Current as of 20 Jan 2022

Privacy Policy

Your privacy is important to us at Untitled. We respect your privacy regarding any information we may collect from you across our website.

1. Overview of Data Protection

General Information

The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data with which you can be personally identified. Detailed information on data protection can be found in our privacy policy listed below this text.

Data Collection on This Website

Who is responsible for the data collection on this website?

The data processing on this website is carried out by the website operator. Their contact details can be found in the section “Notice concerning the responsible party” in this privacy policy.

How do we collect your data?

Your data is collected, firstly, by you providing it to us. This could be data you enter into a contact form, for example.

Other data is collected automatically or after your consent when you visit the website by our IT systems. This primarily includes technical data (e.g., internet browser, operating system, or time of the page access). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Part of the data is collected to ensure the error-free provision of the website. Other data can be used to analyze your user behavior.

What rights do you have regarding your data?

You have the right to receive information about the origin, recipient, and purpose of your stored personal data free of charge at any time. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can revoke this consent at any time in the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to complain to the competent supervisory authority.

You can contact us at any time regarding this and any other questions on the topic of data protection.

Analytics and Third-Party Tools

When visiting this website, your surfing behavior can be statistically analyzed. This happens primarily with so-called analysis programs.

Detailed information on these analysis programs can be found in the following privacy policy.

2. Hosting

We host the contents of our website with the following provider: TBD

The provider is TBD (hereinafter referred to as Host).

Details can be found in Host’s privacy policy: TBD

The use of Host is based on Art. 6(1)(f) GDPR. We have a legitimate interest in ensuring as reliable a presentation of our website as possible. If appropriate consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TTDSG, insofar as the consent includes the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.

Order Processing

We have concluded a data processing agreement (DPA) for the use of the above service. This is a legally required contract that ensures that the provider processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

3. General Information and Mandatory Notices

Data Protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with legal data protection regulations and this privacy policy.

When you use this website, various personal data are collected. Personal data are data with which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We would like to point out that data transmission over the Internet (e.g., when communicating by e-mail) can have security gaps. Complete protection of data from access by third parties is not possible.

Notice Concerning the Responsible Party

The responsible party for data processing on this website is:

Daniel Gvozdenac
North 47 GmbH
ADDRESSE

The responsible party is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data (e.g., names, e-mail addresses, etc.).

Storage Duration

Unless a more specific storage period has been stated within this privacy policy, your personal data will remain with us until the purpose for the data processing no longer applies. If you make a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g., retention periods under tax or commercial law); in the latter case, the data will be deleted once these reasons no longer apply.

General Information on the Legal Basis for Data Processing on This Website

If you have consented to data processing, we process your personal data based on Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR if special categories of data according to Art. 9(1) GDPR are processed. In the case of explicit consent to the transfer of personal data to third countries, the data processing is additionally based on Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or access to information on your device (e.g., via device fingerprinting), the data processing is also based on § 25(1) TTDSG. Consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data based on Art. 6(1)(b) GDPR. Furthermore, we process your data if it is necessary for the fulfillment of a legal obligation based on Art. 6(1)(c) GDPR. Data processing can also be based on our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis for each individual case can be found in the following paragraphs of this privacy policy.

Notice on Data Transfer to Non-Secure Third Countries and the Transfer to US Companies That Are Not DPF-Certified

We use tools from companies based in non-secure third countries in terms of data protection, as well as US tools whose providers are not certified under the EU-US Data Privacy Framework (DPF). When these tools are active, your personal data may be transferred to these countries and processed there. We point out that in non-secure third countries, no level of data protection comparable to that in the EU can be guaranteed.

We would like to point out that the USA is generally considered a secure third country with a data protection level comparable to that of the EU. Data transfer to the USA is permissible if the recipient is certified under the “EU-US Data Privacy Framework” (DPF) or has suitable additional guarantees. Information on transfers to third countries, including the recipients of the data, can be found in this privacy policy.

Recipients of Personal Data

In the course of our business activities, we work with various external parties. This sometimes requires the transfer of personal data to these external parties. We only transfer personal data to external parties if this is necessary for contract fulfillment, if we are legally obligated to do so (e.g., data transfer to tax authorities), if we have a legitimate interest in the data transfer based on Art. 6(1)(f) GDPR, or if another legal basis permits the data transfer. When using processors, we only transfer personal data of our customers based on a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.

