone, etc.) you are currently sitting in front of. Such data is processed when 'something happens to it'. Here, for example, the IP is transmitted from the browser to our provider and automatically stored there. This is then a processing (according to Art. 4 No. 2 GDPR) of personal data (according to Art. 4 No. 1 GDPR).

These and other legal definitions can be found in Art. 4 GDPR.

 

2.2. Applicable regulations/laws - GDPR, BDSG and TTDSG

The scope of data protection is regulated by law. In this case, these are the GDPR (General Data Protection Regulation) as a European regulation and the BDSG (Federal Data Protection Act) as a national law.

In addition, the TTDSG supplements the provisions of the GDPR as far as the use of cookies is concerned.

 

2.3. The person responsible

The controller within the meaning of the GDPR is responsible for data processing on this website. This is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data.

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You can reach the person responsible at:

Okapi Tech GmbH

Holsteinische Straße 23
10717 Berlin Germany 

hi@pongmasters.app

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2.4. Your rights

The GDPR provides you with comprehensive rights. These include, for example, free information about the origin, recipient and purpose of your stored personal data. You can also request the rectification, blocking or erasure of this data or lodge a complaint with the competent data protection supervisory authority. You can revoke your consent at any time.

You can find out what these rights look like in detail and how to exercise them in the last section of this privacy policy.

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2.5. Data protection - Our view

Data protection is more than just a chore for us! Personal data has great value and careful handling of this data should be a matter of course in our digitalized world. As a website visitor, you should also be able to decide for yourself what "happens" to your data, when and by whom. That is why we are committed to complying with all legal regulations, only collect the data that is necessary for us and, of course, treat it confidentially.

 

2.6. Forwarding and deletion

The transfer and deletion of data are also important and sensitive issues. We would therefore like to briefly inform you in advance about our general approach to this.

Data will only be passed on on the basis of a legal basis and only if this is unavoidable. This may be the case in particular if it is a so-called processor and an order processing contract has been concluded in accordance with Art. 28 GDPR.

We delete your data when the purpose and legal basis for processing no longer apply and the deletion does not conflict with any other legal obligations. Art. 17 GDPR also provides a 'good' overview of this.

For further information, please refer to this privacy policy and contact the person responsible if you have any specific questions.

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2.7. Legal basis

The processing of personal data always requires a legal basis. The GDPR provides the following options in Art. 6 para. 1 sentence 1:

a) The data subject has given their consent to the processing of their personal data for one or more specific purposes;

b) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;

c) the processing is necessary for compliance with a legal obligation to which the controller is subject;

d) processing is necessary in order to protect the vital interests of the data subject or of another natural person;

e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

f) processing is necessary for the purposes of the legitimate interests pursued by the controller(s) or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

In the following sections, we will provide you with the specific legal basis for the respective processing.

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3. What happens on our website

Our website is for information purposes only and offers a contact option. We use SSL or TLS encryption to protect your personal data, such as your IP address, against unauthorized access by third parties when you visit our website.  You can recognize this encrypted connection by the https:// or lock symbol in the address bar of your browser.

Below you can find out what data is collected when you visit our website, for what purpose this is done and on what legal basis.

 

3.1. Hosting

Our website is hosted externally. The personal data collected on this website is stored on the host's servers. This includes the automatically collected and stored log files (see below for more details), as well as all other data provided by website visitors.

External hosting is used for the purpose of secure, fast and reliable provision of our website and in this context serves to fulfill the contract with our potential and existing customers.

The legal basis for the processing is Art. 6 para. 1 lit. a, b and f GDPR, as well as § 25 para. 1 TTDSG, insofar as consent includes the storage of cookies or access to information in the terminal device of the website visitor or user within the meaning of the TTDSG.

Our hoster only processes data that is required to fulfill its performance obligation and acts as our processor, i.e. it is subject to our instructions. We have concluded a corresponding contract for order processing with our hoster.

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We use the following hoster:

WiX

Wix.com Ltd, Nemal St. 40, 6350671 Tel Aviv, Israel.

support@wix.com

https://de.wix.com/about/privacy.

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3.2. Data collection when accessing the website

When you visit the website, information is automatically stored in so-called server log files. This is the following information:

  • Browser type and browser version

  • Operating system used

  • Referrer URL

  • Host name of the accessing computer

  • Time of the server request

  • IP address

This data is temporarily required in order to be able to display our website to you permanently and without any problems. In particular, this data is used for the following purposes:

  • System security of the website

  • System stability of the website

  • Troubleshooting on the website

  • Establishing a connection to the website

  • Presentation of the website

Data processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR and is based on our legitimate interest in the processing of this data, in particular our interest in the functionality of the website and its security.

