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Privacy Policy |
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Effective Date: Sep 11, 2025 Last Update: Sep 11, 2025 |
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Preamble
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With
the following privacy policy we would like to inform you which types of your personal data
we process for which purposes and in which scope. The privacy policy applies to all
processing of personal data carried out by us, both in the context of providing our
services.
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Table of Contents
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Preamble
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Controller
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Contact
Information
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Categories
of Processed Data
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Purposes
of Processing
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Security
Precautions
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Transmission
of Personal Data
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International
Data Transfers
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Erasure
of Data
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Rights
of Data Subjects
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Use
of Cookies
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Provision of online Services and Web Hosting
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Communication
via Messenger
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Newsletter
and Electronic Communications
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Commercial
Communication by E-Mail, Postal Mail, Fax or Telephone
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Web
Analysis, Monitoring and Optimization
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Plugins
and Embedded Functions and Content
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Terminology
and Definitions
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Controller
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First
Name, surname/Company
P
VSTAR ENERGY (KENYA) COMPANY LIMITED
Street,
house no.
Fifth Avenue Ngong Road, Building: Fifth Avenue Office Suites.
Postcode,
City, Country
N
airobi West District, Kenya
E-mail
address:
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Contact Information
If you
have any queries or you want to exercise your rights under this privacy policy, you could
contact our staff as follows:
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Categories of Processed Data
We
may process the following types of personal data:
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Personal
information such as your name, ID number, date of birth, gender, phone number,
address;
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Family
background such as your house information, the number of people in your family, the name and
phone number of your families, the number of kids among them, and whether you have any
school age children;
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Your
job and the main source of your income, the average income monthly;
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Your
credit report from Metropol;
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Your
academic information;
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Y
our
demand and preference for products such as photovoltaic, radio and TV.
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Purposes of Processing
We
collect and process your personal data in order to operate, provide and improve the products
and services we provide to you. These purposes include:
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We
collect your personal information for website login, and to provide our products and
services, fulfill the contractual obligations, and ensur
the person using our products is the rightful owner;
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We
collect your phone number to contact requests and communication;
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We
collect your identity, family informaiton and income to assess credit (evaluating payment
ability of our customers);
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We
need your infromation to process the payment;
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We
collect other information to understand customer preferences;
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We
may conduct user profiling, but it will be anonymized;
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Direct
marketing.
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Security Precautions
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We
take appropriate technical and organisational measures in accordance with the legal
requirements, taking into account the state of the art, the costs of implementation and the
nature, scope, context and purposes of processing as well as the risk of varying likelihood
and severity for the rights and freedoms of natural persons, in order to ensure a level of
security appropriate to the risk.
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The
measures include, in particular, safeguarding the confidentiality, integrity and
availability of data by controlling physical and electronic access to the data as well as
access to, input, transmission, securing and separation of the data. In addition, we have
established procedures to ensure that data subjects' rights are respected, that data is
erased, and that we are prepared to respond to data threats rapidly. Furthermore, we take
the protection of personal data into account as early as the development or selection of
hardware, software and service providers, in accordance with the principle of privacy by
design and privacy by default.
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TLS/SSL
encryption (https): To protect the data of users transmitted via our online services, we use
TLS/SSL encryption. Secure Sockets Layer (SSL) is the standard technology for securing
internet connections by encrypting the data transmitted between a website or app and a
browser (or between two servers). Transport Layer Security (TLS) is an updated and more
secure version of SSL. Hyper Text Transfer Protocol Secure (HTTPS) is displayed in the URL
when a website is secured by an SSL/TLS certificate.
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Transmission of Personal Data
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In
the context of our processing of personal data, it may happen that the data is transferred
to other places, companies or persons or that it is disclosed to them. Recipients of this
data may include, for example, service providers commissioned with IT tasks. In the case of
business cooperation, other partners may also be included, such as installers, distributors,
logistics provider, solution
provider, sales agency, collection agency. In such cases, the legal requirements will be
respected and in particular corresponding contracts or agreements, which serve the
protection of your data, will be concluded with the recipients of your data.
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Data
Transmission within the Group of Companies: We may transfer personal data to other companies
within our group of companies or otherwise grant them access to this data. Insofar as this
disclosure is for administrative purposes, the disclosure of the data is based on our
legitimate business and economic interests (e.g. in pooling intragroup resources and
providing our services within our Group capacities), if it is necessary to fulfill our
contractual obligations or if the consent of the data subjects or otherwise a legal
permission is present.
