Make Ecom Work

Site Notice / Imprint
Only ADs OÜ,
Sepapaja 6
15551 Talinn

Estonia

Represented by: 
Nicolas Hoffmann
Contact 
Phone: +1(347)305-6450
E-mail: nicolas@makeecomwork.com

VAT ID 
Sales tax identification number according to Sect. 27 a of the Sales Tax Law: EE102405532

EU dispute resolution 
The European Commission provides a platform for online dispute resolution (ODR): https://ec.europa.eu/consumers/odr/.
Our e-mail address can be found above in the site notice. 
Dispute resolution proceedings in front of a consumer arbitration board 
We are not willing or obliged to participate in dispute resolution proceedings in front of a consumer arbitration board. 



Privacy Policy 
1. An overview of data protection General information 
The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy. 

Data recording on this website

Who is the responsible party for the recording of data on this website (i.e., the “controller”)? 
The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy. 


How do we record your data? 
We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form. 
Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website. 

What are the purposes we use your data for? 
A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns. 
What rights do you have as far as your information is concerned? 
You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency. 
Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues. 

Analysis tools and tools provided by third parties 
There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs. 
For detailed information about these analysis programs please consult our Data Protection Declaration below. 

2. Hosting and Content Delivery Networks (CDN) 
We are hosting the content of our website at the following provider: 

External Hosting 
This website is hosted externally. Personal data collected on this website are stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site. 
The external hosting serves the purpose of fulfilling the contract with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of secure, fast, and efficient provision of our online services by a professional provider (Art. 6(1)(f) GDPR). If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6 (1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user's end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time. 
Our host(s) will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data. 
We are using the following host(s): 
Clickfunnels
Etison LLC
3443 W. Bavaria St., Eagle, Idaho 83616 

Cloudflare 
We use the “Cloudflare” service provided by Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA. (hereinafter referred to as “Cloudflare”). 
Cloudflare offers a content delivery network with DNS that is available worldwide. As a result, the information transfer that occurs between your browser and our website is technically routed via 
Cloudflare’s network. This enables Cloudflare to analyze data transactions between your browser and our website and to work as a filter between our servers and potentially malicious data traffic from the Internet. In this context, Cloudflare may also use cookies or other technologies deployed to recognize Internet users, which shall, however, only be used for the herein described purpose. 
The use of Cloudflare is based on our legitimate interest in a provision of our website offerings that is as error free and secure as possible (Art. 6(1)(f) GDPR). 
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:
https://www.cloudflare.com/privacypolicy/. 
For more information on Cloudflare’s security precautions and data privacy policies, please follow this link: https://www.cloudflare.com/privacypolicy/. 

Data processing 
We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR. 

Google Cloud CDN 
We use the Google Cloud CDN content delivery network. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. 
Google offers a globally distributed content delivery network. Technically, the transfer of information between your browser and our website is routed through the Google network. This enables us to increase the global accessibility and performance of our website. 
The use of Google Cloud CDN is based on our legitimate interest in the most error-free and secure provision of our website (Art. 6(1)(f) GDPR). 
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://cloud.google.com/terms/eu-model-contract-clause. 
You can find more information about Google Cloud CDN here: https://cloud.google.com/cdn/docs/overview?hl=en. 

Data processing 
We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR. 

3. General information and mandatory information Data protection 
The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration. 
Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected. 
We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access. 
Information about the responsible party (referred to as the “controller” in the GDPR) 
The data processing controller on this website is: 
Only ADs OÜ,
Sepapaja, 6
15551 Talinn
Estonia
Phone: +1(347)305-6450 
E-mail: nicolas@makeecomwork.com
The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.). 

Storage duration 
Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply. 

General information on the legal basis for the data processing on this website 
If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TTDSG. The consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy. 

Information on data transfer to the USA and other non-EU countries 
Among other things, we use tools of companies domiciled in the United States or other from a data protection perspective non-secure non-EU countries. If these tools are active, your personal data may potentially be transferred to these non-EU countries and may be processed there. We must point out that in these countries, a data protection level that is comparable to that in the EU cannot be guaranteed. For instance, U.S. enterprises are under a mandate to release personal data to the security agencies and you as the data subject do not have any litigation options to defend yourself in court. Hence, it cannot be ruled out that U.S. agencies (e.g., the Secret Service) may process, analyze, and permanently archive your personal 
data for surveillance purposes. We have no control over these processing activities. 

