© 2019 by haloo.io

Privacy Policy

(Updated: 17.6.2019)

We are delighted that you are interested in our enterprise. Privacy is a very important issue for siracusa UG (haftungsbeschränkt). It is possible to use our websites without any indication of personal data. Nonetheless, if a data subject wants to use special services of our website, processing of personal data could become mandatory. If the processing of personal data is necessary and there is no alternative legal basis for such processing, we generally acquire consent from the data subject.
Processing of personal data, for instance the name, address, telephone number, or email address of a data subject should always be in accordance with the General Data Regulation (GDPR) but also with country-specific data protection regulations suitable to siracusa UG (haftungsbeschränkt).
By means of this privacy policy, our enterprise would like to instruct the general public of the nature, extent, and ambition of the personal data we gather, use and protect. Apart from that, this privacy policy informs data subjects of the rights to which they are entitled.
The siracusa UG (haftungsbeschränkt) has implemented multiple organisational and technical measures to assure the most complete protection of personal data processed through this website. Yet, absolute protection may not be guaranteed because online data transmission suffers from general security gaps. Taking that into account, every data subject is free to transmit personal data to us through alternative means, e.g. by phone or snail mail.

 

1. Terminology

 

Our privacy policy makes use of the terms used by the European legislator in the General Data Protection Regulation (GDPR). We designed our privacy policy to be easy and understandable for the general public as well as consumers, customers and our business partners. This terminology shall be defined and explained as follows.

 

a) Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

 

b) Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

 

c) Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

 

d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

 

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

 

f) Pseudonymisation

Pseudonymisation is the processing of personal data in such a manner 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 is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

 

g) Controller or controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

 

h) Processor

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

 

i) Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.

 

j) Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

k) Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

 

2. Data Controller

 

Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:

 

siracusa UG (haftungsbeschränkt)
Jägerstraße 63c
D - 10117 Berlin

Tel: 030 – 55572862
Mail: info [at] haloo.io

Geschäftsführer: Robert Enderlein

Eingetragen beim Amtsgericht Charlottenburg Berlin, HRB 205023 B

USt.-IdNr: DE322960909

Website: haloo.io

 

4. Cookies

 

Our website uses cookies to improve user experience and to make your visit to our website more convenient. Cookies are little text files which are stored on a computer system via a web browser.

Numerous websites and servers make use of cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie itself. It consists of a string of characters through which internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This enables the visited websites and servers to distinguish the individual browser of the visitor from other web browsers that contain other cookies. A particular browser can be recognised and identified by its unique cookie ID.

By using cookies, siracusa UG (haftungsbeschränkt) can provide users of its website with more user-friendly services that would not be possible without them.

By means of a cookie, the information and offers on our website can be optimised in the interests of the user. As already mentioned, cookies enable us to recognize the users of our website. The purpose of this identification is to make it easier for users to use our website. For example, the user of a website that uses cookies does not have to re-enter his access data each time he visits the website because this is done by the website and the cookie stored on the user's computer system automatically. A further example is the cookie of a shopping basket in an online shop. The online shop remembers the items that a customer has placed in the virtual shopping basket via using a cookie.

The person concerned can prevent the setting of cookies by our website at any time by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. Moreover, cookies that have already been set can be deleted at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. If the person concerned deactivates the setting of cookies in the Internet browser used, not all functions of our website may be fully usable under certain circumstances.

 

5. General Information and Data Collection

 

Our website records a series of general data and information each time it is accessed by a data subject or an automated system. These general data and information are stored in our server’s log files. Recorded may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system accesses our website (so-called referrer), (4) the sub-sites which are accessed via an accessing system on our website, (5) the date and time of a visit to our website, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system and (8) other similar data and information used to avert dangers in the event of attacks on our information technology systems.

siracusa UG (haftungsbeschränkt) does not draw any conclusions about the person concerned when using this general data and information. Rather, this information is required to (1) correctly deliver the content of our website, (2) optimise the content of our website and the advertising for it, (3) guarantee the long-term functionality of our information technology systems and the technology of our website and (4) provide law enforcement authorities with the information necessary for criminal prosecution in the event of a cyber-attack. These anonymous data and information are therefore evaluated by siracusa UG (haftungsbeschränkt) both statistically and with the aim of increasing privacy and data security in our company in order to ultimately ensure an optimum level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by the person concerned.

