Privacy statement

This privacy statement explains the nature, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online service and its related websites, functions and content, as well as related external online resources, such as our Social Media Profile (hereinafter collectively referred to as "online service"). Regarding the terms used, such as "processing" or "person responsible", we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Person responsible

Eray Türer
Schwentnerring 15c
21109 Hamburg
info@alexandraceylan.com

Types of processed data:

- Inventory data (e.g., names, addresses).
- Contact details (e.g., e-mail, telephone numbers).
- Content data (e.g., text input, photographs, videos).
- Usage data (e.g., visited websites, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).

Categories of affected persons

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

Purpose of processing

- Provision of the online service, its functions and contents.
- Answering contact requests and communicating with users.
- Security measures.
- Reach measurement/marketing.

Terms used

"Personal data" means any information relating to an identified or identifiable natural person (hereinafter the "data subject"). A natural person is considered as identifiable, and 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, which form 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. This term is extensive and includes virtually all handling of data.

"Pseudonymisation" means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and subject to technical and organisational measures to ensure that the personal data is not assigned to an identified or identifiable natural person.

"Profiling" means any form of automated processing of personal data which involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects of that natural person relating to job performance, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

"Person responsible" means the natural or legal person, public authority, or other body that decides, alone or in concert with others, on the purposes and means of the processing of personal data.

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

Relevant legal bases

In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis is stated in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6 para 1 lit. a and Art. 7 GDPR, the legal basis for processing in order to provide our services and the execution of contractual measures as well as the answering of inquiries is Art. 6 para 1 lit. b GDPR, the legal basis for processing in order to fulfil our legal obligations is Art. 6 para 1 lit. c GDPR, and the legal basis for processing in order to protect our legitimate interests is Art. 6 para 1 lit. f GDPR. In the event that the vital interests of the data subject or any other natural person require the processing of personal data, Art. 6 para 1 lit. d GDPR serves as the legal basis.

Security measures

In accordance with Art. 32 GDPR, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of processing as well as the different likelihood of occurrence, and seriousness of the risk to the rights and freedoms of natural persons, we are taking appropriate technical and organisational measures to ensure a level of protection appropriate to the risk.

Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access, input, disclosure, availability and separation of said data. We have also set up procedures to ensure the rights of data subjects, data deletion and response to the vulnerability of data. Furthermore, we consider the protection of personal data already during the development process or selection of hardware, software and procedures, according to the principle of data protection through technology design and privacy-friendly default settings (Art. 25 GDPR).

Collaboration with processors and third parties

If, in the context of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit to them or otherwise grant access to the data, this will only be done on the basis of a legal permission (e.g., if a transmission of the data to third parties, as required by payment service providers, according to Art. 6 para 1 lit. b GDPR is necessary in order to fulfil the contract), you have consented to a legal obligation or based on our legitimate interests (e.g., the use of agents, web hosters, etc.).

If we commission third parties to process data on the basis of a so-called "contract processing contract", this is done on the basis of Art. 28 GDPR.

Transfers to third countries

If we process data in a third country (e.g., outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done if it is to fulfil our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we only process or store the data in a third country if the special conditions as described in Art. 44 ff. GDPR, are present. This means access to that processing is based, for example, on specific guarantees, such as the officially recognised level of data protection equivalent to that of the EU (e.g., for the US through the "Privacy Shield") or compliance with officially recognised special contractual obligations (so-called "standard contract clauses").

Rights of data subjects

You have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.

According to Art. 16 GDPR, you have the right to request the completion or correction of incorrect data concerning you.

In accordance with Art. 17 GDPR, you have the right to demand that relevant data be deleted immediately, or that its use be restricted in accordance with Art. 18 GDPR.

You have the right to demand to receive data concerning you, which you have provided to us in accordance with Art. 20 GDPR and to demand its transmission to other persons responsible.

Furthermore, according to Art. 77 GDPR, you have the right to file a complaint with the relevant supervisory authority.

Right of withdrawal

You have the right to withdraw consent given in accordance with Art. 7 par. 3 GDPR effective henceforth.

Right to object

You may object to any future processing of your data in accordance with Art. 21 GDPR at any time. The objection may in particular be made against processing for direct marketing purposes.

