Privacy Policy

1. An overview of data protection

General information

The following
information will provide you with an easy to navigate overview of what will
happen with your personal data when you visit this website. The term “personal
data” comprises all data that can be used to personally identify you. For
detailed information about the subject matter of data protection, please
consult our Data Protection Declaration, which we have included beneath this
copy.

Data recording on this website

Who is the responsible party for the recording of data
on this website (i.e. the “controller”)?

The data on this
website is processed by the operator of the website, whose contact information
is available under section “Information Required by Law” on this website.

How do we record your data?

We collect your
data as a result of your sharing of your data with us. This may, for instance
be information you enter into our contact form.

Other data shall
be recorded by our IT systems automatically or after you consent to its
recording during your website visit. This data comprises primarily technical
information (e.g. web browser, operating system or time the site was accessed).
This information is recorded automatically when you access this website.

What are the purposes we use your data for?

A portion of the
information is generated to guarantee the error free provision of the website.
Other data may be used to analyze your user patterns.

What rights do you have as far as your information is
concerned?

You have the
right to receive information about the source, recipients and purposes of your
archived personal data at any time without having to pay a fee for such
disclosures. You also have the right to demand that your data are rectified or
eradicated. If you have consented to data processing, you have the option to
revoke this consent at any time, which shall affect all future data processing.
Moreover, you have the right to demand that the processing of your data be
restricted under certain circumstances. Furthermore, you have the right to log
a complaint with the competent supervising agency.

Please do not
hesitate to contact us at any time under the address disclosed in section
“Information Required by Law” on this website if you have questions about this
or any other data protection related issues.

Analysis tools and tools provided by third parties

There is a
possibility that your browsing patterns will be statistically analyzed when
your visit this website. Such analyses are performed primarily with what we
refer to as analysis programs.

For detailed
information about these analysis programs please consult our Data Protection
Declaration below.

2. Hosting and Content Delivery Networks (CDN)

External Hosting

This website is
hosted by an external service provider (host). Personal data collected on this
website are stored on the servers of the host. These may include, but are not
limited to, IP addresses, contact requests, metadata and communications,
contract information, contact information, names, web page access, and other
data generated through a web site.

The host is used
for the purpose of fulfilling the contract with our potential and existing
customers (Art. 6 para. 1 lit. b GDPR) and in the interest of secure, fast and
efficient provision of our online services by a professional provider (Art. 6
para. 1 lit. f GDPR).

Our host will
only process your data to the extent necessary to fulfil its performance
obligations and to follow our instructions with respect to such data.

Execution of a contract data processing agreement

In order to
guarantee processing in compliance with data protection regulations, we have
concluded an order processing contract with our host.

3. General information and mandatory information

Data protection

The operators of
this website and its pages take the protection of your personal data very
seriously. Hence, we handle your personal data as confidential information and
in compliance with the statutory data protection regulations and this Data
Protection Declaration.

Whenever you use
this website, a variety of personal information will be collected. Personal
data comprises data that can be used to personally identify you. This Data
Protection Declaration explains which data we collect as well as the purposes
we use this data for. It also explains how, and for which purpose the
information is collected.

We herewith
advise you that the transmission of data via the Internet (i.e. through e-mail
communications) may be prone to security gaps. It is not possible to completely
protect data against third party access.

Information about the responsible party (referred to
as the “controller” in the GDPR)

The data
processing controller on this website is:

Twist & Schirm Social Media GmbH
Leopoldstraße 31
80802 München

Phone: +49 157
5594 8593
E-mail: hello@twistundschirm.de

The controller
is the natural person or legal entity that single-handedly or jointly with
others makes decisions as to the purposes of and resources for the processing
of personal data (e.g. names, e-mail addresses, etc.).

Designation of a data protection officer as mandated
by law

We have
appointed a data protection officer for our company.

Jörg Hermann
jmh datenschutzberatung
c/o Werk1
Atelierstr. 29
81541 München

https://jmh-datenschutz.de

Phone: +49 170 1131871
E-mail: info@jmh-datenschutz.de

Revocation of your consent to the processing of data

A wide range of
data processing transactions are possible only subject to your express consent.
You can also revoke at any time any consent you have already given us. This
shall be without prejudice to the lawfulness of any data collection that
occurred prior to your revocation.

Right to object to the collection of data in special
cases; right to object to direct advertising (Art. 21 GDPR)

IN THE EVENT
THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6 SECT. 1 LIT. E OR F GDPR, YOU
HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA
BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY
PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY
PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION.
IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA,
UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR
THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS
OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF
LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21 SECT. 1 GDPR).

IF YOUR PERSONAL
DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE
RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA
FOR THE PURPOSES OF SUCH ADVERTISING. THIS ALSO APPLIES TO PROFILING TO THE
EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR
PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING
PURPOSES (OBJECTION PURSUANT TO ART. 21 SECT. 2 GDPR).

Right to log a complaint with the competent
supervisory agency

In the event of
violations of the GDPR, data subjects are entitled to log a complaint with a
supervisory agency, in particular in the member state where they usually
maintain their domicile, place of work or at the place where the alleged
violation occurred. The right to log a complaint is in effect regardless of any
other administrative or court proceedings available as legal recourses.

Right to data portability

You have the
right to demand that we hand over any data we automatically process on the
basis of your consent or in order to fulfil a contract be handed over to you or
a third party in a commonly used, machine readable format. If you should demand
the direct transfer of the data to another controller, this will be done only
if it is technically feasible.

