Privacy policy
It stays between us
Dear User,
We are pleased that you are interested in data protection. We would like to give you an easily understandable overview of our data protection process.
Our goal is to provide you with an amazing customer experience that also means that you can always trust us, that we are always transparent and honest to you. Your trust in our product is the reason why we can provide you with an amazing customer experience. We would like to thank you for this cooperation.
Who we are
We are the Delivery Hero (Cyprus) Ltd but usually we just use the name Foody. You can always contact us via the following methods:
Address: Makedonias 88, Latsia, Nicosia/Cyprus
Postcode City: 2238
Phone: 77772250
E-mail address: [email protected]
While visiting our website, registering or placing orders, you agree to this privacy policy.
As data controller, we determine how we process your personal data, for what purposes and by what means. While we are required by law to provide you with all of the following information, we do so primarily out of the belief that a partnership should always be honest.
As data controller we are responsible that all our processing activities are in accordance with legal requirements but also you may reasonably expect these processing of your personal data (legitimate interest).
If you have any questions about data protection at Foody, you can also contact our data protection officer at any time by sending an email to [email protected].
We have a global Corporate Privacy Officer as we are also a member of the large and fascinating family of the Delivery Hero Group.
As a family, we make certain decisions together. Both our parent company, Delivery Hero SE, Oranienburger Straße 70, 10117 Berlin and we jointly decide which means we will use to process your personal data and which purposes we consider to be appropriate.
We will continue to be your point of contact if you have any questions about data protection. If you would like to contact our group’s data protection officer, please reach out to our group data protection officer at [email protected].
Privacy is your right and you have the choice
As a customer you have the choice which information you would like to share with us. Of course we need some information for the fulfillment of our contract. However, this does not always require all the data which you can make available to us.
You can take the following steps to disclose less information about yourself:
Cookies: You can install additional add-ons in your browser that block unnecessary cookies. By doing so, you will not see any interest-based advertisements. Please refer to our cookies policy here.
Advertising: If you do not want to receive newsletters from us, you can unsubscribe at any time. In this case, we will not be able to send you any cool offers.
No data sharing: If you don't want to share any information with us at all, that's a shame. In this case we can't convince you how great our products are.
You can also make use of the following rights at any time:
Right to access
You have the right to be informed which data we store about you and how we process this data.
Right to rectification
If you notice that stored data is incorrect, you can always ask us to correct it.
Right to erasure
You can ask us at any time to delete the data we have stored about you.
Right to restriction of processing
If you do not wish to delete your data, but do not want us to process it further, you can ask us to restrict the processing of your personal data. In this case, we will archive your data and only reintegrate it into our operative systems if you so wish. However, during this time you will not be able to use our services, otherwise we will process your data again.
Right to data portability
You can ask us to transmit the data stored about you in a machine-readable format to you or to another responsible person. In this context, we will make the data available to you in JSON format.
Right to object to the processing of your data
You can revoke your consent at any time or object to the further processing of your data. This also includes objecting to our processing, which we process without your consent but based on our legitimate interest. This applies, for example, to direct marketing. You can object to receiving further newsletters at any time. If you do not agree with one of our processing purposes based on our legitimate interest or wish to object to it, you may object to the processing at any time on grounds relating to his or her particular situation. Please write an email to [email protected]. In this case we will review the processing activity again and either stop processing your data for this purpose or explain to you our reasons worth protecting and why we will continue with the processing.
Automated decision making
We also process your personal data in the context of algorithms in order to simplify our processes. Of course, you have the right not to be subject to decisions based solely on automated processing. If you believe that we have denied your access in an unjustified way, you can always contact us at [email protected]. In this case, we will examine the case separately and decide on a case-by-case basis.
Right of complaint
If you believe that we have done something wrong with your personal data or your rights, you can complain to the appropriate supervisory authority at any time.
The supervisory authority responsible for us is:
Name of the supervisory authority: Office of the Commissioner for Personal Data Protection
Address: Iasonos 1, Nicosia, Cyprus
Postcode City: 1082
Email Address: [email protected]
To exercise your rights, you can contact [email protected] at any time. You can also use the self service provided in section “Personal Data” on our website, in order to delete your account, correct any inaccurate information and opt out from newsletters and email based marketing activities.