Where possible, this data is stored in pseudonymized form and deleted once the respective purpose has been achieved.

If the server log files allow the data subject to be identified, the data is stored for a maximum period of 14 days. An exception is made if a security-relevant event occurs. In this case, the server log files are stored until the security-relevant event has been resolved and finally clarified.

Otherwise, no merging with other data takes place.

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3.3. Cookies

 

3.3.1. General information

This website uses so-called cookies. This is a data record, information that is stored in the browser of your end device and is related to our website.

The use of cookies can make it easier for visitors to navigate the website.

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3.3.2. Rejecting cookies

You can prevent cookies from being set by adjusting your browser settings.

Here you will find the corresponding links to frequently used browsers:

Mozilla Firefox: https://support.mozilla.org/de/kb/cookies-und-website-daten-in-firefox-loschen?redirectslug=Cookies+l%C3%B6schen&redirectlocale=en

Google Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=de

Microsoft Edge: https://support.microsoft.com/de-de/windows/l%C3%B6schen-und-verwalten-von-cookies-168dab11-0753-043d-7c16-ede5947fc64d

Safari: https://support.apple.com/de-de/guide/mdm/mdmf7d5714d4/web and https://support.apple.com/de-de/guide/safari/sfri11471/mac

If you are using a different browser, we recommend that you enter the name of your browser and 'Delete and manage cookies' in a search engine and follow the official link to your browser

Alternatively, you can also manage your cookie settings at www.aboutads.info/choices/
or www.youronlinechoices.com.

However, we must point out that a comprehensive blocking/deletion of cookies can lead to impairments in the use of the website.

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3.3.3. Technically necessary cookies

We use technically necessary cookies on this website to ensure that our website functions correctly and in accordance with the applicable laws. They help to make the website user-friendly. Some functions of our website cannot be displayed without the use of cookies.

legal basis for this is, depending on the individual case, Art. 6 para. 1 lit. b, c and/or f GDPR

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3.3.4. Technically not necessary cookies

We also use cookies on our website that are not technically necessary. These cookies are used, among other things, to analyze the surfing behavior of the website visitor or to offer functions of the website that are not technically necessary.

The legal basis for this is your consent in accordance with Art. 6 para. 1 lit. a GDPR.

Technically unnecessary cookies are only set with your consent, which you can revoke at any time in the cookie consent tool.

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3.4. Data processing through user input

 

3.4.1. Contact us

 

a) E-mail

When you contact us by email, we process your email address and any other data contained in the email. This data is stored on the mail server and in some cases on the respective end devices. Depending on the request, the legal basis for this is regularly Art. 6 para. 1 lit. f GDPR or Art. 6 para. 1 lit. b GDPR. The data will be deleted as soon as the respective purpose no longer applies and it is possible in accordance with the legal requirements.

 

b) Telephone

If you contact us by telephone, the call data may be stored in pseudonymized form on the respective end device and with the telecommunications provider used. Personal data collected during the telephone call will only be processed in order to process your request. Depending on the request, the legal basis for this is regularly Art. 6 para. 1 lit. f GDPR or Art. 6 para. 1 lit. b GDPR. The data will be deleted as soon as the respective purpose no longer applies and it is possible in accordance with the legal requirements.

 

c) Contact form

We offer a contact form. This is used to contact our company.

In this form, we usually process your first and last name, your telephone number, your e-mail address, a postal address and the content of the message. The data is stored on our web server and forwarded internally to the relevant e-mail addresses.

The legal basis for data processing is Art. 6 para. 1 lit. b and f GDPR, as it serves the implementation of (pre-)contractual measures that are carried out at your request and we have a legitimate interest in carrying out our business activities.

We delete this data no later than 3 months after receipt, unless it is required for a contractual relationship that has arisen.

We bind the contact form from

Wix

Wix.com Ltd, Nemal St. 40, 6350671 Tel Aviv, Israel

https://de.wix.com/about/privacy.

on our website.

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3.5. Website construction kit system

 

3.5.1. Wix

We use the Wix service to create our website. This is a service of Wix.com Ltd, Namal 40, 6350671 Tel Aviv, Israel.

Wix is a website builder system that can be used to create HTML5 websites and mobile websites. It is an online platform that is based on the cloud principle. This makes it very easy to integrate the functions into your own website. With this service, we can design our website according to our wishes and meet our goal of user-friendliness.