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International Data Transfers
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If
we process data in a third country (i.e. outside Kenya) or the processing takes place in the
context of the use of third party services or disclosure or transfer of data to other
persons, bodies or companies, this will only take place in accordance with the legal
requirements. This mainly happen in case of data transmission within the Group of Companies,
and you hereby agree to the cross-border transfer in this case.
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Erasure of Data
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The
data processed by us will be erased in accordance with the statutory provisions as soon as
their processing is withdrawn or other permissions no longer apply (e.g. if the purpose of
processing this data no longer applies or they are not required for the purpose). If the
data is not deleted because they are required for other and legally permissible purposes,
their processing is limited to these purposes. This means that the data will be restricted
and not processed for other purposes. This applies, for example, to data that must be stored
for commercial or tax reasons or for which storage is necessary to assert, exercise or
defend legal claims or to protect the rights of another natural or legal person. In the
context of our information on data processing, we may provide users with further information
on the deletion and retention of data that is specific to the respective processing
operation.
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Rights of Data Subjects
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Rights
of the Data Subjects under the DPA (Data Protection Act): As data subject, you are entitled
to various rights under the DPA, which arise in particular from Articles 26 to 27 of the
DPA:
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Right to Object: You have the right, on grounds arising from your particular situation, to object
at any time to the processing of your personal data, including profiling based on those
provisions. Where personal data are processed for direct marketing purposes, you have
the right to object at any time to the processing of the personal data concerning you
for the purpose of such marketing, which includes profiling to the extent that it is
related to such direct marketing.
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Right of withdrawal for consents: You have the right to withdraw your consent at
any time. The withdrawal of consent shall not affect the lawfulness of processing based on
consent before its withdrawal.
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Right of access: You have the right to request confirmation as
to whether the data in question will be processed and to be informed of this data and to
receive further information and a copy of the data in accordance with the provisions of the
law.
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Right to rectification: You have the right, in accordance with the law,
to request the completion of the data concerning you or the rectification of the incorrect
data concerning you.
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Right to Erasure and Right to Restriction of Processing: In accordance with the statutory provisions,
you have the right to demand that the relevant data be erased immediately or, alternatively,
to demand that the processing of the data be restricted in accordance with the statutory
provisions.
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Complaint to the supervisory authority: In accordance with the law and without
prejudice to any other administrative or judicial remedy, you also have the right to lodge a
complaint with a data protection supervisory authority, in particular Office of the Data
Protection Commissioner (ODPC), if you consider that the processing of personal data
concerning you infringes the DPA.
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Use of Cookies
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Cookies
are small text files or other data records that store information on end devices and read
information from the end devices. For example, to store the login status in a user account,
the contents of a shopping cart in an e-shop, the contents accessed or the functions used.
Cookies can also be used for various purposes, e.g. for purposes of functionality, security
and convenience of online offers as well as the creation of analyses of visitor
flows.
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Information on consent: We use cookies in accordance with the statutory
provisions. Therefore, we obtain prior consent from users, except when it is not required by
law. In particular, consent is not required if the storage and reading of information,
including cookies, is strictly necessary in order to provide an information society service
explicitly requested by the subscriber or user. Essential cookies usually include cookies
with functions related to the display and operability of the online service, load balancing,
security, storage of users' preferences and choices or similar purposes related to the
provision of the main and secondary functions of the online service requested by users. The
revocable consent will be clearly communicated to the user and will contain the information
on the respective cookie use.
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Information on legal bases under data protection law: The legal basis under data protection law on
which we process users' personal data with the use of cookies depends on whether we ask
users for consent. If users consent, the legal basis for processing their data is their
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 services 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. For which purposes the cookies are processed by us, we do clarify in the course
of this privacy policy or in the context of our consent and processing
procedures.
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Retention period: With regard to the retention period, a
distinction is drawn between the following types of cookies:
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Temporary cookies (also known as "session cookies"): Temporary cookies are deleted at the latest
after a user has left an online service and closed his or her end device (i.e. browser or
mobile application).
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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, 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.