Revocation of your consent to the processing of data 
A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation. 
Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR) 
IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21(1) GDPR). 
IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING AT ANY TIME. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21(2) GDPR).
 
Right to log a complaint with the competent supervisory agency 
In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses. 

Right to data portability 
You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.
 
Information about, rectification and eradication of data 
Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time. 

Right to demand processing restrictions 
You have the right to demand the imposition of restrictions as far as the processing of your personal data is 
concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases: 
In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data.
If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication. 
If you have raised an objection pursuant to Art. 21(1) GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data. 
If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to
protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU. 

SSL and/or TLS encryption 
For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line. 
If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties. 
Encrypted payment transactions on this website 
If you are under an obligation to share your payment information (e.g. account number if you give us the authority to debit your bank account) with us after you have entered into a fee-based contract with us, this information is required to process payments. 
Payment transactions using common modes of paying (Visa/MasterCard, debit to your bank account) are processed exclusively via encrypted SSL or TLS connections. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line. 
If the communication with us is encrypted, third parties will not be able to read the payment information you share with us. 

Rejection of unsolicited e-mails 
We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in our Site Notice to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages. 

4. Recording of data on this website Cookies 
Our websites and pages use what the industry refers to as “cookies.” Cookies are small data packages that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser. 
In some cases, it is possible that third-party cookies are stored on your device once you enter our site (third- party cookies). These cookies enable you or us to take advantage of certain services offered by the third party (e.g., cookies for the processing of payment services). 
Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g., the shopping cart function or the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages. 
Cookies, which are required for the performance of electronic communication transactions, or for the provision of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error free and optimized provision of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies has been requested, processing occurs exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TTDSG); this consent may be revoked at any time. 
You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited. 
In the event that third-party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.
 
Use of Chatbots 
We use chatbots to communicate with you. Chatbots have the capability to respond to your questions and other entries without the assistance of humans. To do this, chatbots analyze your entries and other data to give matching responses (e.g., names, email addresses and other contact information, customer numbers and other identification, orders, and chat progresses). The chatbot can also register your IP address, log files, location information and other meta data. The data is archived on the servers of the chatbot provider. 
It is possible to generate user profiles based on the recorded data. Moreover, the data can be used to display interest-related advertising if the other legal requirements are met (in particular if consent has been obtained). Moreover, it is possible to link chatbots to analytical and advertising tools. 
The recorded data can also be used to improve our chatbots and their response patterns (machine learning). 
We or the chatbot operator retain the data you enter until you ask us to delete it, revoke your consent to archive it or if the purpose for the data storage is no longer in effect (e.g., once your inquiry has been fully processed). This does not affect mandatory statutory provisions – in particular, retention time frames. 
The legal basis for the use of chatbots is Art. 6(1)(b) GDPR, if the chatbot is used to negotiate a contract or in conjunction with the fulfillment of a contract. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time. In all other cases, the use is based on our legitimate interest in the most effective client communication possible (Art. 6(1)(f) GDPR). 
We use the following chatbots: 

ManyChat 
The provider is ManyChat, Inc., 535 Everett Ave, Palo Alto, CA 94301, USA (hereinafter referred to as ManyChat). 
ManyChat processes, among other things, publicly viewable information from your social media profiles, your navigation behavior on our website, your chat history, other data entered and log data (IP address, browser used, etc.) as part of the interaction with you. 
The data privacy declaration of ManyChat can be found here: https://manychat.com/privacy_statement.html and https://manychat.com/privacy.html. 
The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: 
https://manychat.com/privacy.html

Data processing 
We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR. 

5. Analysis tools and advertising Google Analytics 
This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. 
Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. This data is assigned to the respective end device of the user. An assignment to a user-ID does not take place. 
Furthermore, Google Analytics allows us to record your mouse and scroll movements and clicks, among other things. Google Analytics uses various modeling approaches to augment the collected data sets and uses machine learning technologies in data analysis. 
Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the user behavior patterns (e.g., cookies or device fingerprinting). The website use information recorded by Google is, as a rule transferred to a Google server in the United States, where it is stored. 
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time. 
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/. 

Browser plug-in 
You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link:
https://tools.google.com/dlpage/gaoptout?hl=en. 
For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at:
https://support.google.com/analytics/answer/6004245?hl=en. 

Contract data processing 
We have executed a contract data processing agreement with Google and are implementing the stringent provisions of the German data protection agencies to the fullest when using Google Analytics. 