Wix uses cookies. These cookies are only set with the consent of the website visitor and can be revoked at any time. The legal basis for the processing is Art. 6 para. 1 lit. a GDPR.

Furthermore, the use of the service is technically necessary for us to display our website. The legal basis for the processing is Art. 6 para. 1 lit. f GDPR.

The data will be deleted as soon as it is no longer required for the processing purposes.

Further information:

https://de.wix.com/about/privacy.

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3.6. Analysis and tracking tools

 

3.6.1. YouTube

We embed YouTube videos on this website. YouTube is an online video platform. This service is offered by Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

As soon as you start a video on our website, a connection to the YouTube servers is established. After starting a video, YouTube can set cookies on the end device of the website visitor in order to save settings and preferences and subsequently display personalized advertising. The information obtained from this is also used for video statistics, to improve user-friendliness and to prevent attempted fraud.

The legal basis for the processing is Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG, insofar as this consent includes access to information in the user's terminal device or the storage of cookies within the meaning of the TTDSG. This consent can be revoked at any time.

Further information:

https://policies.google.com/privacy?hl=de.

 

3.6.2.Meta pixel

We use meta pixels on this website. Meta Pixel is a conversion tracking tool. This service is provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Habour, Dublin 2, Ireland.

Meta-pixel enables us to track the behavior of the website visitor after they have been redirected to the website via a Facebook ad.

Meta-Pixel uses cookies for its own advertising purposes. The data is stored and processed by Facebook so that a connection to the respective user profile can be established.

The data collected is also transferred to the USA and other third countries.

The EU Commission's Standard Contractual Clauses (SCC) apply to data transfers to the USA.

The legal basis for the processing is Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG. Consent can be revoked at any time.

If personal data is collected on this website with the help of meta pixels and forwarded to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Habour, Dublin 2, Ireland are jointly responsible for data processing in accordance with Art. 26 GDPR. This joint responsibility is limited exclusively to the collection and transfer of data to Facebook. There is an agreement on joint processing for this purpose:

https://www.facebook.com/legal/controller_addendum.

We are responsible for providing data protection information when using the Facebook tool and for the secure integration of the tool on the corresponding website in accordance with data protection law. Facebook, on the other hand, is responsible for the data security of its products. This means that data subjects' rights with regard to the data processed by Facebook must be asserted directly with Facebook.

Further details:

https://de-de.facebook.com/about/privacy/

https://www.facebook.com/ads/preferences/?entry_product=ad_settings_scrnen

http://www.youronlinechoices.com/de/praferenzmanagement/

https://www.facebook.com/legal/EU_data_transfer_addendum

https://de-de.facebook.com/help/566994660333381.

 

3.6.3. Facebook Conversion API

We use Facebook Conversion API on this website. Facebook Conversion API is a web analysis service. This service is provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland.

With the help of Facebook Conversion API, we can record the interaction of the website visitor with the website and transmit it to Facebook in order to optimize advertising performance on Facebook.

The data collected is also transferred to the USA and other third countries.

The EU Commission's Standard Contractual Clauses (SCC) apply to data transfers to the USA.

https://www.facebook.com/legal/EU_data_transfer_addendum   

https://de-de.facebook.com/help/566994660333381. 

The legal basis for the processing is Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG. Consent can be revoked at any time.

If personal data is collected on this website with the help of meta pixels and forwarded to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Habour, Dublin 2, Ireland are jointly responsible for data processing in accordance with Art. 26 GDPR. This joint responsibility is limited exclusively to the collection and transfer of data to Facebook. There is an agreement on joint processing for this purpose:

https://www.facebook.com/legal/controller_addendum.

We are responsible for providing data protection information when using the Facebook tool and for the secure integration of the tool on the corresponding website in accordance with data protection law. Facebook, on the other hand, is responsible for the data security of its products. This means that data subjects' rights with regard to the data processed by Facebook must be asserted directly with Facebook.

Further details:

https://de-de.facebook.com/about/privacy/.

 

3.6.4.Facebook Custom Audiences

We use Facebook Custom Audiences on this website. Facebook Custom Audiences is a web analysis service. This service is provided by Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland.

When using the online offer, personal data of the website visitor is collected. If the website visitor has given us consent to use Facebook Cutsom Audiences, this data is transmitted to Facebook in order to display suitable advertising to the website visitor and to define target groups.

The legal basis for the processing is Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG. Consent can be revoked at any time.

The EU Commission's Standard Contractual Clauses (SCC) apply to data transfers to the USA.

https://www.facebook.com/legal/terms/customaudience

https://www.facebook.com/legal/terms/dataprocessing.