The requests asking to exercise your rights are completed within 30 days with no charge.
What data we process
In the following description of our processing activities, we refer in each case to categories of personal data. A category includes several personal data, which are usually processed together for the purposes. Personal data is information that can identify you or even make you identifiable. We generally process the following categories of personal data for the following reasons:
Contact Information:
Name, address, telephone number, email address, your ID from any social media
Reason:
If you contact us, we collect this data because we need to know who we are talking to and what we have been talking about so that we can help you with your reason for contacting us. This also applies if you leave comments on social media on our fan pages. We do not combine this data with your profile data on our platform, but we can still identify you by your social media ID.
Location data:
Address, Postcode, City, Country, Longitude, Latitude
Reason:
We need these data to be able to deliver your orders. We create the longitude and latitude automatically in order to be able to process your delivery address in our other linked systems, such as our Rider app, and to display your address to our riders.
Profile data (master data):
Name, email address, password, telephone number, delivery addresses
Reason:
This data is your master data, which we absolutely need for our services. Without an email address / telephone number and a password, you cannot create a profile. Together with your name, this is your master data.
Device information and access data:
Device ID, device identification, operating system and corresponding version, time of access, configuration settings, information on Internet connection (IP address)
Reason:
With each access this information is stored by us for technical reasons. We also use parts of this information to detect suspicious behaviour at an early stage and to avert damage.
Order information:
Order history, selected restaurants, invoices, order ID, comments on orders, information on payment method, delivery address, successful orders and cancelled orders
Reason:
Each time you place an order, this information will be added to your profile. You can view all this information in your profile at any time. The information should give you an overview of your own interests and previous orders. We will also use the same information to improve our services. In addition, we will anonymize this information when you request a deletion or when your profile becomes inactive in order to continue to use this information in an anonymized form to optimize our services.
Communication data:
Name, email address, telephone number, device ID
Reason:
If you would like to receive a newsletter, an SMS or an in-app push notification from us, we need certain information to send you the messages. Instead of addressing you with "Hey You", we find it more customer friendly to address you with your name. This category of personal information is also used by us to contact you, for example, if a product cannot be delivered and we want to offer you an alternative instead.
Payment information:
Payment method, pseudonymized credit card data
Reason:
We need these information to track your payments and assign them to the orders you have placed. Order address will be shared with the payment in the context of Strong Customer Authentication
Delivery information:
Name, delivery address, phone number, and order ID
Reason:
In accordance with the principle of data minimization, we only provide our riders and restaurants with the information that they need from you to prepare and deliver your order.
For which purposes we process data
We process your personal data only in accordance with the strict legal requirements. We pay particular attention to the fact that all principles for the processing of personal data are taken into account. The Delivery Hero Group pays great attention to transparency. Therefore, we only process your data if this is lawful and you can reasonably expect it to be processed. If, in the course of our evaluation, we come to the conclusion that the processing cannot reasonably be expected, we will only carry out the processing with your express consent.
Account creation, SSO registration, administration of your profile
In order to be able to offer you our services, the processing of your personal data is essential. Much of this data you transmit to us and other parts of the data we collect automatically when using our platforms. Nevertheless, we endeavour to keep the amount of data as small as possible. You can help us by only sharing necessary data with us that we need to fulfill our contractual obligations.
Account creation
When creating a customer account you will be asked to enter your master data. This is absolutely necessary, as we cannot create a customer profile without this data. Your email address and telephone number are particularly important, as we can use this information to identify you in our system the next time you want to log in again. Furthermore, we would like to ask you to choose your password carefully. Do not use the same password on multiple websites and follow our relevant password requirements.
Categories of personal data:
Profile data (master data)
Device information and access data
Legal basis:
Art. 6 para. 1 (b) GDPR, performance of contract
Login
If you already have an existing customer account, you will need to enter your email address and password to log in. If we detect irregularities during registration, such as entering the wrong password several times, we will take appropriate measures to prevent damage to you and us.