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General notes on withdrawal : Users can withdraw their consent they have
given at any time and object to the processing in accordance with legal requirements. Users
can restrict the use of cookies in their browser settings, among other options (although
this may also limit the functionality of our online offering).
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Provision of Online Services and Web Hosting
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We
process user data in order to be able to provide them with our online services. For this
purpose, we process the IP address of the user, which is necessary to transmit the content
and functions of our online services to the user's browser or terminal device.
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Processed data types: Usage data (e.g. websites visited, interest in
content, access times). Meta, communication and process data (e.g. IP addresses, time
information, identification numbers, consent status).
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Data subjects: Users (e.g. website visitors, users of online
services).
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Purposes of Processing: Provision of our online services and usability;
Information technology infrastructure (Operation and provision of information systems and
technical devices, such as computers, servers, etc.).). Security measures.
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Further information on processing methods, procedures and services used:
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Provision of online offer on rented hosting space: For the provision of our online services, we
use storage space, computing capacity and software that we rent or otherwise obtain from a
corresponding server provider (also referred to as a "web hoster").
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Collection of Access Data and Log Files: The access to our online services is logged in
the form of so-called "server log files". Server log files may include the address and name
of the web pages and files accessed, the 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 general rule, IP addresses and the
requesting provider. The server log files can be used for security purposes, e.g. to avoid
overloading the servers (especially in the case of abusive attacks, so-called DDoS attacks)
and to ensure the stability and optimal load balancing of the servers. Retention period: Log file information is stored for a maximum
period of 30 days and then deleted or anonymized. Data, the further storage of which is
necessary for evidence purposes, are excluded from deletion until the respective incident
has been finally clarified.
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Alibaba Cloud: Services in the field of the provision of
information technology infrastructure and related services (e.g. storage space and/or
computing capacities); Service provider: Alicloud (Germany) GmbH, Neue Rothofstraße
13 -19, 60313 Frankfurt am Main, Germany; Website: https://www.alibabacloud.com/.
Privacy Policy: https://www.alibabacloud.com/help/en/legal/latest/alibaba-cloud-international-website-privacy-policy.
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Communication via Messenger
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We
use messenger services for communication purposes and therefore ask you to observe the
following information regarding the functionality of the messenger services, encryption, use
of the metadata of the communication and your objection options.
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You
can also contact us by alternative means, e.g. telephone or e-mail. Please use the contact
options provided to you or use the contact options provided within our online
services.
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In
the case of encryption of content (i.e. the content of your message and attachments), we
point out that the communication content (i.e. the content of the message and attachments)
is encrypted end-to-end. This means that the content of the messages is not visible, not
even by the messenger service providers themselves. You should always use a current version
of the messenger service with activated encryption, so that the encryption of the message
contents is guaranteed.
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However,
we would like to point out to our communication partners that although messenger service
providers do not see the content, they can find out that and when communication partners
communicate with us and process technical information on the communication partner's device
used and, depending on the settings of their device, also location information (so-called
metadata).
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Information on Legal basis: If we ask communication partners for permission
before communicating with them via messenger services, the legal basis of our processing of
their data is their consent. Otherwise, if we do not request consent and you contact us, for
example, voluntarily, we use messenger services in our dealings with our contractual
partners and as part of the contract initiation process as a contractual measure and in the
case of other interested parties and communication partners on the basis of our legitimate
interests in fast and efficient communication and meeting the needs of our communication
partners for communication via messenger services. We would also like to point out that we
do not transmit the contact data provided to us to the messenger service providers for the
first time without your consent.
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Withdrawal, objection and deletion: You can withdraw your consent or object to
communication with us via messenger services at any time. In the case of communication via
messenger services, we delete the messages in accordance with our general data retention
policy (i.e. as described above after the end of contractual relationships, archiving
requirements, etc.) and otherwise as soon as we can assume that we have answered any
information provided by the communication partners, if no reference to a previous
conversation is to be expected and there are no legal obligations to store the messages to
prevent their deletion.
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Reservation of reference to other means of communication: Finally, we would like to point out that we
reserve the right, for reasons of your safety, not to answer inquiries about messenger
services. This is the case if, for example, internal contractual matters require special
secrecy or if an answer via the messenger services does not meet the formal requirements. In
such cases we refer you to more appropriate communication channels.