 

4. What happens in our app

 

4.1. Registration

Users must register to use our app. Registration can be done directly with us or via a social login.

 

4.1.1. Registration in the app

If you log in directly in the app, you must first register. This requires your e-mail address and a password. You can then choose a user name. This enables secure access to our app.

We will also use your e-mail address to contact you if necessary.

The processing of this data is justified in accordance with Art. 6 para. 1 lit. b GDPR.

We delete your data when you delete your account with us.

 

4.1.2. Social logins

You can also register in our app using a social login.

The legal basis for the processing is Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG. Consent is given by selecting the corresponding social media profile and can be revoked at any time for the future.

The transmitted data may subsequently be processed for the establishment, execution and termination of a contractual relationship, Art. 6 para. 1 lit. b GDPR.

If the user chooses such a social login, the corresponding social media provider establishes the identity and transmits the following data to us:

  • Google

When you log in via Google, the following data is transmitted to us by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland:

First and last name, e-mail address, profile picture

Further information on data processing by Google:

https://policies.google.com/privacy

  • Apple ID

When you log in via Apple, the following data is transmitted to us by Apple Inc, Infinite Loop, Cupertino, CA 95014, USA:

First and last name, e-mail address

Further information on data processing by Apple:

https://www.apple.com/de/privacy/.

 

4.2. Profile data

You have the option of filling in your profile with personal information about yourself. You can add a profile, your date of birth, your gender, your playing level, club membership, your playing frequency, your experience and a profile picture.

Entering this data is optional.

With the help of this data, other players can better assess you and, if necessary, invite you to a game or an exchange.

The processing of this data is based on your consent in accordance with Art. 6 para. 1 lit. a GDPR. You can withdraw your consent at any time. You can also change or delete your data in your profile at any time.

 

4.3. Statistics

We use the data on the games you have played to determine

  • your playing strength (Eloscore)

  • your number of games

  • further statistics on your gaming behavior.

The processing of this data is based on Art. 6 para. 1 lit. b GDPR and serves to ensure the core functionality of the app.

 

4.4. Online status

You can change your personal online status so that other players can find you.

We process your status in accordance with Art. 6 para. 1 lit. b GDPR.

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4.5. Interaction data

We process your personal data through your interactions in the app.

These include:

  • Posts, possibly with photos, comments and likes

  • Documentation of matches and their results and venues

  • Your followers and who you follow

  • Match requests

  • Ratings of games through the possibility of a post function

  • Chat messages and their personal content

  • Participation or expressed interest in events, meet-ups, tournaments and leagues

The processing of this data is based on your voluntary input in accordance with Art. 6 para. 1 lit. a GDPR. If there is interaction with you, we process the data in accordance with Art. 6 para. 1 lit. b GDPR to ensure the functionality and purpose of our app.

 

4.6. Location data

When you use the app, we collect and process your location information. This is the only way we can enable our core functions (finding possible game partners, tables played, etc.). We do not determine your location when the app is closed.

Your location data is processed with your consent in accordance with Art. 6 para. 1 lit. a GDPR.

 

4.7. Google Maps

If you are a user of an Android system, our app accesses the "Google Maps" map service. Google Maps is provided by Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.

By integrating Google Maps, we want to enable our users to discover new tables, share known venues with others and search for players in the area.

When using Google Maps, the IP address is stored. This data is usually transferred to a Google server in the USA and stored there. We have no influence on this.

The legal basis for the integration of Google Maps is Art. 6 para. 1 lit. f GDPR. By integrating Google Maps, we can display the locations of possible venues and thus fulfill the actual purpose of the app.

By deactivating Google Maps in the app, you can prevent your data from being processed further. This can lead to considerable restrictions in the use of the app.

The EU Commission's Standard Contractual Clauses (SCC) apply to data transfers to the USA. Google is also certified in accordance with the EU-U.S. Data Privacy Framework.

Further information:

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

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

https://policies.google.com/privacy?hl=de.

 

4.8. Apple Maps

If you use our app on an iOS device, you will have access to the "Apple Maps" map service. This service is provided by Apple Inc, 1 Infinite Loop, Cupertino, California, USA 95014.

With the help of Apple maps, geographical content is displayed visually by embedding the Apple maps in our app using a so-called "iFrame".

When loading the iFrame, personal data may be processed by Apple.

According to Apple, your data will not be linked to your Apple ID when you load the Apple Card. Apple also states that it does not keep a history of where you have been.