Revocation of Your Consent to Data Processing

Many data processing operations are only possible with your explicit consent. You can revoke consent that you have already given at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Right to Object to Data Collection in Special Cases and to Direct Advertising (Art. 21 GDPR)

IF DATA PROCESSING IS BASED ON ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, RIGHTS, AND FREEDOMS OR THE PROCESSING IS FOR THE ESTABLISHMENT, EXERCISE, OR DEFENSE OF LEGAL CLAIMS (OBJECTION ACCORDING TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA FOR SUCH MARKETING, INCLUDING PROFILING TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL THEN NO LONGER BE USED FOR DIRECT MARKETING PURPOSES (OBJECTION ACCORDING TO ART. 21(2) GDPR).

Right to Lodge a Complaint with the Competent Supervisory Authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, particularly in the member state of their habitual residence, place of work, or place of the alleged violation. This right to lodge a complaint exists without prejudice to other administrative or judicial remedies.

Right to Data Portability

You have the right to have data that we process based on your consent or in fulfillment of a contract automatically delivered to you or a third party in a commonly used, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done to the extent technically feasible.

Information, Correction, and Deletion

Within the framework of the applicable legal provisions, you have the right to free information about your stored personal data, its origin and recipients, and the purpose of the data processing, and if applicable, a right to correction or deletion of this data. For this, as well as for further questions on the topic of personal data, you can contact us at any time.

Right to Restrict Processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restrict processing exists in the following cases:

  • If you contest the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.

  • If the processing of your personal data happened/ happens unlawfully, you can request the restriction of data processing instead of deletion.

  • If we no longer need your personal data but you need it for exercising, defending, or asserting legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.

  • If you have lodged an objection according to Art. 21(1) GDPR, a balance must be struck between your interests and ours. As long as it is not yet clear whose interests predominate, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – apart from their storage – may only be processed with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a member state.

SSL or TLS Encryption

This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or inquiries you send to us as the site operator. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Objection to Promotional Emails

We hereby object to the use of contact data published as part of the imprint’s’s obligation to send unsolicited advertising and information materials. The operators of the pages expressly reserve the right to take legal action in the event of unsolicited sending of advertising information, such as spam emails.

4. Data Collection on This Website

Cookies

Our websites use “cookies.” Cookies are small data packets that do not harm your device. They can be temporarily stored for the duration of a session (session cookies) or permanently (persistent cookies) on your device. Session cookies are automatically deleted after your visit ends. Persistent cookies remain stored on your device until you delete them or they are automatically deleted by your web browser.

Cookies can be either first-party cookies (set by us) or third-party cookies (set by third-party companies). Third-party cookies enable the integration of certain services from third-party companies within websites (e.g., cookies for processing payment services).

Cookies serve various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g., shopping cart function or video display). Other cookies can be used to analyze user behavior or for advertising purposes.

Cookies necessary for the electronic communication process, for providing specific functions requested by you (e.g., shopping cart function), or for optimizing the website (e.g., cookies for measuring web audience) are stored based on Art. 6(1)(f) DSGVO unless a different legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of its services. If consent for storing cookies and similar recognition technologies was requested, the processing is based exclusively on this consent (Art. 6(1)(a) DSGVO and § 25(1) TDDG); the consent can be revoked at any time.

You can configure your browser to notify you about the setting of cookies and allow cookies only in individual cases, exclude the acceptance of cookies for certain cases or in general, and enable the automatic deletion of cookies when closing the browser. Disabling cookies may limit the functionality of this website.

You can find out which cookies and services are used on this website in this privacy policy.

Data Processing Agreement

We have concluded a data processing agreement (DPA) for the use of the above service. This is a contract required by data protection law, ensuring that this service processes the personal data of our website visitors only according to our instructions and in compliance with the DSGVO.

Server Log Files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

  • Browser type and browser version

  • Operating system used

  • Referrer URL

  • Hostname of the accessing computer

  • Time of the server request

  • IP address

This data is not combined with other data sources.

The collection of this data is based on Art. 6(1)(f) DSGVO. The website operator has a legitimate interest in the technically error-free presentation and optimization of its website – for this purpose, the server log files must be recorded.