Categories of personal data:
Profile data (master data)
Legal basis:
Art. 6 para. 1 (b) GDPR, fulfilment of contract for registration;
Art. 6 para. 1 (f) GDPR, for the security measures
Single-Sign-On with Facebook
If you have a Facebook profile, you can register on our platform to create a customer account or to register using the "Continue with Facebook" function provided by the social network Facebook, operated by Meta Ireland Limited 4 Grand Canal Square, Grand Canal Harbour, Dublin, Ireland ("Meta"), within the framework of the so-called single sign-on technology. You can recognize the social plugins of "Continue with Facebook" on our website by the blue button with the Facebook logo and the label “Continue with Facebook".
By using this "Continue with Facebook" button on our website, you can log in or register on our website using your Facebook user data. Only if you give your express consent prior to the registration process on the basis of a corresponding note on the exchange of data with Facebook, will we receive the general and publicly accessible information stored in your profile when using the Facebook "Continue with Facebook" button on Facebook, depending on your personal data protection settings on Facebook. This information includes user ID, name, profile picture and age.
Further information on the Facebook Login can be found at: https://www.facebook.com/privacy/explanation.
Categories of personal data:
Profile data (master data)
Contact Information
Facebook profile information
Legal basis:
Art. 6 para. 1 (a) GDPR, Consent
Single-Sign-On with Apple
If you have an account with Apple, you can use this account to log in to our service. Apple accounts for European users are provided by Apple Computer Limited, Hollyhill Industrial Estate, Cork, Ireland ("Apple Ireland"), a subsidiary of Apple Inc., One Apple Park Way, Cupertino, CA 95014, United States.
By using the “Continue with Apple” button on our website, you can log in or register on our website using your Apple user data. Only if you give your express consent in accordance with Art. 6 Para. 1 (a) GDPR prior to the registration process on the basis of a corresponding note on the exchange of data with Apple, will we receive your Apple user ID, user name and email address. We will never receive your Apple password and cannot log in to your Apple account. You can learn more about data sharing with Apple when logging in to our service with Apple by reviewing Apple’s explanations here: https://support.apple.com/en-us/HT204053.
The data transmitted by Apple is stored and processed by us solely for the creation of a user account with the necessary data.
Categories of personal data:
Profile data (master data)
Contact Information
Apple ID and associated email address
Legal basis:
Art. 6 (1) (a) GDPR, Consent
Single-Sign-On with Google
If you have an account with Google, you can use this account to log in to our service. Google accounts for European users are provided by Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland ("Google Ireland"), a subsidiary of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 ("Google").
By using the “Continue with Google” button on our website, you can log in or register on our website using your Google user data. Only if you give your express consent in accordance with Art. 6 Para. 1 (a) GDPR prior to the registration process on the basis of a corresponding note on the exchange of data with Google, will we receive your Google user ID, user name and email address. We will never receive your Google password and cannot log in to your Google account. You can learn more about data sharing with Google when logging in to our service with Google by reviewing Google’s explanations here: https://support.google.com/accounts/answer/112802.
The data transmitted by Google is stored and processed by us solely for the creation of a user account with the necessary data.
Categories of personal data:
Profile data (master data)
Contact Information
Google ID and associated account data
Legal basis:
Art. 6 (1) (a) GDPR, Consent
Managing your profile
You can log in to your profile at any time and change your personal data, such as name, address or telephone number. To change your email address you can contact us at [email protected]. You can also view your previous orders.
Categories of personal data:
Profile data, location data
Order information
Device information and access data
Order information
Communication data
Payment information
Legal basis:
Art. 6 para. 1 (b) GDPR, performance of contract
Order processing
Once you have successfully registered and decided to place your order, we will store this information in your profile and process it in further processes so that you can submit your order to us. When you submit your order, your personal data is transferred to our backend where it is transferred to other systems for further processing.
Categories of personal data:
Contact Information
Location data
Device information and access data
Legal basis:
Art. 6 para. 1 (b) GDPR, fulfilment of contract
Buffering
After you have logged in to your profile and made your selection, the products will be saved in your profile. If you accidentally close your browser or app, after adding things to your cart, you can continue to the last point of your order, when you select again the specific restaurant from the homepage. The last information is stored in the appropriate storage.