By integrating Apple Maps, we want to enable our users to discover new tables, share known venues with others and search for players in the area.

The legal basis for the integration of Apple Maps is Art. 6 para. 1 lit. f GDPR. By integrating Google Maps, we can display the locations of possible venues and thus fulfill the actual purpose of the app.

By deactivating Apple Maps in the app, you can prevent your data from being processed further. This can lead to considerable restrictions in the use of the app.

The EU Commission's Standard Contractual Clauses (SCC) apply to data transfers to the USA.

Further information:

https://www.apple.com/privacy/.

 

4.9. Google Firebase

We use Google Firebase Analytics in our app to monitor and evaluate user behavior in the app. This service is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

The app uses so-called advertising IDs (identifiers) instead of cookies. These are issued by the mobile device's operating system and can be reset by the user. With the help of these advertising IDs, the activities of the users can be recorded.

When using Google Firebase, the number of users and sessions, session duration, operating system, device model, region, first-time stars, app executions, app updates and in-app purchases are processed by default.

The legal basis for the use of Firebase is Art. 6 para. 1 lit. f GDPR. We have a legitimate interest in the optimal marketing of our app.

You can object to data processing by Google at any time for the future by deactivating data collection for Firebase by sending us your request by e-mail at hi@pongmasters.app or by restricting the use of the advertising ID in your device settings.

The EU Commission's Standard Contractual Clauses (SCC) apply to data transfers to the USA. Google is also certified in accordance with the EU-U.S. Data Privacy Framework.

Further information:

https://firebase.google.com/support/privacy?hl=de

 

5. What else is important

Finally, we would like to inform you in detail about your rights and how you will be informed about changes to data protection requirements.

 

5.1. Your rights in detail

 

5.1.1. Right to information in accordance with Art. 15 GDPR

You can request information about whether your personal data is being processed. If this is the case, you can request further information on the type and manner of processing. A detailed list can be found in Art. 15 para. 1 lit. a to h GDPR.

 

5.1.2. Right to rectification in accordance with Art. 16 GDPR

This right includes the correction of incorrect data and the completion of incomplete personal data.

 

5.1.3. Right to erasure in accordance with Art. 17 GDPR

This so-called 'right to be forgotten' gives you the right, under certain conditions, to request the deletion of personal data by the controller. This is generally the case if the purpose of the data processing no longer applies, if consent has been withdrawn or the initial processing took place without a legal basis. A detailed list of reasons can be found in Art. 17 para. 1 lit. a to f GDPR. This "right to be forgotten" also corresponds to the controller's obligation under Art. 17 para. 2 GDPR to take reasonable measures to bring about the general erasure of data.

 

5.1.4. Right to restriction of processing in accordance with Art. 18 GDPR

This right is subject to the conditions set out in Art. 18 para. 1 lit. a to d.

 

5.1.5. Right to data portability pursuant to Art. 20 GDPR

This regulates the basic right to receive your own data in a commonly used form and to transfer it to another controller. However, this only applies to data processed on the basis of consent or a contract in accordance with Art. 20 (1) (a) and (b) and insofar as this is technically feasible.

 

5.1.6. Right to object pursuant to Art. 21 GDPR

In principle, you can object to the processing of your personal data. This applies in particular if your interest in objecting outweighs the legitimate interest of the controller in the processing and if the processing relates to direct marketing and/or profiling.

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5.1.7. Right to "individual decision-making" pursuant to Art. 22 GDPR

In principle, you have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you. However, this right is also subject to restrictions and additions in Art. 22 (2) and (4) GDPR.

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5.1.8. Further rights

The GDPR includes comprehensive rights to inform third parties whether or how you have asserted rights under Art. 16, 17, 18 GDPR. However, this is only possible or feasible with reasonable effort.

We would like to take this opportunity to draw your attention once again to your right to withdraw your consent in accordance with Art. 7 (3) GDPR. However, this does not affect the lawfulness of the processing carried out up to that point.

We would also like to draw your attention to your rights under §§ 32 ff. BDSG, which, however, are largely congruent with the rights just described.

 

5.1.9. Right to lodge a complaint pursuant to Art. 77 GDPR

You also have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data violates this regulation.

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6. What if the GDPR is abolished tomorrow or other changes take place?

The current status of this privacy policy is 23.11.2023. From time to time, it is necessary to adapt the content of the privacy policy in order to react to actual and legal changes. We reserve the right to change this privacy policy at any time. We will update the version in the same place and recommend that you read the Privacy Policy on a regular basis.

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Created with the kind support of Dieter macht den Datenschutz

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