 

6. Contact Possibility 

 

Our website inheres information that enables a fast electronic contact to us as well as direct communication with us, which also includes an electronic mail address (e-mail address). If a data subject contacts the controller by e-mail or via our contact form, the personal data transmitted by the data subject are automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the data controller are stored for the purpose of processing or contacting the data subject. We do not transmit this personal data to third parties.

 

7. Regular erasure and blocking of personal data

 

We will process and store the personal data of the data subject only for the period of time necessary to achieve the storage purpose or in cases provided for by the European lawmaker or another legislator in laws or regulations to which the controller is subject. If the storage purpose no longer exists or if a storage period prescribed by a European directive or regulation or another competent legislator expires, the personal data will be blocked or deleted routinely and in accordance with the statutory provisions.

 

8. Rights of the Data Subject

 

a) Right to Confirmation

Every data subject shall have the right, granted by the GDPR, to obtain from the controller confirmation as to whether personal data relating to him or her are being processed. If a data subject wishes to exercise this right of confirmation, he or she may at any time contact the controller.

 

b) Right to Access 

Any person concerned by the processing of personal data has the right, granted by the GDPR, to obtain at any time, free of charge, from the controller, information on the personal data relating to him which have been stored and a copy of that information. Furthermore, the European Data Protection Supervisor has granted the data subject access to the following information:

-the purposes of the processing

-the categories of personal data processed

-the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations

-if possible, the planned duration for which the personal data will be stored or, if that is not possible, the criteria for determining that duration

-the existence of a right to the rectification or erasure of personal data concerning him or her or to the limitation of the processing carried out by the controller or of a right to object to such processing

-the existence of a right of appeal to a supervisory authority

-if the personal data are not collected from the data subject itself, all available information on the origin of the data

-the existence of automated decision-making, including profiling, in accordance with Article 22(1) and (4) of the DS Block Exemption Regulation and, at least in these cases, meaningful information on the logic involved, the scope and the intended effects of such processing on the data subject

The data subject also has the right to know whether personal data have been transferred to a third country or to an international organisation. If this is the case, the data subject shall also have the right to obtain information on the appropriate safeguards in connection with the transfer.

If a data subject wishes to exercise this right to access, he or she may at any time contact the controller.

 

c) Right to rectification 

Any person concerned by the processing of personal data has the right, granted by the GDPR, to request the rectification without delay of inaccurate personal data concerning him or her. Furthermore, the data subject shall have the right, having regard to the purposes of the processing, to request the completion of incomplete personal data, including by means of a supplementary statement.

If a data subject wishes to exercise this right of rectification, he or she may at any time contact a member of staff of the controller.

 

d) Right to Deletion (Right to be forgotten) 

Any data subject to the processing of personal data has the right, granted by the GDPR, to require the controller to erase without delay personal data concerning him or her which are subject to one of the following conditions and the processing is not necessary:

-Personal data have been collected or otherwise processed for purposes for which they are no longer necessary.

-The data subject withdrew his consent on which the processing was based pursuant to Art. 6 (1) lit. a GDPR or Art 9 (2) lit. a GDPR and there is no other legal basis for the processing.

-The data subject objects to the processing under Article 21 (1) DS Block Exemption Regulation and there are no superior legitimate reasons for the processing or the data subject objects to the processing under Article 21 (2) DS Block Exemption Regulation.

-The personal data have been processed unlawfully.

-The deletion of the personal data is necessary to fulfil a legal obligation under EU law or the law of the Member States to which the controller is subject.

-The personal data were collected in relation to information society services offered pursuant to Art. 8 (1) GDPR.

If one of the above reasons applies and a person concerned wishes to have personal data stored at siracusa UG (haftungsbeschränkt) deleted, he or she can contact us at any time. We will ensure that the request for deletion is complied with immediately.