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Processed data types: Contact data (e.g. e-mail, telephone numbers);
Usage data (e.g. websites visited, interest in content, access times). Meta, communication
and process data (e.g. IP addresses, time information, identification numbers, consent
status).
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Data subjects: Communication partner (Recipients of e-mails,
letters, etc.).
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Purposes of Processing: Contact requests and communication. Direct
marketing (e.g. by e-mail or postal).
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Further information on processing methods, procedures and services used:
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WhatsApp: WhatsApp Messenger with end-to-end encryption;
Service provider: WhatsApp Ireland Limited, 4 Grand Canal Quay,
Dublin 2, D02 KH28, Ireland; Website:
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https://www.whatsapp.com/;
Privacy Policy: https://www.whatsapp.com/legal.
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Newsletter and Electronic Communications
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We
send newsletters, e-mails and other electronic communications (hereinafter referred to as
"newsletters") only with the consent of the recipient or a legal permission. Insofar as the
contents of the newsletter are specifically described within the framework of registration,
they are decisive for the consent of the user. Otherwise, our newsletters contain
information about our services and us.
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In
order to subscribe to our newsletters, it is generally sufficient to enter your e-mail
address. We may, however, ask you to provide a name for the purpose of contacting you
personally in the newsletter or to provide further information if this is required for the
purposes of the newsletter.
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Double opt-in procedure: The registration to our newsletter takes place
in general in a so-called Double-Opt-In procedure. This means that you will receive an
e-mail after registration asking you to confirm your registration. This confirmation is
necessary so that no one can register with external e-mail addresses.
The
registrations for the newsletter are logged in order to be able to prove the registration
process according to the legal requirements. This includes storing the login and
confirmation times as well as the IP address. Likewise the changes of your data stored with
the dispatch service provider are logged.
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Deletion and restriction of processing: We may store the unsubscribed email addresses
for up to three years based on our legitimate interests before deleting them to provide
evidence of prior consent. The processing of these data is limited to the purpose of a
possible defense against claims. An individual deletion request is possible at any time,
provided that the former existence of a consent is confirmed at the same time. In the case
of an obligation to permanently observe an objection, we reserve the right to store the
e-mail address solely for this purpose in a blocklist.
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The
logging of the registration process takes place on the basis of our legitimate interests for
the purpose of proving its proper course. If we commission a service provider to send
e-mails, this is done on the basis of our legitimate interests in an efficient and secure
sending system.
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Contents:
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Information
about us, our services, promotions and offers.
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Processed data types: Contact data (e.g. e-mail, telephone numbers).
Meta, communication and process data (e.g. IP addresses, time information, identification
numbers, consent status).
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Data subjects: Communication partner (Recipients of e-mails,
letters, etc.).
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Purposes of Processing: Direct marketing (e.g. by e-mail or
postal).
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Consent withdrawal: You can cancel the receipt of our newsletter at
any time by withdrawing your consent. You will find a link to cancel the newsletter either
at the end of each newsletter or you can otherwise use one of the contact options listed
above, preferably e-mail.
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Commercial Communication by E-Mail, Postal Mail, Fax or Telephone
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We
process personal data for the purposes of promotional communication, which may be carried
out via various channels, such as e-mail, telephone, post or fax, in accordance with the
legal requirements.
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The
recipients have the right to withdraw their consent at any time or to object to the
advertising communication at any time.
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After
revocation or objection, we store the data required to prove the past authorization to
contact or send up to three years from the end of the year of revocation or objection on the
basis of our legitimate interests. The processing of this data is limited to the purpose of
a possible defense against claims. Based on the legitimate interest to permanently observe
the revocation, respectively objection of the users, we further store the data necessary to
avoid a renewed contact (e.g. depending on the communication channel, the e-mail address,
telephone number, name).
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Processed data types: Contact data (e.g. e-mail, telephone
numbers).
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Data subjects: Communication partner (Recipients of e-mails,
letters, etc.).
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Purposes of Processing: Direct marketing (e.g. by e-mail or
postal).
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Web Analysis, Monitoring and Optimization
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Web
analysis is used to evaluate the visitor traffic on our website and may include the
behaviour, interests or demographic information of users, such as age or gender, as
pseudonymous values. With the help of web analysis we can e.g. recognize, at which time our
online services or their functions or contents are most frequently used or requested for
repeatedly, as well as which areas require optimization.