Categories of personal data:
Profile data (master data)
Device information and access data
Order information
Legal basis:
Art. 6 para. 1 (f) GDPR, legitimate interest
The legitimate interest is to provide you with a better ordering experience where you can conveniently continue your order with browsers or apps that are accidentally closed.
Delivery
Once you have successfully placed your order, a number of processes are running in the background to ensure that your order is delivered quickly. The following processing activities describe how and why your data is processed for the respective purposes.
Transfer to Riders and Stores
We use different riders for delivery. These can be permanent employees, freelancers or third parties who provide us with riders on the basis of a service agreement when we deliver our orders. In all these cases we send your personal data to the riders so that they can deliver your order quickly.
Categories of personal data:
Delivery information
Legal basis:
Art. 6 para. 1 (b) GDPR, performance of contract
Calls from riders or restaurants
If a product of your choice is not available for delivery or our riders cannot reach you at the delivery address you provided, they have received instructions from us to call you so that the problem can be solved easily.
Categories of personal data:
Delivery information
Legal basis:
Art. 6 para. 1 (b) GDPR, contract performance on call by the rider
Art. 6 para. 1 (f) GDPR, legitimate interest when called by the restaurant. The restaurants have no claim whatsoever to your personal data and under no circumstances may they use it for their own purposes. If you should nevertheless be contacted by a restaurant without your prior consent, we ask you to report this to us by e-mail to [email protected].
Saved payment methods
In order to make the ordering process even more convenient for you, we offer to save your preferred payment method. This means that you don't have to enter your payment details again the next time you place an order. The storage of this data requires your prior consent. You can save your payment data by clicking on the consent field. You can revoke your consent for the future at any time by deleting your preferred payment method.
Categories of personal data:
Payment data
Legal basis:
Art. 6 para. 1 (a) GDPR, consent
Fraud prevention and security of our platform
In order to protect our customers and our platform from possible attacks, we continuously monitor the activities on our website. To this end, we use various technical measures to ensure that suspicious behavior patterns are detected at an early stage and prevented in good time. To achieve this goal, several monitoring mechanisms run in parallel and prevent potential attackers from accessing our website at all.
The decision-making process is automated and can have a legal effect on the person concerned or affect them in a similar way. If automated decision making leads to a negative result for you and you do not agree with this, you can contact us at [email protected] In this case, we will individually assess the circumstances of your case.
Categories of personal data:
Device information and access data
Contact information
Payment information
Order information
Voucher information
Legal basis:
Art. 6 Para. 1 (f) GDPR, Legitimate Interest
Advertising and direct marketing
Newsletter
If you have provided us with your email address when purchasing goods or services, we reserve the right to send you regular offers of similar goods or services to those already purchased from our range by email. Not only do the contents of our newsletters vary, but so do the technologies and criteria we use to design our newsletters and segment customer groups. For example, a group of customers may receive a special newsletter promoting special deals from restaurants where customers have ordered. Other newsletters may refer to specific products that relate to a particular flavour, such as sushi, Indian delicacies or pizza. We use different information from your order history and delivery addresses. This is a profiling process in which we automatically process your data. The specific customer segmentation can have a legal effect on you or can have a significant effect on you in other ways if you receive certain newsletters and are not included in other campaigns.
If automated decision making leads to a negative result for you and you do not agree with this, you can contact us at [email protected]. In this case, we will individually assess the circumstances of your case.
Categories of personal data:
Contact Information
Location data
Order information
Legal basis:
Data processing in this respect takes place solely on the basis of our legitimate interest in personalised direct advertising pursuant to Art. 6 Para. 1 lit. f GDPR. If you have initially objected to the use of your email address for this purpose, we will not send you an email. You are entitled to object to the use of your email address for the aforementioned advertising purposes at any time with effect for the future by notifying the person responsible named at the beginning. For this purpose you only incur transmission costs according to the basic tariffs. Upon receipt of your objection, the use of your email address for advertising purposes will be discontinued immediately.