If the personal data has been made public by siracusa UG (haftungsbeschränkt) and our company is responsible pursuant to Art. 17 (1) GDPR, the siracusa UG (haftungsbeschränkt) will take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform other persons responsible for data processing who process the published personal data that the person concerned has requested the deletion of all links to this personal data or copies or replications thereof from these other persons responsible for data processing insofar as the processing is not necessary. We will take the necessary steps in individual cases.

 

e) Right to Limitation of Processing 

Any data subject to the processing of personal data has the right, granted by the GDPR, to request the controller to limit the processing if one of the following conditions is met:

-The accuracy of the personal data is being contested by the data subject for a period of time which allows the controller to verify the accuracy of the personal data.

-The processing is unlawful and the data subject refuses to erase the personal data and instead requests that the use of the personal data be restricted.

-The controller no longer needs the personal data for the purposes of processing, but the data subject needs them for the assertion, exercise or defense of legal rights.

-The data subject has lodged an objection to the processing pursuant to Art. 21 (1) GDPR and it is not yet clear whether the legitimate reasons of the data controller outweigh those of the data subject.

If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored at siracusa UG (haftungsbeschränkt), he or she can contact us at any time. We will then arrange for the processing to be restricted.

 

f) Right to Data Transferability 

Any data subject involved in the processing of personal data has the right, granted by the GDPR, to obtain personal data concerning him or her which have been provided by the data subject to a controller in a structured, common and machine-readable format. He or she also has the right to having these data transferred to another controller without being hindered by the controller to whom the personal data have been provided, that the processing is based on a consent pursuant to Art. 6 (1) lit. a GDPR or Art. 9 (2) lit. a GDPR or on a contract pursuant to Art. 6 (1) lit. b GDPR and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority entrusted to the controller.

Furthermore, when exercising his or her right to data transferability pursuant to Art. 20 (1) GDPR, the data subject has the right to obtain that the personal data be transferred directly from one data controller to another data controller insofar as this is technically feasible and insofar as this does not impair the rights and freedoms of other persons.

In order to assert the right to data transfer, the person concerned may at any time contact us.

 

g) Right to Appeal 

Any person subject to the processing of personal data has the right, granted by the GDPR, to object at any time, for reasons related to his or her particular situation, to the processing of personal data concerning him or her on the basis of Art. 6 (1) lit. e or lit. f GDPR. This also applies to profiling based on these provisions.

The siracusa UG (haftungsbeschränkt) will no longer process the personal data in the event of objection unless we can prove compelling reasons for the processing worthy of protection which outweigh the interests, rights and freedoms of the person concerned, or the processing serves the assertion, exercise or defense of legal claims.

If the siracusa UG (haftungsbeschränkt) processes personal data in order to conduct direct advertising, the person concerned has the right to object at any time to the processing of personal data for the purpose of such advertising. This also applies to profiling as far as it is connected with such direct advertising. If the data subject objects to the processing for direct marketing purposes by siracusa UG (haftungsbeschränkt), we no longer process the personal data for these purposes.

In addition, the data subject has the right to object to the processing of personal data relating to him or her by siracusa UG (haftungsbeschränkt) for scientific or historical research purposes or for statistical purposes pursuant to Art. 89 (1) GDPR for reasons arising from his or her particular situation, unless such processing is necessary for the performance of a task in the public interest.

In order to exercise the right to object, the data subject may directly address us. The data subject is also free to exercise his or her right of objection in connection with the use of information society services, notwithstanding Directive 2002/58/EC, by means of automated procedures in which technical specifications are used.

 

h) Automated individual Case Decisions including Profiling 

Any data subject has the right, granted by GDPR, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects upon him or her or significantly affects him or her in a similar manner, provided that the decision (1) is not necessary for the conclusion or performance of a contract between the data subject and the data controller, or (2) is authorised by EU or national law or by the Member States to which the data controller is subject and which provides for adequate measures to safeguard the rights and freedoms and the legitimate interests of the data subject, or (3) is taken with the express consent of the data subject.

If the decision (1) is necessary for the completion or performance of a contract between the data subject and the data subject or (2) is made with the express consent of the data subject, the siracusa UG (haftungsbeschränkt) will take appropriate measures to safeguard the rights and freedoms as well as the legitimate interests of the data subject, including at least the right to obtain the intervention of a person on the part of the data subject, to state his or her own position and to challenge the decision.