Contact Form

If you send us inquiries via the contact form, your details from the inquiry form, including the contact data you provided there, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We do not share this data without your consent.

The processing of this data is based on Art. 6(1)(b) DSGVO if your inquiry is related to the fulfillment of a contract or necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries directed to us (Art. 6(1)(f) DSGVO) or on your consent (Art. 6(1)(a) DSGVO) if this was requested; the consent can be revoked at any time.

The data you entered in the contact form will remain with us until you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies (e.g., after your request has been processed). Mandatory legal provisions – especially retention periods – remain unaffected.

Request by E-Mail, Phone, or Fax

If you contact us by e-mail, phone, or fax, your request, including all resulting personal data (name, request), will be stored and processed by us for the purpose of processing your request. We do not share this data without your consent.

The processing of this data is based on Art. 6(1)(b) DSGVO if your request is related to the fulfillment of a contract or necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the inquiries directed to us (Art. 6(1)(f) DSGVO) or on your consent (Art. 6(1)(a) DSGVO) if this was requested; the consent can be revoked at any time.

The data you send to us via contact inquiries will remain with us until you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies (e.g., after your request has been processed). Mandatory legal provisions – especially legal retention periods – remain unaffected.

Data Processing Agreement

We have concluded a data processing agreement (DPA) for the use of the above service. This is a contract required by data protection law, ensuring that this service processes the personal data of our website visitors only according to our instructions and in compliance with the DSGVO.

5. Analytics Tools and Advertising

Google Tag Manager

We use Google Tag Manager, provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Google Tag Manager is a tool that helps us integrate tracking or statistical tools and other technologies on our website. The Tag Manager itself does not create user profiles, store cookies, or conduct its own analyses. It merely facilitates the management and deployment of the tools integrated through it. However, Google Tag Manager does capture your IP address, which may be transmitted to Google’s parent company in the United States.

The use of Google Tag Manager is based on Art. 6(1)(f) of the GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and management of various tools on his website. If consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, to the extent that the consent includes the storage of cookies or access to information on the user’s device (e.g., device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the United States to ensure compliance with European data protection standards in US data processing. Each company certified under the DPF commits to adhering to these data protection standards. More information can be found at the following link: DPF Participant Search.

Google Analytics

This website uses functions of the web analytics service Google Analytics, provided by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior of website visitors. The website operator receives various usage data, such as page views, duration of visits, operating systems used, and the user’s origin. This data is assigned to the user’s respective device. No user ID assignment is carried out.

Furthermore, we can record your mouse and scroll movements and clicks with Google Analytics. Google Analytics also uses various modeling approaches to supplement the collected datasets and employs machine learning technologies in data analysis.

Google Analytics uses technologies that allow the recognition of users for the purpose of analyzing their behavior (e.g., cookies or device fingerprinting). The information collected by Google about the use of this website is generally transmitted to a Google server in the USA and stored there.

The use of this service is based on your consent under Art. 6(1)(a) GDPR and § 25(1) TDDDG. Consent can be revoked at any time.

Data transfer to the USA is based on the EU Commission’s standard contractual clauses. Details can be found here: Google’s Data Privacy.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the United States to ensure compliance with European data protection standards in US data processing. Each company certified under the DPF commits to adhering to these data protection standards. More information can be found at the following link: DPF Participant Search.

IP Anonymization

We have activated IP anonymization on this website. As a result, your IP address is truncated by Google within member states of the European Union or other parties to the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, compile reports on website activity, and provide other services related to website and internet usage for the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google.

Browser Plugin

You can prevent the collection and processing of your data by Google by downloading and installing the browser plugin available at the following link: Google Opt-out Plugin.

More information on how Google Analytics handles user data can be found in Google’s privacy policy: Google Support.

Contract Data Processing

We have entered into a contract data processing agreement with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

Google Ads

The website operator uses Google Ads, an online advertising program of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads enables us to display advertisements in the Google search engine or on third-party websites when the user enters specific search terms in Google (keyword targeting). Additionally, targeted ads can be displayed based on user data available to Google (e.g., location data and interests) (audience targeting). As the website operator, we can quantitatively evaluate this data by analyzing, for example, which search terms led to the display of our ads and how many ads resulted in corresponding clicks.