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In
addition to web analysis, we can also use test procedures, e.g. to test and optimize
different versions of our online services or their components.
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Unless
otherwise stated below, profiles, i.e. data aggregated for a usage process, can be created
for these purposes and information can be stored in a browser or in a terminal device and
read from it. The information collected includes, in particular, websites visited and
elements used there as well as technical information such as the browser used, the computer
system used and information on usage times. If users have agreed to the collection of their
location data from us or from the providers of the services we use, location data may also
be processed.
Unless
otherwise stated below, profiles, that is data summarized for a usage process or user, may
be created for these purposes and stored in a browser or terminal device (so-called
"cookies") or similar processes may be used for the same purpose. The information collected
includes, in particular, websites visited and elements used there as well as technical
information such as the browser used, the computer system used and information on usage
times. If users have consented to the collection of their location data or profiles to us or
to the providers of the services we use, these may also be processed, depending on the
provider.
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The
IP addresses of the users are also stored. However, we use any existing IP masking procedure
(i.e. pseudonymisation by shortening the IP address) to protect the user. In general, within
the framework of web analysis, A/B testing and optimisation, no user data (such as e-mail
addresses or names) is stored, but pseudonyms. This means that we, as well as the providers
of the software used, do not know the actual identity of the users, but only the information
stored in their profiles for the purposes of the respective processes.
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Processed data types: Usage data (e.g. websites visited, interest in
content, access times). Meta, communication and process data (e.g. IP addresses, time
information, identification numbers, consent status).
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Data subjects: Users (e.g. website visitors, users of online
services).
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Purposes of Processing: Web Analytics (e.g. access statistics,
recognition of returning visitors). Profiles with user-related information (Creating user
profiles).
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Security measures: IP Masking (Pseudonymization of the IP
address).
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Plugins and Embedded Functions and Content
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Within
our online services, we integrate functional and content elements that are obtained from the
servers of their respective providers (hereinafter referred to as "third-party providers").
These may, for example, be graphics, videos or city maps (hereinafter uniformly referred to
as "Content").
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The
integration always presupposes that the third-party providers of this content process the IP
address of the user, since they could not send the content to their browser without the IP
address. The IP address is therefore required for the presentation of these contents or
functions. We strive to use only those contents, whose respective offerers use the IP
address only for the distribution of the contents. Third parties may also use so-called
pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing
purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on
the pages of this website. The pseudonymous information may also be stored in cookies on the
user's device and may include technical information about the browser and operating system,
referring websites, visit times and other information about the use of our website, as well
as may be linked to such information from other sources.
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Processed data types: Usage data (e.g. websites visited, interest in
content, access times). Meta, communication and process data (e.g. IP addresses, time
information, identification numbers, consent status).
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Data subjects: Users (e.g. website visitors, users of online
services).
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Purposes of Processing: Provision of our online services and
usability.
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Further information on processing methods, procedures and services used:
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Google Fonts (Provision on own server): Provision of font files for the purpose of a
user-friendly presentation of our online services; Service provider: The Google Fonts are hosted on our server, no
data is transmitted to Google.
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Terminology and Definitions
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In
this section, you will find an overview of the terminology used in this privacy policy.
Where the terminology is legally defined, their legal definitions apply. The following
explanations, however, are primarily intended to aid understanding.
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Profiles with user-related information: The processing of "profiles with user-related
information", or "profiles" for short, includes any kind of automated processing of personal
data that consists of using these personal data to analyse, evaluate or predict certain
personal aspects relating to a natural person (depending on the type of profiling, this may
include different information concerning demographics, behaviour and interests, such as
interaction with websites and their content, etc.) (e.g. interests in certain content or
products, click behaviour on a website or location). Cookies and web beacons are often used
for profiling purposes.
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Web Analytics: Web Analytics serves the evaluation of visitor
traffic of online services and can determine their behavior or interests in certain
information, such as content of websites. With the help of web analytics, website owners,
for example, can recognize at what time visitors visit their website and what content they
are interested in. This enables them, for example, to better adapt the content of their
websites to the needs of their visitors. For the purposes of web analytics, pseudonymous
cookies and web beacons are often used to recognize returning visitors and thus obtain more
precise analyses of the use of an online service.
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