Hotjar 
This website utilizes Hotjar. The provider is Hotjar Ltd., Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Europe (website:
https://www.hotjar.com). 
Hotjar is a tool used to analyze your user patterns on this website. Hotjar allows us to for instance record your mouse and scroll movements as well as your click. During this process, Hotjar also has the capability to determine how long your cursor remained in a certain position. Based on this information, Hotjar compiles so-called Heatmaps, that make possible to determine which parts of the website the website visitor reviews with preference. 
We are also able to determine how long you have stayed on a page of this website and when you left. We can also determine at which point you suspended making entries into a contact form (so-called conversion funnels). 
Furthermore, Hotjar can be deployed to obtain direct feedback from website visitors. This function aims at the improvement of the website offerings of the website operator. 
Hotjar uses technologies that make it possible to recognize the user for the purpose of analyzing the user patterns (e.g., cookies or the deployment of device fingerprinting). 
If your approval (consent) has been obtained the use of the abovementioned service shall occur on the basis of Art. 6(1)(a) GDPR and § 25 TTDSG (German Telecommunications Act). Such consent may be revoked at any time. If your consent was not obtained, the use of the service will occur on the basis of Art. 6(1)(f) GDPR; the website operator has a legitimate interest in the analysis of user patterns to optimize both, the web presentation and the operator’s advertising activities. 

Deactivation of Hotjar 
If you would like to deactivate the recording of data by Hotjar, please click on the link below and follow the instructions provided under the link:
https://www.hotjar.com/policies/do-not-track/. 
Please keep in mind that you will have to separately deactivate Hotjar for every browser and every device. 
For more detailed information about Hotjar and the data to be recorded, please consult the Data Privacy Declaration of Hotjar under the following link:
https://www.hotjar.com/privacy. 
Data processing 
We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR. 

Google Ads 
The website operator uses Google Ads. Google Ads is an online promotional program of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. 
Google Ads enables us to display ads in the Google search engine or on third-party websites, if the user enters certain search terms into Google (keyword targeting). It is also possible to place targeted ads based on the user data Google has in its possession (e.g., location data and interests; target group targeting). As the website operator, we can analyze these data quantitatively, for instance by analyzing which search terms resulted in the display of our ads and how many ads led to respective clicks. 
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time. 
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:
https://policies.google.com/privacy/frameworks and https://privacy.google.com/businesses/controllerterms/mccs/. 

Google Ads Remarketing 
This website uses the functions of Google Ads Remarketing. The provider of these solutions is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. 
With Google Ads Remarketing, we can assign people who interact with our online offering to specific target groups in order to subsequently display interest-based advertising to them in the Google advertising network (remarketing or retargeting). 
Moreover, it is possible to link the advertising target groups generated with Google Ads Remarketing to device encompassing functions of Google. This makes it possible to display interest-based customized advertising messages, depending on your prior usage and browsing patterns on a device (e.g., cell phone) in a manner tailored to you as well as on any of your devices (e.g., tablet or PC). 
If you have a Google account, you have the option to object to personalized advertising under the following link:
https://www.google.com/settings/ads/onweb/. 
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time. 
For further information and the pertinent data protection regulations, please consult the Data Privacy Policies of Google at:
https://policies.google.com/technologies/ads?hl=en. 

Formation of Target Groups with Customer Reconciliation 
For the formation of target groups, we use, among other things, the Google Ads Remarketing customer reconciliation feature. To achieve this, we transfer certain customer data (e.g., email addresses) from our customer lists to Google. If the respective customers are Google users and are logged into their Google accounts, matching advertising messages within the Google network (e.g., YouTube, Gmail or in a search engine) are displayed for them to view. 

Google Conversion-Tracking 
This website uses Google Conversion Tracking. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. 
With the assistance of Google Conversion Tracking, we are in a position to recognize whether the user has completed certain actions. For instance, we can analyze the how frequently which buttons on our website have been clicked and which products are reviewed or purchased with particular frequency. The purpose of this information is to compile conversion statistics. We learn how many users have clicked on our ads and which actions they have completed. We do not receive any information that would allow us to personally identify the users. Google as such uses cookies or comparable recognition technologies for identification purposes. 
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time. 
For more information about Google Conversion Tracking, please review Google’s data protection policy at: 
https://policies.google.com/privacy?hl=en 