The use of this service is based on your consent under Art. 6(1)(a) GDPR and § 25(1) TDDDG. Consent can be revoked at any time.

Data transfer to the USA is based on the EU Commission’s standard contractual clauses. Details can be found here: Google Policies and Google Controller Terms.

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the United States to ensure compliance with European data protection standards in US data processing. Each company certified under the DPF commits to adhering to these data protection standards. More information can be found at the following link: DPF Participant Search.

LinkedIn Insight Tag

This website uses the Insight Tag from LinkedIn, provided by LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

Data Processing by LinkedIn Insight Tag

The LinkedIn Insight Tag allows us to obtain information about visitors to our website. If a website visitor is registered with LinkedIn, we can analyze the professional data of our website visitors (e.g., career level, company size, country, location, industry, and job title) and better tailor our site to our target audiences. Furthermore, we can measure whether visitors to our websites complete a purchase or perform another action (conversion measurement). Conversion measurement can also occur across devices (e.g., from PC to tablet). LinkedIn Insight Tag also offers a retargeting function that allows us to show visitors to our website targeted advertising outside the website, without identifying the advertising recipient, according to LinkedIn.

LinkedIn also collects so-called log files (URL, referrer URL, IP address, device and browser characteristics, and time of access). The IP addresses are truncated or (if used to reach LinkedIn members across devices) hashed (pseudonymized). Direct identifiers of LinkedIn members are deleted by LinkedIn after seven days. The remaining pseudonymized data is then deleted within 180 days.

The data collected by LinkedIn cannot be assigned to specific individuals by us as the website operator. LinkedIn will store the collected personal data of website visitors on its servers in the USA and use it for its own advertising purposes. For details, please refer to LinkedIn’s privacy policy: LinkedIn Privacy Policy.

Legal Basis

If consent has been requested, the use of the above service is based exclusively on Art. 6(1)(a) GDPR and § 25 TDDDG. Consent can be revoked at any time. If no consent was requested, the use of this service is based on Art. 6(1)(f) GDPR; the website operator has a legitimate interest in effective advertising measures, including social media.

Data transfer to the USA is based on the EU Commission’s standard contractual clauses. Details can be found here: LinkedIn DPA and LinkedIn SCCs.

Objection to LinkedIn Insight Tag

You can object to the analysis of your usage behavior and targeted advertising by LinkedIn via the following link: LinkedIn Retargeting Opt-out.

In addition, LinkedIn members can control the use of their personal data for advertising purposes in their account settings. To prevent LinkedIn from linking the data collected on our website with your LinkedIn account, you must log out of your LinkedIn account before visiting our website.

Contract Data Processing

We have entered into a contract data processing agreement to use the above service. This is a data protection contract required by law to ensure that the service processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

6. Newsletter

Newsletter Data

If you wish to receive the newsletter offered on the website, we require an email address from you and information that allows us to verify that you are the owner of the provided email address and agree to receive the newsletter. Additional data will not be collected or only on a voluntary basis. We use this data exclusively for sending the requested information and do not pass it on to third parties.

The processing of the data entered in the newsletter registration form is based solely on your consent (Art. 6(1)(a) GDPR). You can revoke your consent to the storage of the data, the email address, and its use for sending the newsletter at any time, for example, via the “unsubscribe” link in the newsletter. The legality of the data processing operations already carried out remains unaffected by the revocation.

The data you provide to us for the purpose of receiving the newsletter will be stored by us until you unsubscribe from the newsletter and deleted from the newsletter distribution list after you unsubscribe. Data that we have stored for other purposes remains unaffected.

After unsubscribing from the newsletter distribution list, your email address may be stored in a blacklist with us or the newsletter service provider if this is necessary to prevent future mailings. The data from the blacklist will only be used for this purpose and not merged with other data. This serves both your interest and our interest in complying with legal requirements for sending newsletters (legitimate interest under Art. 6(1)(f) GDPR). The storage in the blacklist is indefinite. You can object to the storage if your interests outweigh our legitimate interest.

7. Plugins and Tools

Google Fonts (local hosting)

This site uses Google Fonts for uniform font representation, provided by Google. The Google Fonts are installed locally. No connection to Google servers takes place.

For more information about Google Fonts, please see Google Fonts FAQ and Google’s privacy policy: Google Policies.