If the data subject wishes to assert rights relating to automated decisions, he or she may at any time contact us.

 

i) Right to revoke Consent under Privacy Law 

Any person concerned by the processing of personal data has the right, granted by the GDPR, to revoke consent to the processing of personal data at any time.

If the data subject wishes to exercise his or her right to withdraw consent, he or she may at any time do so by contacting us.

 

9. Privacy Provisions for the Use of PayPal as a Payment Processor

 

The controller has integrated components of PayPal on this website. PayPal is an online payment service provider. Payments are processed through so-called PayPal accounts, which represent business or virtual private accounts. In case a user does not have such an account, PayPal is also able to process virtual payments via credit and debit cards. The account is managed via an e-mail address. That is why there are no classic account numbers. PayPal facilitates to trigger online payments to third parties or to receive payments. PayPal also accepts trustee functions and offers buyer protection services.

The European operating company of PayPal is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal L-2449, Luxemburg.

We automatically transmit the data of the data subject to PayPal, if the data subject chooses "PayPal" as the payment option in the online shop during the ordering process. By choosing this payment option, the data subject agrees to the transfer of personal data required for payment processing.

Usually the personal data transmitted to PayPal is the first name, last name, address, email address, telephone number, IP address, mobile phone number, or other data necessary for payment processing. The processing of the purchase contract also calls for such personal data, which are connected with the respective order.

The transmission of the data aims for payment processing and fraud prevention. If a legitimate interest in the transmission is given, the controller will in particular transfer personal data to PayPal. The processing of the personal data, which is exchanged between PayPal and the controller for the processing of the data, will be transmitted by PayPal to credit agencies. This transmission is necessary for identity and creditworthiness checks.

If necessary, PayPal will pass on personal data to affiliates and service providers or subcontractors to the degree that is required to fulfil contractual obligations or for data to be processed in the order.

At any time, the data subject has the possibility to revoke consent for the handling of personal data from PayPal. A revocation does not have any effect on personal data which must be processed, used or transmitted in accordance with (contractual) payment processing.

The applicable privacy provisions of PayPal may be retrieved under https://www.paypal.com/us/webapps/mpp/ua/privacy-full.

 

10. Privacy Provisions for the youcanbook.me Tool 

 

Our website enables users to schedule appointments with us. To provide this service we use a tool, i.e. a plugin, called youcanbook.me. If you use this tool to schedule an appointment with us, personal data will be processed and transferred to youcanbook.me.

Provider of the service is YouCanBook.me Ltd., 38 Mill Street, Bedford, MK40 3 HD, United Kingdom.

The following personal data of the user will be transferred to youcanbook.me:

Name, Surname, phone number, email address as well as additional information necessary for the appointment. This processing is based on the voluntary consent of the user and therefore rests upon Art. 6 (1) lit. a DSGVO. The user’s consent can be revoked at any given time. However, such revocation does not affect prior data processing. In case the user chooses not to provide personal data, he or she may not be able to use our appointment scheduling service.

 

11. Privacy Provisions for Credit Card Payment 

 

We provide users with the possibility to use a credit card or a debit card for payment. For processing such a payment, some of the user’s personal data is required. The payment process itself will show the user which specific personal data is required.

Such data involves the user’s name, surname, address, email address, credit card number or debit card number, card owner and the card’s expiration date. To prevent abuse and fraud we check the personal data entered with regard to the payment with the data of the order. Once this check is successful, we use the personal data for processing the payment.

The legal basis for such data processing is Art. 6 (1) lit. b DSGVO.

Personal data processed for providing this payment method will be stored for 24 months for reasons of security and fraud prevention.

In case the user does not want to provide us with the data, he or she will not be able to use the credit or debit card payment method.

 

12. Privacy Provisions for Bank Transfers 

 

We provide users with the possibility to make payments via bank transfer. For processing such a payment, some of the user’s personal data is required. The payment process itself will show the user which specific personal data is required.