TikTok Pixel

We use the "TikTok pixel" of the social network TikTok, which is operated by TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland ("TikTok"). With the help of the TikTok pixel, it is possible for TikTok to determine the visitors to our online store as a target group for the display of advertisements (so-called "TikTok Ads"). Accordingly, we use the TikTok pixel to display the TikTok ads placed by us only to those TikTok users who have also shown an interest in our online offer or who have certain characteristics that we transmit to TikTok. The TikTok pixel also allows us to statistically analyze the TikTok ads that are served. Data processing by TikTok is carried out within the framework of TikTok's Data Use Policy. For specific information and details about the TikTok Pixel and how it works, please visit the TikTok help section: https://www.tiktok.com/legal/privacy-policy?lang=en The use of the TikTok Pixel as well as the storage of "conversion cookies" is based on Art. 6 (1) lit. a DSGVO. You can object to the data collection by the TikTok pixel and use of your data to display TikTok ads. You can find an opt-out option in our cookie settings.

Improvely

We have integrated components of Improvely.com (hereinafter referred to as the “Improvely”). Improvely compares relevant Internet content to data from prospective customers and their profiles, to enable Internet site operators to speak more effectively and specifically to prospects and customers. The purpose of Improvely is to increase the conversion rate of prospective customers and thus increase the turnover of an Internet site operator.
The operating company of Improvely  is http://www.awio.com/ 219 Chatham Place, Lansdale, PA 19446 • 888-304-5864 UNITED STATES.
Eloqua sets a cookie on the information technology system of the data subject. The definition of cookies is explained above. Improvely will use the data collected from our website and information on behalf of the controller to analyze user behaviour of the data subject, who has used our Internet page. In addition, Improvely will use the data to create reports on user activities on our behalf, as well as to provide other services for our enterprise, which are in relation to the use of our website.
The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the Internet browser used would also prevent Improvely from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Improvely may be deleted at any time via a web browser or other software programs.
In addition, the data subject has the possibility of objecting to a collection of data relating to a use of this Internet site that are generated by the Improvely cookie as well as the processing of these data by Improvely and the chance to preclude any such.

Facebook Pixel 
To measure conversion rates, this website uses the visitor activity pixel of Facebook. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Facebook’s statement the collected data will be transferred to the USA and other third-party countries too. 
This tool allows the tracking of page visitors after they have been linked to the website of the provider after clicking on a Facebook ad. This makes it possible to analyze the effectiveness of Facebook ads for statistical and market research purposes and to optimize future advertising campaigns. 
For us as the operators of this website, the collected data is anonymous. We are not in a position to arrive at any conclusions as to the identity of users. However, Facebook archives the information and processes it, so that it is possible to make a connection to the respective user profile and Facebook is in a position to use the data for its own promotional purposes in compliance with the 
Facebook Data Usage Policy. This enables Facebook to display ads on Facebook pages as well as in locations outside of Facebook. We as the operator of this website have no control over the use of such data. 
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time. 
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum und https://de-de.facebook.com/help/566994660333381. 
Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook. The processing by Facebook that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found under: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook tool and for the privacy-secure implementation of the tool on our website. Facebook is responsible for the data security of Facebook products. You can assert data subject rights (e.g., requests for information) regarding data processed by Facebook directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook. 
In Facebook’s Data Privacy Policies, you will find additional information about the protection of your privacy at:
https://www.facebook.com/about/privacy/. 
You also have the option to deactivate the remarketing function “Custom Audiences” in the ad settings section under
https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. To do this, you first have to log into Facebook. 
If you do not have a Facebook account, you can deactivate any user-based advertising by Facebook on the website of the European Interactive Digital Advertising Alliance: http://www.youronlinechoices.com/de/praferenzmanagement/. 

