Privacy Policy

Introduction

With the following privacy policy, we would like to inform you about the types of your personal data (hereinafter also referred to as “data” for short) that we process, for what purposes and to what extent. The privacy policy applies to all processing of personal data carried out by us, both in the context of providing our services and in particular on our websites, mobile applications, as well as within external online presences, such as our social media profiles (hereinafter collectively referred to as “Online Offer”).

The terms used are not gender-specific.

Status: [Please insert current date]

Contents Overview

Responsible Person

Name: Stefan Wissert
Address: Kirchstr. 11, 79361 Sasbach am Kaiserstuhl, Germany
E-mail: info@vanillekiste.de
Website: vanillabox.eu

Overview of Processing

The following overview summarizes the types of data processed and the purposes of their processing, and refers to the data subjects.

Types of Data Processed

  • Inventory data (e.g. names, addresses)
  • Content data (e.g. entries in online forms)
  • Contact data (e.g. e-mail, telephone numbers)
  • Meta/communication data (e.g. device information, IP addresses)
  • Usage data (e.g. web pages visited, interest in content, access times)
  • Contract data (e.g., subject of contract, term, customer category)
  • Payment data (e.g. bank details, invoices, payment history)

Categories of Data Subjects

  • Business and contractual partners
  • Interested parties
  • Communication partners
  • Customers
  • Users (e.g. website visitors, users of online services)

Purposes of Processing

  • Providing our online services and user experience
  • Visit action evaluation
  • Office and organization procedures
  • Contact requests and communication
  • Security measures
  • Provision of contractual services and customer service
  • Managing and responding to requests

Relevant Legal Bases

In the following, we share the legal bases of the General Data Protection Regulation (GDPR) on the basis of which we process personal data. Please note that in addition to the regulations of the GDPR, the national data protection regulations in your or our country of residence and domicile may apply. Furthermore, should more specific legal bases be relevant in individual cases, we will inform you of these in the privacy policy.

  • Consent (Art. 6 para. 1 p. 1 lit. a. GDPR) – The data subject has given consent to the processing of personal data concerning him or her for one or more specific purposes.
  • Contractual performance and pre-contractual requests (Art. 6 para. 1 p. 1 lit. b. GDPR) – Processing is necessary for the performance of a contract to which the data subject is party or for the performance of pre-contractual measures carried out at the data subject’s request.
  • Legal obligation (Art. 6 para. 1 p. 1 lit. c. GDPR) – Processing is necessary for compliance with a legal obligation to which the controller is subject.
  • Legitimate interests (Art. 6 para. 1 p. 1 lit. f. GDPR) – Processing is necessary for the purposes of protecting the legitimate interests of the controller or of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data.

Security Measures

We take appropriate technical and organizational measures in accordance with the law, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

The measures include, in particular, securing the confidentiality, integrity and availability of data by controlling physical and electronic access to the data as well as the access, input, transfer, ensuring availability and their separation. Furthermore, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data, and responses to data compromise. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software as well as procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

SSL encryption (https): To protect your data transmitted via our online offer, we use SSL encryption. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Transmission and Disclosure of Personal Data

In the course of our processing of personal data, it happens that the data are transmitted to or disclosed to other entities, companies, legally independent organizational units or persons. Recipients of this data may include, for example, payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such cases, we comply with the legal requirements and, in particular, conclude appropriate contracts or agreements that serve to protect your data with the recipients of your data.

Data Processing in Third Countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, entities or companies, this will only be done in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we process or allow the data to be processed only in third countries with a recognized level of data protection, contractual obligation by so-called standard protection clauses of the EU Commission, in the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR).

Use of Cookies

Cookies are small text files, or other memory tags, that store information on terminal devices and read information from terminal devices. E.g. to store the login status in a user account, a shopping cart content in an e-shop, the content accessed or used functions of an online offer. Cookies can further be used for various purposes, e.g. for purposes of functionality, security and comfort of online offers as well as the creation of analyses of visitor flows.

Notes on consent: We use cookies in accordance with the statutory provisions. Therefore, we obtain prior consent from users, except where this is not required by law. In particular, consent is not required if the storage and reading of information, including cookies, are absolutely necessary to provide the user with a telemedia service (i.e. our online offer) expressly requested by them. The revocable consent will be clearly communicated to the users and will contain the information about the respective cookie usage.