Such data involves the user’s bank account number or IBAN, the name of the account owner and the name of the bank. To prevent abuse and fraud we check the personal data entered with regard to the payment with the data of the order. Once this check is successful, we use the personal data for processing the payment.

The legal basis for such data processing is Art. 6 (1) lit. b DSGVO.

In case the user does not want to provide us with the data, he or she will not be able to use the credit or debit card payment method.

 

13. Privacy Policy for Jotforms 

 

Our website uses a plugin provided by Jotform to enable us to offer and maintain a contact form as well as a means of direct communication with us.

Jotform is a service provided by JotForm Inc., 1700 Montgomery St, San Francisco, CA 94111, USA.

Jotform is member of the US-EU Privacy Shield.

The personal data a data subject enters into our contact form will be transferred to Jotform’s servers situated within the European Union. The specific personal data being processed by our contact form can be found in the form itself. Such voluntarily entered data will be stored on Jotform’s EU-based servers and used by the controller to process and answer the data subject’s request. Purpose of the data processing is to provide our visitors with a contact form. Legal basis therefore is art. 6 sec. 1 lit. b) of the GDPR. The storage period of the personal data depends on the data subject’s purpose of the request. Requests that do not lead to a contract between the controller and the data subject will be deleted automatically after six months. Statutory storage periods shall remain unaffected.

The data controller and Jotform agreed to a data processing addendum.

Further information as well as Jotform’s Privacy Policy can be found here: http://www.jotform.com/privacy/

 

14. Legal Basis for the Processing 

 

Art. 6 (1) lit. a GDPR serves our company as a legal basis for processing operations in which we obtain consent for specific processing purposes. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, with processing operations that are necessary for the delivery of goods or the provision of other services or consideration, the processing is based on Art. 6 (1) lit. b GDPR. The same shall apply to such processing operations which are necessary for the implementation of pre-contractual measures, for example in cases of inquiries regarding our products or services. If our company is subject to a legal obligation which requires the processing of personal data, such as for the fulfilment of tax obligations, the processing is based on Art. 6 (1) lit. c GDPR. In rare cases, the processing of personal data may become required in order to protect the vital interests of the data subject or another natural person. This would be the case, for example, if a visitor to our website were injured and his name, age, health insurance information or other vital information that would have to be disclosed to a doctor, hospital or other third party. Then the processing would be based on Art. 6 (1) lit. d GDPR. Ultimately, processing operations could be based on Art. 6 (1) lit. f GDPR. Processing operations that are not covered by any of the aforementioned legal bases are based on this legal basis if the processing is necessary to safeguard a legitimate interest of our company or a third party, provided that the interests, fundamental rights and fundamental freedoms of the data subject do not predominate. Such processing operations are permitted to us in particular because they have been specifically mentioned by the European legislator. In this respect, the view was tanken that a legitimate interest could be assumed if the data subject is a customer of the data controller (recital 47 sentence 2 GDPR).

 

15. The legitimate Interests pursued by the Controller or by a Third Party 

 

If the processing of personal data is based on Article 6 (1) lit. f GDPR, our legitimate interest is the conduct of our business for the benefit of all our employees and shareholders.

 

16. Period for which the personal data will be stored

 

The criterion for the duration of the storage of personal data is the respective legal retention period. After this period has expired, the corresponding data will be routinely deleted unless they are no longer required for the fulfilment or initiation of a contract.

 

17. Provision of Personal Data as Requirement; Requirement necessary to enter into a contract; Obligation of the Data Dubject to provide Personal Data; possible Consequences of Failure to provide such Data

 

We clarify that the provision of personal data is partly presupposed by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). It may be necessary to conclude a contract that the data subject provides us with personal data, which need to be post hoc processed by us. For example, the data subject is obliged to provide us with personal data when our company signs a contract with him or her. In case of non-provision of personal data the contract with the data subject could not be concluded. The data subject can contact any of our employees before personal data is provided by himself or herself. The employee elucidates to the data subject whether the provision of the personal data is required by law or contract or is mandatory for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

 

18. Existence of automated decision-making

 

As a responsible company, we refrain from automatic decision-making or profiling.

haloo.io

siracusa UG (haftungsbeschränkt)

Jägerstraße 63c

D - 10117 Berlin