Cookies and the right to object in direct mail

"Cookies" are small files that are stored on users' computers. Different types of information can be stored within cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his visit to an online service. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, for example, the content of a shopping cart in an online shop or a login status can be saved. The term "permanent" or "persistent" refers to cookies that remain stored even after the browser has been closed. For example, the login status can be stored if users visit it again after several days. Likewise, the interests of the users can be stored in such a cookie, which are used for reach measurement or marketing purposes. A "third-party cookie" refers to cookies that are offered by providers other than the person who manages the online service (otherwise, if it is only their cookies, these are called "first-party cookies").

We can use temporary and permanent cookies and clarify this in our privacy policy.

If users do not want cookies stored on their machine, they will be asked to disable the corresponding option in the system settings of their browser. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online service.

A general objection against the use of cookies used for the purpose of online marketing can be made through a variety of services, especially regarding tracking, on the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/ . Furthermore, the storage of cookies can be managed by switching them off in the settings of the browser. Please note that in this case, not all features of this online service may be available.

Deletion of data

The data processed by us will be deleted or restricted in their processing according to Art. 17 and 18 GDPR. Unless explicitly stated in this privacy policy, the data stored by us is deleted as soon as it's no longer required for its purpose and the deletion does not conflict with any statutory storage requirements. If data is not deleted because it is required for other and legitimate purposes, its processing will be restricted. That means access to the data is blocked and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax reasons.

According to legal requirements in Germany, data is stored for 10 years in accordance with §§147 par. 1 AO, 257 par. 1 No. 1 and 4, par. 4 German Commercial Code (books, records, management reports, accounting documents, trading books, relevant for taxation documents, etc.) and 6 years in accordance with §257 (1) no. 2 and 3, para. 4 German Commercial Code (commercial letters).

According to legal regulations in Austria data is stored for 7 years in accordance with §132 para. 1 BAO (accounting documents, receipts/invoices, accounts, receipts, business papers, statement of income and expenses, etc.), for 22 years in connection with real estate and for 10 years in the case of documents relating to electronically supplied services, telecommunications, broadcasting and television services provided to non-entrepreneurs in EU Member States and for which the Mini-One-Stop-Shop (MOSS) is used.

Agency services

We process our clients' data as part of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, campaign/process/handling implementation, server administration, data analysis/consulting services, and training services.

In doing so we process stock data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text input, photographs, videos), contract data (e.g., subject matter, term), payment data (e.g., bank details, payment history), usage and metadata (e.g., in the context of the evaluation and success measurement of marketing measures). Generally, we do not process special categories of personal data, unless these are components of a commissioned processing. Those affected include our customers, prospects and their customers, users, website visitors or employees as well as third parties. The purpose of data processing is the provision of contract services, billing and our customer service. The legal bases of the processing result from Art. 6 para 1 lit. b GDPR (contractual services), Art. 6 para 1 lit. f GDPR (analysis, statistics, optimisation, security measures). We process data that is required to provide and fulfil our contractual services and indicate the necessity of your information. Disclosure to external parties will only be made if it is required to fulfil an order. When processing the data provided to us within the framework of an order, we act in accordance with the instructions of the client as well as with the legal requirements of order processing pursuant to Art. 28 GDPR and process the data for no other purpose than the order.

We delete the data after the expiry of legal warranty and comparable obligations. The necessity of storing the data is checked every three years; in the case of legal archiving obligations, deletion takes place after its expiry (6 years, pursuant to § 257 (1) HGB, 10 J, in accordance with § 147 (1) AO). In the case of data disclosed to us in the context of an order by the client, we delete the data according to the specifications of the order, usually after the order is fulfilled.

Contractual services

We process the data of our contractual partners and interested parties as well as other customers, clients or contractual partners (uniformly referred to as "contractual partners") according to Art. 6 para 1 lit. b. GDPR in order to provide you with our contractual or pre-contractual services. The data processed in this regard, the nature, scope and purpose and necessity of its processing are determined by the underlying contractual relationship.

The processed data includes the master data of our contractual partners (e.g., names and addresses), contact data (e.g., e-mail addresses and telephone numbers) as well as contract data (e.g., services used, contract contents, contractual communication, names of contact persons) and payment data (e.g., bank details, payment history).

In principle, we do not process special categories of personal data, unless they are part of contracted or contractual processing.

