Privacy Policy

This privacy policy applies to the nature, scope and purpose of the processing of personal data (subsequently referred to as "data") in the course of the provision of our services, as well as within our online offering and the related websites, functions and content, as well as external online presence, such as Wanted our social media profile (subsequently referred to as "online offer"). With regard to the terms used, such as "processing" or "responsible", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Person in charge

Hugo Gambleau, CEO
1337 Gamble St
Cayman Islands
Legal Disclosure

Types of processed data

- Stock data (e.g., Person Master Data).
- Contact data (e.g., E-mail).
- Content data (e.g., Text input).
- Usage data (e.g., Access time).
- Meta-/Communication data (ze.g., Device information, IP address).

Categories of affected persons

Visitors and users of the online offer (subsequently we refer to the affected persons as "users").

Purpose of processing

- Provision of the online offer, its functions and contents.
- Answering contact requests and communicating with users.
- Safety measures..
- Reach Measurement / Marketing

Used terms

"Personal data" means any information relating to an identified or identifiable natural person (subsequently referred to as "data subject"); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (e.g. cookie) or to one or more special features, are the expression of the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.

"Processing" means any process performed with or without the aid of automated procedures, or any such process associated with personal data. The term goes far and includes virtually every handling of data.

"Pseudonymization" means the processing of personal data in such a way that the personal data can no longer be assigned to the affected person, without enlistment of additional information, these additional Information should be kept separate and technical and organizational measures ensure that your personal information is not identified or identifiable natural person.

"Profiling" means any kind of automated processing of personal data that involves the use of that personal information to assess particular personal aspects related to a natural person, in particular to analyze or predict aspects related to work performance, economic situation, health, personal preferences, interests, reliability, behavior, whereabouts or relocation of that natural person.

Controller" means any natural or legal person, public authority, agency or body which determines on its own or jointly with others the purposes and means of the processing of personal data.

"Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Significant legal bases

In accordance with Art. 13 DSGVO we inform you about the legal basis of our data processing. For users from the area of application of the data protection basic regulation (DSGVO), i.e. the EU and the EEC, the following applies, if the legal basis is not mentioned in the data protection explanation:
The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 DSGVO;
The legal basis for the processing for the fulfilment of our services and the execution of contractual measures as well as the answering of inquiries is Art. 6 para. 1 lit. b DSGVO;
. The legal basis for the processing for the fulfilment of our legal obligations is Art. 6 para. 1 lit. c DSGVO;
In the event that vital interests of the data subject or another natural person necessitate the processing of personal data, Art. 6 para. 1 lit. d DSGVO serves as the legal basis.
The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the public authority shall be the following Art. 6 para. 1 lit. e DSGVO has been transferred to the person responsible.
The legal basis for the processing to safeguard our legitimate interests is Art. 6 para. 1 lit. f DSGVO.
The processing of data for purposes other than those for which they were collected is governed by the provisions of Art. 6 (4) DSGVO.
The processing of special categories of data (pursuant to Art. 9 para. 1 DSGVO) is governed by the provisions of Art. 9 para. 2 DSGVO.

Security measures

In accordance with the statutory requirements, we make our assessment taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing as well as the different probability of occurrence and severity of the risks to the rights and freedoms of natural persons, appropriate technical and organisational measures to ensure a level of protection adequate to the risk.

These measures shall include, in particular, safeguarding confidentiality, integrity and availability of data by controlling the physical access to the data, as well as the access, input, transmission, securing availability and use of the data concerning them and of their breakup. In addition, we have established procedures that allow the perception of Ensure data subjects' rights, deletion of data and response to data breaches. Furthermore, we take the protection of personal data into account as early as the development stage, or selection of hardware, software and procedures, according to the principle of the data protection through technology design and data protection-friendly presettings.

Cooperation with contract processors, joint managers and third parties

Provided as we process data in relation to other persons and companies, we shall not disclose such data to third parties. (processors, joint processors or third parties) to disclose them to these third parties. or otherwise grant them access to the data, this will only be done on the basis of the information provided. a legal permission (e.g. if a transmission of the data to third parties, like to payment service provider, necessary for the performance of the contract), a legal obligation provides for this or on the basis of our legitimate belief in the Interests (e.g. when using agents, web hosts, etc.).

Provided as we disclose, transmit or otherwise grant access to data to other companies of our group of companies, this is done in particular for administrative purposes as a legitimate interest and beyond that on a basis corresponding to the legal requirements.

Transfers to third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation), or this in the context of the use of services of third parties or disclosure, or transmission of data to other persons or companies, this only takes place if it is necessary for the purpose of the Fulfilment of our (pre)contractual obligations, on the basis of your consent, based on a legal obligation or on the basis of our legitimate interests happens. Subject to express consent or contractually required transfer, process or allow the data to be processed only in third countries with a data protection level, to which the data protection authorities certified under the "Privacy Shield" belong. US processors or on the basis of special guarantees, e.g. contractual Obligation through so-called standard protection clauses of the EU Commission, the presence of certifications or binding internal data protection regulations (Art. 44 up to 49 DSGVO, Information page of the EU Commission).