Facebook Conversion API 
We have integrated Facebook Conversion API into this website. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. However, based on the information provided by Facebook, the recorded data is also transmitted to the United States and other Non-EU and Non- EEZ countries. 
Facebook Conversion API enables us to record the interactions of our website visitors with our website and to share this information with Facebook to improve the promotional performance with Facebook. 
To do this, in particular the time you accessed the site, the website you accessed, your IP address and your user agent, as well as, if applicable, other specific data (e.g., purchased products, value of the shopping cart and currency) are tracked. For a complete overview of the tracked data, please visit: https://developers.facebook.com/docs/marketing-api/conversions-api/parameters. 
The use of this service occurs on the basis of your consent pursuant to Art. 6 Sect. 1 lit. a GDPR and § 25 Sect. 1 TTDSG. You may revoke your consent at any time. 
If personal data is collected on our website with the assistance of the tool described herein and if it is shared with Facebook, we and Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland shall be jointly responsible for the processing of your data, i.e., we are the data controllers (Art. 26 GDPR). This shared responsibility is limited exclusively to the recording of your data and its sharing with Facebook. The processing that occurs after the data has been shared with Facebook is not part of this shared responsibility. The obligations we share responsibility for have been documented in an agreement on joint processing. The concrete wording of this agreement can be found at: https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for the provision of the data protection information when using the Facebook tool and for the data protection law compliant secure implementation of the tool on our website. Facebook is liable for the data security of Facebook products. You may request information on your rights as a data subject (e.g., request for information) related to the data processed by Facebook directly from Facebook. If you claim any data subject rights with us, we are required to forward your request to Facebook. 
The transfer of data to the United States is based on the standard contract clauses of the EU commission. For details please visit:
https://www.facebook.com/legal/EU_data_transfer_addendum and https://de-de.facebook.com/help/566994660333381. 
In Facebook’s data privacy policy, you will find additional information pertaining to the protection of your privacy:
https://de-de.facebook.com/about/privacy/. 
Data processing 
We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR.
 
Facebook Custom Audiences 
We use Facebook Custom Audiences. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. 
Whenever you visit or use our website and apps, utilize our portfolio (e.g., participation in sweepstakes), transfer data to us or interact with the Facebook content of our company, we record related personal data. In the event that you have given us your consent to the use of Facebook Custom Audiences, we will share these data with Facebook to put Facebook in a position to send you compatible ads. These data may also be used to defined target audiences (Lookalike Audiences). 
Facebook processes these data as our contract processor. For details, please consult the user agreement of Facebook:
https://www.facebook.com/legal/terms/customaudience. 
The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TTDSG. You may revoke your consent at any time. 
The transfer of date to the USA is based on the standard contract clauses of the EU Commission. For details please see:
https://www.facebook.com/legal/terms/customaudience and https://www.facebook.com/legal/terms/dataprocessing. 

6. Newsletter Newsletter data 
If you would like to receive the newsletter offered on the website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter. Further data is not collected or only on a voluntary basis. For the handling of the newsletter, we use newsletter service providers, which are described below. 

ActiveCampaign 
This website uses ActiveCampaign for sending newsletters. Provider is ActiveCampaign, Inc., 1 N Dearborn, 5th Floor Chicago, Illinois 60602, United States. 
ActiveCampaign is a service with which, among other things, the dispatch of newsletters can be organized and analyzed. The data you enter for the purpose of subscribing to the newsletter will be stored on the servers of ActiveCampaign in the United States. 

Data analysis by ActiveCampaign 
With the help of ActiveCampaign we are able to analyze our newsletter campaigns. For example, we can see if a newsletter message has been opened and which links have been clicked. In this way, we can determine which links have been clicked particularly frequently. 
We can also see whether certain previously defined actions were performed after opening / clicking (conversion rate). For example, we can tell if you have made a purchase after clicking on the newsletter. 
ActiveCampaign also allows us to classify newsletter recipients into different categories („clusters”). For example, the newsletter recipients can be subdivided according to age, gender, or place of residence. In this way, the newsletters can be better adapted to the respective target groups. If you do not want an analysis by ActiveCampaign, you have to unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every newsletter message. Furthermore, you can unsubscribe from the newsletter directly on the website. 
Detailed information about the functions of ActiveCampaign can be found in the following link: https://www.activecampaign.com/email-marketing. 
The privacy policy of ActiveCampaign can be found at: https://www.activecampaign.com/privacy-policy. 

Legal Basis 
Data processing is based on your agreement (Art. 6(1)(a) GDPR). You can revoke this agreement at any time. The legality of the data processing operations that have already taken place remains unaffected by the revocation. 
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:
https://www.activecampaign.com/legal/scc and https://www.activecampaign.com/de/legal/gdpr-updates/privacy-shield. 

Storage period 
The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected. 
After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist, if such action is necessary to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest. 

Data processing 
We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR. 