NPS
We are constantly striving to improve our services. Your constructive feedback is very important to us. Therefore we will occasionally send you customer surveys and ask you to give us your opinion. If you do not wish to receive customer surveys, you can unsubscribe at any time. For any customer survey request you can click "unsubscribe" below and we will not contact you again.
Categories of personal data:
Communication data
Legal basis:
Art. 6 para. 1 (f) GDPR, legitimate interest.
Our legitimate interest is the purpose described above.
App Notifications
We have a strong interest in informing you about new restaurants or deals when using our app. We are always working to give you an amazing customer experience. To achieve this, we negotiate very good deals for you with our restaurant partners. To inform you about these deals, we send you in our Apps in-app-notification or push-notification. It is imperative that you have activated this in your end devices.
Categories of personal data:
Location data
Profile data (master data)
Order information
Legal basis:
If processing takes place with your consent, the legal basis is Art. 6 Para. 1 (a) GDPR, namely your consent. Otherwise, the processing is based on our legitimate interest pursuant to Art. 6 para. 1 (f) GDPR. Our legitimate interest lies in the aforementioned purpose.
SMS
Besides other means we continue to use SMS to inform you about new deals in your area. You will only receive an SMS from us if you have given your consent. You can revoke your consent at any time for the future. Please send us an e-mail to [email protected]. The registration as well as the cancellation is free of charge for you.
Categories of personal data:
Contact Information
Order information
Legal basis:
Art. 6 para. 1 (a) GDPR, consent
Online marketing
Our service is based to a large extent on convincing potential customers that we offer an amazing customer experience and that every visit to our platform is worthwhile. In order to reach as many potential customers as possible, we are very active in the field of online marketing. It is just as important to win the trust of potential customers and to strengthen the trust of our existing customers. Therefore, we would like to present to you our processes as transparent as possible.
Targeting
In principle, targeting means the switching and fading in of advertising banners on websites that are tailored to specific target groups. The aim is to display the most attractive banners as individually as possible for the user and potential customer. Firstly, we define a target group and secondly, we commission our service providers to show our advertising to the defined target group. We do not process any personal data, as these are initially made anonymous. To better define the target group, we segment customer types and place different ads on different portals.
Retargeting
As soon as you have visited our website and, for example, have already placed an order in your shopping cart, we store this information in cookies. If you continue to surf other websites, our advertising partners will remind you on our behalf that you have not yet completed your order. We don't want you to miss out on our amazing customer experience. You can disable retargeting by installing appropriate add-ons for your browser. Furthermore, you can and should also regularly delete the cookies stored in the browser you are using.
Categories of personal data:
Contact Information
Legal basis:
Art. 6 para. 1 (f) GDPR, legitimate interest.
Our legitimate interest is the purpose described above.
Cookies
In order to make the visit of our website/app attractive and to enable the use of certain functions, we use so-called cookies on various pages. These are small text files that are stored on your device. Some of the cookies we use are deleted after the end of the browser session, i.e. after closing your browser (so-called session cookies). Other cookies remain on your device and allow us or our affiliate to recognize your browser on your next visit (persistent cookies). You can set your browser so that you are informed about the setting of cookies and individually decide on their acceptance or exclude the acceptance of cookies for specific cases or in general. Failure to accept cookies may limit the functionality of our website/app.
Legal basis:
If processing takes place with your consent, the legal basis is Art. 6 Para. 1 (a) GDPR, namely your consent. Otherwise, the processing is based on our legitimate interest pursuant to Art. 6 para. 1 (f) GDPR. Our legitimate interest lies in the aforementioned purpose.
You can find our cookie policy with all the cookies we use here.
Sweepstakes
The participation in the lottery requires your consent. If you have already given your consent and would like to revoke it for the future, you can do so at any time by sending an email to [email protected]. In this case, we will exclude you from participating in our sweepstakes and you will not receive any further invitations to sweepstakes.
Categories of personal data:
Contact Information
Legal basis:
Art. 6 Para. 1 (a) GDPR, Consent
User Experience Surveys
We always develop new products and try to adapt our services to the wishes of our customers. In order to measure the effectiveness of these changes, we regularly offer interviews with our User Experience team. In these interviews we record your usage behavior and ask you for possible optimization possibilities. Participation in the interviews requires your consent. If you have already given your consent and would like to revoke it for the future, you can do so at any time by sending an email to [email protected]. In this case we will exclude you from participating in our interviews and you will not receive any further invitations for them.