Rights of data subjects

Right of access: You have the right to obtain confirmation as to whether the data in question will be processed and to obtain access to such data, as well as further information and a copy of the data in accordance with the provisions of the law.

Right of rectification: You have the right, in accordance with the law, to request the completion of the data concerning you or the rectification of the inaccurate data concerning you.

Right to deletion and limitation of processing: You have the right, in accordance with the statutory provisions, to demand that the relevant data be deleted immediately or, alternatively, to demand that the processing of the data be restricted in accordance with the statutory provisions.

Right to data portability: You have the right to receive data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to demand that it be transferred to another responsible party.

Complaints to the supervisory authority: You also have the right to submit a complaint to the competent supervisory authority in accordance with the statutory provisions.

Right of withdrawal

You have the right to revoke any consent you have given with effect for the future.

Right od objection

Right of objection: You have the right, for reasons arising out of your particular circumstances, to object to this situation at any time against the processing of the data concerning you. personal data that takes place pursuant to Art. 6 Para. 1 lit. e or f DSGVO, to lodge an objection; this also applies to any objection based on these provisions. Profiling. Are the personal data relating to you processed in order to direct advertising, you have the right at any time to object to the terms and conditions of the Processing of personal data concerning you for the purpose of such advertising This also applies to profiling to the extent that such direct advertising is not possible in I'm connected.

Cookies and right to object to direct advertising

Cookies" are small files that are stored on the user's computer. will be. Different data can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is stored). stored) during or also after its visit within an on-line offer to Save. As temporary cookies, or "session cookies" or "transient cookies", the following are stored cookies, which are deleted after a user has left an online service and which are used to closes his browser. In such a cookie, for example, the contents of a shopping cart in an online shop or a login status. As "permanent" or "persistent". are cookies that remain stored even after closing the browser. So the login status can be saved, for example, if the users have saved it after several days. to visit. The interests of the user can also be stored in such a cookie. which are used for range measurement or marketing purposes. As "Third party cookie" means a cookie that is stored on your computer by a service provider other than the the person responsible for operating the online service (otherwise, if it is only used to whose cookies are called "First-Party Cookies").

We may use temporary and permanent cookies and explain this in our privacy policy.

If we ask the users for their consent to the use of cookies (e.g. in the context of of a cookie consent), the legal basis for this processing is Art. 6 para. 1 lit. a. DSGVO. Otherwise, the personal cookies of the users will be stored according to the the following explanations in the context of this data protection declaration on the basis of our privacy policy. Legitimate interests (i.e. interest in the analysis, optimization and economic Operation of our online offer within the meaning of Art. 6 Para. 1 lit. f. DSGVO) or if the Use of cookies is necessary for the provision of our contract-related services, pursuant to Art. 6 para. 1 lit. b. DSGVO, or if the use of cookies for the perception of the a task which is necessary in the public interest or is carried out in the exercise of such a task of official authority, in accordance with Art. 6 Para. 1 lit. e. DSGVO, processed.

If users do not wish cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general objection to the use of cookies for online marketing purposes can be raised for a large number of services, especially in the case of tracking, via the US website or the EU site be explained. In addition, the storage of cookies can be deactivated by means of their deactivation in the settings of the browser. Please note that then, if necessary not all functions of this online offer can be used.

Deletion od data

The data processed by us will be deleted in accordance with the statutory provisions or their processing will be restricted. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and there are no legal obligations to retain them.

If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons.

Changes and updates of the privacy policy

We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

Registration function

Users can create a user account. Within the scope of registration, the required mandatory data will be communicated to the users and processed on the basis of Art. 6 Para. 1 lit. b DSGVO for the purpose of providing the user account. The processed data includes inparticular the login information (name, password and an e-mail address). The data entered during registration will be used for the purposes of using the user account and its purpose.

Users may obtain information that is relevant to their user account, such astechnical changes, by e-mail. If Users Canceled their User Accounttheir data will be used with regard to the user account, subject to a statutory limitation of use. Retention obligation, deleted. It is incumbent on the users to store their data in the event of termination. before the end of the contract. We shall be entitled to demand payment of all claims arising during the contract period the stored data of the user irretrievably.

In the context of the use of our registration and log-in functions as well as the use of our website and the of the user account, we store the IP address and the time of the respective user action. The storage takes place on the basis of our justified interests, as well as the user protection against misuse and other unauthorized use. A passing on of these data to third parties, unless it is necessary to pursue our claims. or there is a legal obligation to do so pursuant to Art. 6 para. 1 lit. c. DSGVO. The IP addresses are anonymised or deleted after 7 days at the latest.


When contacting us (e.g. via contact form, e-mail, telephone or via social media), the user's details are used to process the contact enquiry and to process it in accordance with Art. 6 Para. 1 lit. b. of the German Data Protection Act. (within the framework of contractual/ pre-contractual relationships), Art. 6 Para. 1 lit. f. (other requests) DSGVO processed... The user data can be stored in a customer relationship management system ("CRM system") or comparable inquiry organization.

We will delete the requests if they are no longer necessary. We review the necessity every two years; furthermore, the statutory archiving obligations apply.

Constructed with by RA Dr. Thomas Schwenke