7. Plug-ins and Tools

Vimeo Without Tracking (Do-Not-Track) 
This website uses plugins of the Vimeo video portal. The provider is Vimeo Inc., 555 West 18th Street, New York, New York 10011, USA. 
Whenever you visit one of our pages featuring Vimeo videos, a connection with the servers of Vimeo is established. In conjunction with this, the Vimeo server receives information about which of our sites you have visited. Vimeo also receives your IP address. However, we have set up Vimeo in such a way that Vimeo 
cannot track your user activities and does not place any cookies. 
We use Vimeo to make our online presentation attractive for you. This is a legitimate interest on our part pursuant to Art. 6(1)(f) GDPR. If a respective declaration of consent was requested (e.g. concerning the storage of cookies), processing shall occur exclusively on the basis of Art. 6(1)(a) GDPR; the given consent may be revoked at any time. 
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission and, according to Vimeo, on “legitimate business interests”. Details can be found here: https://vimeo.com/privacy. 
For more information on the handling of user data, please consult Vimeo’s data privacy policy at: 
https://vimeo.com/privacy 

Tidio 
We use Tidio (hereinafter referred to as “Tidio”) for the processing of user inquiries via our support channels or live chat systems. The provider is Tidio LLC, 180 Steuart St, CA 94119, San Francisco, California, USA. 
Messages you send to us, can be stored in the Tidio ticket system or our employees respond to them in the live chat system. If you communicate with us via Tidio, all data you have entered from the start of the chat (i.e., name or chat ID, address, and phone number) as well as your IP address, your country of origin, the utilized browser and device, the accessed website and the exchanges messages are consolidated in a profile and saved on Tidio’s servers. 
Messages that are addressed to us remain in our possession until you ask us to delete them or the reason for the data storage is no longer effective (e. g. after your inquiry has been processed). This shall be without prejudice to any statutory provisions – especially statutory mandatory retention obligations. 
We also use Tidio to analyze the patterns of our users. This allows us, for instance, to determine how many users have accessed our website or completed the contact form. 
The use of Tidio is based on Art. 6(1)(f) GDPR. We have a legitimate interest in marketing activities that are as effective as possible. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TTDSG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TTDSG. This consent can be revoked at any time. 
For more information, please consult the data privacy declaration of Tidio: https://www.tidio.com/privacy-policy/. 

Data processing 
We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract mandated by data privacy laws that guarantees that they process personal data of our website visitors only based on our instructions and in compliance with the GDPR. 

8. eCommerce and payment service providers 
Processing of Customer and Contract Data 
We collect, process, and use personal customer and contract data for the establishment, content arrangement and modification of our contractual relationships. Data with personal references to the use of this website (usage data) will be collected, processed, and used only if this is necessary to enable the user to use our services or required for billing purposes. The legal basis for these processes is Art. 6(1)(b) GDPR. 
The collected customer data shall be deleted upon completion of the order or termination of the business relationship and upon expiration of any existing statutory archiving periods. This shall be without prejudice to any statutory archiving periods. 

Data transfer upon closing of contracts for services and digital content 
We share personal data with third parties only if this is necessary in conjunction with the handling of the contract; for instance, with the financial institution tasked with the processing of payments. 
Any further transfer of data shall not occur or shall only occur if you have expressly consented to the transfer. Any sharing of your data with third parties in the absence of your express consent, for instance for advertising purposes, shall not occur. 
The basis for the processing of data is Art. 6(1)(b) GDPR, which permits the processing of data for the fulfilment of a contract or for pre-contractual actions. 

Payment services 
We integrate payment services of third-party companies on our website. When you make a purchase from us, your payment data (e.g. name, payment amount, bank account details, credit card number) are processed by the payment service provider for the purpose of payment processing. For these transactions, the respective contractual and data protection provisions of the respective providers apply. The use of the payment service providers is based on Art. 6(1)(b) GDPR (contract processing) and in the interest of a smooth, convenient, and secure payment transaction (Art. 6(1)(f) GDPR). Insofar as your consent is requested for certain actions, Art. 6(1)(a) GDPR is the legal basis for data processing; consent may be revoked at any time for the future. 
We use the following payment services / payment service providers within the scope of this website: 

PayPal 
The provider of this payment service is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal”). 
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.paypal.com/de/webapps/mpp/ua/pocpsa-full. 
Details can be found in PayPal’s privacy policy: https://www.paypal.com/de/webapps/mpp/ua/privacy-full. 

Stripe 
The provider for customers within the EU is Stripe Payments Europe, Ltd,1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland (hereinafter “Stripe”). 
Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:
https://stripe.com/de/privacy and https://stripe.com/de/guides/general-data-protection-regulation. 
Details can be found in Stripe’s Privacy Policy at the following link: https://stripe.com/de/privacy. 

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