Categories of personal data:
Contact Information
Order information
Legal basis:
Art. 6 Para. 1 (a) GDPR, Consent
Vouchers
We often offer vouchers for our platform. The reasons can vary. The purpose of these vouchers is to reward our loyal customers and to encourage them to continue to lead our loyal customers. In some cases the Stores in our platform might also want to offer a voucher to you, for your next Foody order, as a reward or a compensation. In order to be able to check the number, the value and the frequency of use of the vouchers, but also to avoid misuse of these vouchers, we collect various personal data.
Categories of personal data:
Profile data (master data)
Voucher information
Legal basis:
Art. 6 para. 1 (f) GDPR, legitimate interest
Our legitimate interest is the purpose described above.
Social Media Sites
We have profiles on various social media platforms on which we advertise our products and interact with customers. Since we operate these profiles on third-party platforms, each time you visit these social media channels the operators collect different personal data from you.
Responsibilities
We and the respective operators of the social media platforms act as joint controllers. Where two or more controllers jointly determine the purposes and means of processing, they shall be joint controllers.
The social media platforms Facebook and Instagram are operated by Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland.
We are responsible for all interactions on our own platforms. The operators of the social media platforms themselves are data controllers for general interactions and interactions outside our profiles. An exception applies to the data processing described below for the usage analysis (page insights); we are jointly responsible with Facebook for this.
The following links will show you exactly which data is collected by the respective social media operators:
Privacy Policy Facebook Privacy Policy Instagram
Data processing
For pages, Facebook provides page administrators with statistics and insights that help them understand the types of actions people take on their pages ("Page Insights"). When you visit or interact with a Page or its content, information such as the following may be collected and used to create Page Insights:
Viewing a Page, or a post or video from a Page
- Following or unfollowing a Page
- Liking or unliking a Page or post
- Recommending a Page in a post or comment
- Commenting on, sharing or reacting to a Page post (including the type of reaction)
- Hiding a Page's post or reporting it as spam
- Clicking a link to a Page from another Page on Facebook or from a website off Facebook
- Hovering over a Page's name or profile picture to see a preview of the Page's content
- Clicking on the website, phone number, Get Directions button or other button on a Page
- Whether you're on a computer or mobile device while visiting or interacting with a Page or its content
We and Facebook are jointly responsible for the processing of your data for the provision of page insights. For this purpose, we and Facebook have agreed in an agreement which and a division of our data protection obligations according to Art. 26 GDPR shall be agreed.
Your data subject rights
For all data processing on this website, we are solely responsible for processing your data in accordance with data protection regulations. As part of our agreement with Facebook, we have determined that Facebook is primarily responsible for fulfilling its information obligations in connection with the Page Insight data and for ensuring that you exercise your rights under the GDPR. For more information about your data subject rights on Facebook, please see Facebook's Page-Inside Privacy Policy.
Merger & acquisitions, change of ownership
We would also like to inform you that in the event of a merger with or acquisition by another company, we will disclose information to that company. Of course, we will require the company to comply with the legal data protection regulations.
Categories of personal data:
Contact Information
Delivery information
Location data
Profile data (master data)
Device information and access data
Order information
Communication data
Payment information
Voucher information
Legal basis:
Art. 6 para. 1 (f) GDPR, legitimate interest Our legitimate interest is the purpose described above.
Call Center
If you contact us by phone, we store the conversation for quality assurance purposes. In individual cases, we also use the recordings for quality improvement in customer service, i.e. for training purposes (coaching) with our employees. The content of the information we store depends on the information you provide to us as part of our communications. The stored telephone calls are deleted after seven days at the latest or if the purpose of the storage, i.e. the quality check, is fulfilled earlier.