Notes on legal bases under data protection law: On which legal basis under data protection law we process users’ personal data using cookies depends on whether we ask users for consent. If users consent, the legal basis for the processing of your data is the declared consent. Otherwise, the data processed with the help of cookies is processed on the basis of our legitimate interests (e.g. in a business operation of our online offer and improvement of its usability) or, if this is done in the context of the fulfillment of our contractual obligations, if the use of cookies is necessary to fulfill our contractual obligations.

Storage period: In terms of storage period, the following types of cookies are distinguished:

  • Temporary cookies (also: session cookies): Temporary cookies are deleted at the latest after a user has left an online offer and closed his end device (e.g. browser or mobile app).
  • Permanent cookies: Permanent cookies remain stored even after the terminal device is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the user data collected with the help of cookies can be used for reach measurement. Unless we provide users with explicit information about the type and storage duration of cookies (e.g., as part of obtaining consent), users should assume that cookies are permanent and that the storage period can be up to two years.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke any consent given or to object to the processing of your data by cookie technologies (collectively referred to as “opt-out”). You can initially declare your objection by means of your browser settings, e.g. by deactivating the use of cookies (whereby this may also restrict the functionality of our online offer).

Commercial and Business Services

We process data of our contractual and business partners, e.g. customers and prospective customers (collectively referred to as “contractual partners”) in the context of contractual and comparable legal relationships as well as related measures and in the context of communication with contractual partners (or pre-contractual), e.g. to answer inquiries.

We process this data to fulfill our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as for business organization. Within the framework of applicable law, we only disclose the data of contractual partners to third parties to the extent that this is necessary for the aforementioned purposes or for the fulfillment of legal obligations or with the consent of the data subjects.

We inform the contractual partners which data is required for the aforementioned purposes before or during data collection, e.g. in online forms, by means of special marking (e.g. colors) or symbols (e.g. asterisks or similar), or in person.

We delete the data after the expiry of legal warranty and comparable obligations, i.e. generally after 4 years, unless the data is stored in a customer account, e.g. as long as it must be retained for legal archiving reasons (e.g. for tax purposes, generally 10 years).

Customer account: Contractual partners can create an account within our online offer (e.g. customer or user account, in short “customer account”). If registration of a customer account is required, contractual partners will be informed of this as well as of the information required for registration. Customer accounts are not public and cannot be indexed by search engines. In the course of registration and subsequent logins and use of the customer account, we store the IP addresses of the customers together with the access times in order to be able to prove registration and prevent any misuse of the customer account.

If customers have terminated their customer account, the data relating to the customer account will be deleted, unless their retention is required for legal reasons. It is the responsibility of customers to back up their data when their customer account is terminated.

Digital Products and Plugin Services: We process the data of our customers to enable them to select, purchase, download and use the selected WordPress plugins and related digital services, as well as their payment and delivery or execution. The required information is identified as such in the context of the order or comparable acquisition process and includes the information needed for delivery, or provision and billing, as well as contact information, so that any consultation can be held.

  • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • People concerned: Interested parties, business and contractual partners, customers.
  • Purposes of processing: Providing contractual services and customer service, contact requests and communications, office and organizational procedures, managing and responding to requests, security measures.
  • Legal basis: Contract performance and pre-contractual requests (Art. 6 para 1 p. 1 lit. b. GDPR), Legal obligation (Art. 6 para 1 p. 1 lit. c. GDPR), Legitimate interests (Art. 6 para 1 p. 1 lit. f. GDPR).

Payment Service Provider

In the context of contractual and other legal relationships, due to legal obligations or otherwise on the basis of our legitimate interests, we offer data subjects efficient and secure payment options and use PayPal as our payment service provider.

The data processed by PayPal includes inventory data, such as the name and address, bank data, such as account numbers or credit card numbers, passwords, TANs and checksums, as well as the contract, total and recipient-related information. The information is required to carry out the transactions. However, the data entered is only processed by PayPal and stored with them. I.e., we do not receive any account or credit card related information, but only information with confirmation or negative information of the payment.

For payment transactions, the terms and conditions and data protection notices of PayPal apply, which can be accessed within the respective websites or transaction applications. We refer to these likewise for the purpose of further information and assertion of revocation, information and other data subject rights.

  • Types of data processed: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contract data (e.g. subject matter of contract, term, customer category), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • People concerned: customers, prospective customers.
  • Purposes of processing: Provision of contractual services and customer service.
  • Legal basis: Contract performance and pre-contractual requests (Art. 6 para 1 p. 1 lit. b. GDPR), Legitimate interests (Art. 6 para 1 p. 1 lit. f. GDPR).