We process data necessary for the justification and fulfilment of our contractual services and always indicate the necessity of disclosure, if it is not evident to the contractual partner. Disclosure to external persons or companies will only be made if it is necessary in the course of contracting. When processing the data provided to us as part of an order, we act according to the instructions of the client as well as the legal requirements.

As part of the use of our online services, we can save the IP address and the time of each user action. The storage of this data is based on our legitimate interests, as well as the interests of the user for protection against misuse and other unauthorised use. A transfer of this data to third parties does not take place, unless it is required in order to pursue our claims according to Art. 6 para 1 lit. f. GDPR or unless there is a legal obligation in accordance with Art. 6 para 1 lit. c. GDPR.

The data will be deleted if the data is no longer required for the fulfilment of contractual or statutory duties of care and for the handling of any warranty and comparable obligations, whereby the necessity of keeping the data is reviewed every three years; otherwise the statutory storage obligations apply.

Contacting us

When contacting us (e.g., via contact form, e-mail, telephone or via social media), the information provided by the user to process the contact request and its processing is handled according to Art. 6 para 1 lit. b. (in the context of contractual/pre-contractual relationships), Art. 6 para 1 lit. f. (other requests) GDPR. User information can be stored in a Customer Relationship Management System (CRM System) or comparable inquiry organisation system.

We delete these requests, when they are no longer required. We check their necessity every two years; furthermore, legal archiving obligations apply.

Hosting and e-mailing

The hosting services we use are designed to provide the following services: infrastructure and platform services, computing capacity, storage and database services, e-mailing, security services as well as the technical maintenance services we utilise for the purpose of operating this online service.

For this purpose we or our hosting provider processes inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties and visitors to this online service on the basis of our legitimate interests in an efficient and secure provision of this online service Acc. to Art. 6 para 1 lit. f GDPR as well as Art. 28 GDPR (conclusion of order processing contract).

Collection of access data and log files

We, or our hosting provider, collect data concerning our legitimate interests as per Art. 6 para 1 lit. f. GDPR on every access to the server on which this service is located (so-called "server log files"). This access data includes the name of the retrieved web page, file, date and time of retrieval, amount of data transferred, notification of successful retrieval, browser type and version, the user's operating system, referrer URL (previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons ( e.g., to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data which must be retained further because it is required for evidence purposes is exempt from deletion until final clarification of the incident.

Online presence in social media

We maintain an online presence within social networks and platforms in order to communicate with customers, prospective customers and users who are active there and to inform them about our services.

We draw attention to the fact that this means that user data may be processed outside the area of ​​the European Union. This may result in risks for users, as, for example, enforcement of the rights of users could become more difficult. With respect to US providers certified under the Privacy Shield, we highlight that they are committed to respecting EU privacy standards.

Furthermore, user data is usually processed for market research and advertising purposes. For example, user profiles can be created from user behaviour and resulting user interests. The usage profiles can in turn be used, for example, to place advertisements inside and outside the platforms that are supposedly in line with the interests of the users. For these purposes, cookies are usually stored on the computers of the users, which store the user behaviour and interests. Furthermore, in these usage profiles, data can also be stored independently of the devices used by the users (in particular if the users are members of the respective platforms and logged in to them).

The processing of personal user data is based on our legitimate interests in effectively informing and communicating with users in accordance with Art. 6 para 1 lit. f. GDPR. If the respective providers ask for a user's consent in order to process data (e.g., explaining their agreement e.g., to tick a check box or a confirmation button), the legal basis of the processing is Art. 6 para 1 lit. a., Art. 7 GDPR.

For a detailed description of the respective processing and the possibilities of objection (opt-out), we refer to the following links containing the information of the providers.

Additionally, in the case of requests for information and the assertion of user rights, we point out that these can be made most effectively directly with the providers. Only the providers have access to user data and can directly take the appropriate action and provide information. Should you nevertheless require help, feel free to contact us.

- Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) - Privacy Policy: https://www.facebook.com/about/privacy/ , Opt-out: https://www.facebook.com/settings?tab=ads and http://www.youronlinechoices.com , Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active ,

- Google (Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA) - Privacy Policy: https://policies.google.com/privacy , Opt-out: https://adssettings.google.com/authenticated , Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active ,

- Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) - Privacy Policy/Opt-Out: http://instagram.com/about/legal/privacy/ ,

- Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, United States) - Privacy Policy: https://twitter.com/de/privacy , Opt-out: https://twitter.com/personalization , Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active ,

- Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA) - Privacy Policy/Opt-Out: https://about.pinterest.com/de/privacy-policy ,

- LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland) - Privacy Policy: https://www.linkedin.com/legal/privacy-policy , Opt-out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out , Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active ,

- Xing (XING AG, Dammtorstrasse 29-32, 20354 Hamburg, Germany) - Privacy Policy/Opt-Out: https://privacy.xing.com/de/datenschutzerklaerung ,

Embedding of services and content of third parties

Within our online service, we embed third party content or services, such as videos or fonts (collectively referred to as "content") within the scope of our legitimate interests (e.g., interest in the analysis, optimisation and economic operation of our service offer in accordance with Art. 6 para 1 lit. f. GDPR).

This always presupposes that the third-party providers of this content receive the IP addresses of the users, as they would not be able to send content to their browser without their IP address. Your IP address is therefore required for the presentation of this content. We endeavour to use only content where the respective providers use the IP address solely in order to deliver such content. Third party providers may also use so-called pixel tags (invisible graphics, also referred to as "web beacons") for statistical or marketing purposes. These "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. Pseudonymous information may also be stored in cookies on the user's device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and other information concerning the use of our online service.

YouTube

We embed videos from the YouTube platform of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/ , Opt-out: https://adssettings.google.com/authenticated ,

Google ReCaptcha

We incorporate a feature to detect bots, for example when filling out online forms (ReCaptcha), provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/ , Opt-out: https://adssettings.google.com/authenticated ,

Google Maps

We embed maps from the Google Maps service provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Processed data may include, in particular, users' IP addresses and location data, which are not collected without their consent (usually as part of the settings of their mobile devices). This data may be processed in the USA. Privacy policy: https://www.google.com/policies/privacy/ , Opt-out: https://adssettings.google.com/authenticated ,

Use of Facebook social plugins

Within the scope of our legitimate interests (e.g., interest in the analysis, optimisation and economic operation of our online offer within the meaning of Art. 6 para 1 lit. f. GDPR), we use social plugins ("plugins") of the social network facebook.com, which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook").
This may include, for example, content such as images, videos or text and buttons, with which users can share the content of this online service through Facebook. A list of and the appearance of Facebook social plugins can be viewed here: https://developers.facebook.com/docs/plugins/ ,

Facebook is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European data protection law ( https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active ).

When a user invokes a feature of this online service that contains such a plugin, his device establishes a direct connection with the servers of Facebook. The content of the plugin is transmitted by Facebook directly to the device of the user and incorporated into the online service through it. During this process, data can be used to create user profiles. We therefore have no influence on the amount of data Facebook collects through this plugin and therefore inform the users according to our knowledge.

By integrating these plugins, Facebook receives information that a user has accessed the corresponding page of our online service. If the user is logged in to Facebook, Facebook can connect the visit to his Facebook account. If users interact with these plugins, for example, by pressing the Like button or leaving a comment, that information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, there is still the possibility that Facebook may receive and store their IP address. According to Facebook, only an anonymous IP address is stored in Germany.

The purpose and scope of data collection and the further processing and usage of data by Facebook as well as the related rights and setting options to protect the privacy of users, can be found in the privacy policy of Facebook: https://www.facebook.com/about/privacy/ ,

If a user is a Facebook member and does not want Facebook to collect data about him through this online service and associate it with his membership data stored on Facebook, he must log out of Facebook and delete his cookies before using our online service. Additional settings and the option to object to the usage of data for promotional purposes are available within the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/

These settings are platform-independent, e.g., they are adopted for all devices, such as desktop computers or mobile devices.

Instagram

Within our online service, features and content of the Instagram service offered by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, may be incorporated. This may include, for example, content such as images, videos or text and buttons that allow users to share content from this online service through Instagram. If the users are members of the platform Instagram, Instagram can associate viewing the above mentioned contents and functions with the corresponding user profiles there. Instagram privacy policy: http://instagram.com/about/legal/privacy/ .

Created with Datenschutz-Generator.de by Dr. Thomas Schwenke, attorney