Categories of personal data:
Contact information
Order information
Legal basis:
Art. 6 para. 1 (f) GDPR, Legitimate interest
Whom We Share Your Personal Data With
We never give your data to unauthorized third parties. However, as part of our work we obtain the services of selected service providers and give them limited and strictly monitored access to some of our data. However, before we forward personal data to these partner companies for processing on our behalf, each individual company undergoes an audit. All data recipients must meet the legal data protection requirements and prove their data protection level with appropriate proofs.
Delivery Hero Group
Within a group it is sometimes necessary to use resources effectively. In this context, we support each other within our Group in optimizing our processes. In addition, we provide joint content and services. This includes, for example, the technical support of systems. This is a joint responsibility within the meaning of Art. 26 GDPR. We are fully responsible for fulfilling the data protection requirements together with Delivery Hero SE, Oranienburger Straße 70, 10117 Berlin, [email protected]. Within the framework of joint controllership, both we and Delivery Hero SE have agreed that both will guarantee your rights equally. For practical reasons we have decided that we are to you for all data protection-legal questions at the disposal and in particular your rights in accordance with Art. 15 to 22 of GDPR. Please contact us for this under [email protected].
Service providers
We use different data processors in our daily processing. These process your personal data in accordance with the requirements of Art. 28 GDPR only according to our instructions and have no claims whatsoever on these data. We also monitor our processors and include only those who meet our high standards. Because we use different data processors and change them from time to time, it is not appropriate to identify specific recipients of personal information. However, if you are interested, we will be happy to disclose the name of the processor(s) in use at that time upon request.
Third parties
In addition to data processors, we also work with third parties, to whom we also transmit your personal data, but who are not bound by our instructions. These are, for example, our consultants, lawyers or tax consultants who receive your data from us on the basis of a contract and process your personal data for legal reasons or to protect our own interests. We do not sell or rent your personal data to third parties under any circumstances. This will never take place without your explicit consent.
Prosecuting authorities, courts and other public bodies
Unfortunately, it can happen that a few of our customers and service providers do not behave fairly and want to harm us. In these cases, we are not only obliged to hand over personal data due to legal obligations, it is also in our interest to prevent damage and to enforce our claims and to reject unjustified claims.
International Data Transfers
We process your data mainly within the European Union (EU) and the European Economic Area (EEA). However, some of our service providers or affiliated companies mentioned above are based outside the EEA in so-called “third countries”. The GDPR has high requirements for the transfer of personal data to such third countries. All our data recipients have to measure up to these requirements.
Before we transfer your data to a recipient in a third country, this recipient is first assessed with regard to their data protection level. They will only be chosen if they can demonstrate an adequate level of data protection even outside the territory of the EEA. According to Art. 44 ff. GDPR personal data may be transferred to service providers meeting at least one of the following requirements:
- The European Commission has decided that the third country ensures an adequate level of protection (e.g. Israel and Canada).
- Standard contractual clauses (also called “standard data protection clauses”) have been incorporated into our contract with the data recipient (including any supplementary measures, if required).
- Further appropriate safeguards in accordance with Art. 46 GDPR have been provided (for example Binding Corporate Rules).
How long we store your data
We generally delete your data after the purpose has been fulfilled. The exact deletion rules are defined in our regional deletion concepts. Different deletion rules apply depending on the purpose of the processing. Within our deletion concepts we have defined various data classes and assigned rule deletion periods to them. The data collected is marked with a deletion rule. When the retention period is met, the stored data will be deleted accordingly.
We will delete your personal data if you wish and let us know via email at [email protected] or if your account is inactive for three years. In addition to the deletion rules defined by us, there are other legal retention periods which we must also observe. For example, tax data must be kept for a period of between six and ten years . These special retention periods vary according to local legal requirements.
Therefore, despite your request for deletion of your data, we may still have to store some of the stored data due to legal regulations. In this case, however, we will restrict data from further processing.
Furthermore, we will continue to store your data if we have a right to do so in accordance with Art. 17 para. 3 GDPR. This applies in particular if we need your personal data for the establishment, exercise or defense of legal claims.
Right of modification
We reserve the right to change this data protection declaration in compliance with the statutory provisions. We will inform you of any significant changes, such as changes of purpose or new purposes of processing.
Last update: February 14, 2023