Services used and service providers:

  • PayPal: Payment services and solutions; Service provider: PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg; website: https://www.paypal.com; privacy policy: https://www.paypal.com/legalhub/paypal/privacy-full.

Provision of Online Services and Web Hosting

In order to provide our Online Offer securely and efficiently, we use the services of Hostinger web hosting provider from whose servers the Online Offer can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security services and technical maintenance services.

The data processed as part of the provision of the hosting offer may include all information relating to the users of our online offer, which is generated as part of the use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on each access to the server (so-called server log files). The server log files may include the address and name of the web pages and files accessed, date and time of access, data volumes transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files may be used on the one hand for security purposes, e.g. to prevent server overload (especially in the event of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the utilization of the servers and their stability.

  • Types of data processed: Content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • People Concerned: users (e.g., website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 para 1 p. 1 lit. f. GDPR).

Contact

When contacting us (for example, by contact form, e-mail, telephone or via social media), the information of the requesting persons is processed to the extent necessary to respond to the contact requests and any requested action.

The response to the contact requests in the context of contractual or pre-contractual relationships is carried out to fulfill our contractual obligations or to respond to (pre)contractual requests and otherwise on the basis of legitimate interests in responding to the requests.

  • Types of data processed: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. entries in online forms), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • People concerned: communication partners, interested parties.
  • Purposes of processing: contact requests and communication, management and response to requests.
  • Legal basis: Contract performance and pre-contractual requests (Art. 6 para 1 p. 1 lit. b. GDPR), Legitimate interests (Art. 6 para 1 p. 1 lit. f. GDPR).

Services used and service providers:

  • Contact form: If users contact us via our contact form, e-mail or other communication channels, we process the data communicated to us in this context to process the communicated request. For this purpose, we process personal data in the context of pre-contractual and contractual business relationships, insofar as this is necessary for their fulfillment, and otherwise on the basis of our legitimate interests as well as the interests of the communication partners in responding to the concerns and our statutory retention obligations.

Deletion of Data

The data processed by us will be deleted in accordance with legal requirements as soon as their consents permitted for processing are revoked or other permissions cease to apply (for example, if the purpose of processing this data has ceased to apply or it is not necessary for the purpose).

If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. I.e., the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law or whose storage is necessary for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person.

Further information on the deletion of personal data can further be provided in the context of the individual data protection notices of this privacy policy.

Changes and Updates to Privacy Policy

We ask you to regularly inform yourself about the content of our privacy policy. We will adapt the privacy statement as soon as the changes in the data processing activities we carry out make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this privacy statement, please note that the addresses may change over time and please check the information before contacting us.

Rights of Data Subjects

As a data subject, you are entitled to various rights under the GDPR, arising in particular from Articles 15 to 21 of the GDPR:

  • Right of objection: you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of Article 6(1)(e) or (f) of the GDPR; this also applies to profiling based on these provisions. If the personal data concerning you is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct marketing.
  • Right of revocation for consents: You have the right to revoke granted consents at any time.
  • Right of access: You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with legal requirements.
  • Right to rectification: You have the right, in accordance with the law, to request that the data concerning you be completed or that inaccurate data concerning you be rectified.
  • Right to erasure and restriction of processing: You have, in accordance with the law, the right to request that data concerning you be erased without undue delay, or alternatively, in accordance with the law, to request restriction of the processing of the data.
  • Right to data portability: You have the right to receive data relating to you, which you have provided to us, in a structured, common and machine-readable format in accordance with the legal requirements, or to demand its transfer to another responsible party.
  • Complaint to supervisory authority: You also have the right, in accordance with the law, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement, if you consider that the processing of personal data relating to you infringes the GDPR.

Definitions of Terms

This section provides you with an overview of the terms used in this Privacy Policy. Many of the terms are taken from the law and defined primarily in Article 4 of the GDPR. The legal definitions are binding. The following explanations, on the other hand, are primarily intended to aid understanding.

  • Personal data: “Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more particular characteristics that are an expression of that natural person’s physical, physiological, genetic, mental, economic, cultural or social identity.
  • Controller: A “controller” is the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.
  • Processing: “Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and includes virtually any handling of data, be it collection, analysis, storage, transmission or deletion.