SSL and/or TLS encryption

For security
reasons and to protect the transmission of confidential content, such as
purchase orders or inquiries you submit to us as the website operator, this
website uses either an SSL or a TLS encryption program. You can recognize an
encrypted connection by checking whether the address line of the browser
switches from “http://” to “https://” and also by the appearance of the lock
icon in the browser line.

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

Information about, rectification and eradication of
data

Within the scope
of the applicable statutory provisions, you have the right to at any time
demand information about your archived personal data, their source and
recipients as well as the purpose of the processing of your data. You may also
have a right to have your data rectified or eradicated. If you have questions
about this subject matter or any other questions about personal data, please do
not hesitate to contact us at any time at the address provided in section
“Information Required by Law.”

Right to demand processing restrictions

You have the
right to demand the imposition of restrictions as far as the processing of your
personal data is concerned. To do so, you may contact us at any time at the
address provided in section “Information Required by Law.” The right to demand
restriction of processing applies in the following cases:

·
In the event
that you should dispute the correctness of your data archived by us, we will
usually need some time to verify this claim. During the time that this
investigation is ongoing, you have the right to demand that we restrict the
processing of your personal data.

·
If the
processing of your personal data was/is conducted in an unlawful manner, you
have the option to demand the restriction of the processing of your data in
lieu of demanding the eradication of this data.

·
If we do not
need your personal data any longer and you need it to exercise, defend or claim
legal entitlements, you have the right to demand the restriction of the
processing of your personal data instead of its eradication.

·
If you have
raised an objection pursuant to Art. 21 Sect. 1 GDPR, your rights and our
rights will have to be weighed against each other. As long as it has not been
determined whose interests prevail, you have the right to demand a restriction
of the processing of your personal data.

If you have
restricted the processing of your personal data, these data – with the
exception of their archiving – may be processed only subject to your consent or
to claim, exercise or defend legal entitlements or to protect the rights of
other natural persons or legal entities or for important public interest
reasons cited by the European Union or a member state of the EU.

Rejection of unsolicited e-mails

We herewith
object to the use of contact information published in conjunction with the
mandatory information to be provided in section “Information Required by Law”
to send us promotional and information material that we have not expressly
requested. The operators of this website and its pages reserve the express
right to take legal action in the event of the unsolicited sending of
promotional information, for instance via SPAM messages.

4. Recording of data on this website

Cookies

Our websites and
pages use what the industry refers to as “cookies.” Cookies are small text
files that do not cause any damage to your device. They are either stored
temporarily for the duration of a session (session cookies) or they are
permanently archived on your device (permanent cookies). Session cookies are
automatically deleted once you terminate your visit. Permanent cookies remain
archived on your device until you actively delete them or they are
automatically eradicated by your web browser.

In some cases it
is possible that third party cookies are stored on your device once you enter
our site (third party cookies). These cookies enable you or us to take
advantage of certain services offered by the third party (e.g. cookies for the
processing of payment services).

Cookies have a
variety of functions. Many cookies are technically essential since certain
website functions would not work in the absence of the cookies (e.g. the
shopping cart function or the display of videos). The purpose of other cookies
may be the analysis of user patterns or the display of promotional messages.

Cookies, which
are required for the performance of electronic communication transactions
(required cookies) or for the provision of certain functions you want to use
(functional cookies, e.g. for the shopping cart function) or those that are
necessary for the optimization of the website (e.g. cookies that provide
measurable insights into the web audience), shall be stored on the basis of
Art. 6 Sect. 1 lit. f GDPR, unless a different legal basis is cited. The
operator of the website has a legitimate interest in the storage of cookies to
ensure the technically error free and optimized provision of the operator’s
services. If your consent to the storage of the cookies has been requested, the
respective cookies are stored exclusively on the basis of the consent obtained
(Art. 6 Sect. 1 lit. a GDPR); this consent may be revoked at any time.

You have the
option to set up your browser in such a manner that you will be notified any
time cookies are placed and to permit the acceptance of cookies only in
specific cases. You may also exclude the acceptance of cookies in certain cases
or in general or activate the delete function for the automatic eradication of
cookies when the browser closes. If cookies are deactivated, the functions of
this website may be limited.

In the event
that third party cookies are used or if cookies are used for analytical
purposes, we will separately notify you in conjunction with this Data
Protection Policy and, if applicable, ask for your consent.

Cookie Consent with Borlabs Cookie

Our website uses
the Borlabs cookie consent technology to obtain your consent to the storage of
certain cookies in your browser and for their data privacy protection compliant
documentation. The provider of this technology is Borlabs – Benjamin A.
Bornschein, Georg-Wilhelm-Str. 17, 21107 Hamburg, Germany (hereinafter referred
to as Borlabs).

Whenever you
visit our website, a Borlabs cookie will be stored in your browser, which
archives any declarations or revocations of consent you have entered. These
data are not shared with the provider of the Borlabs technology.

The recorded data shall remain archived until you ask
us to eradicate them, delete the Borlabs cookie on your own or the purpose of
storing the data no longer exists. This shall be without prejudice to any
retention obligations mandated by law. To review the details of Borlabs’ data
processing policies, please visit 
https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/

We use the
Borlabs cookie consent technology to obtain the declarations of consent
mandated by law for the use of cookies. The legal basis for the use of such
cookies is Art. 6 Sect. 1 Sentence 1 lit. c GDPR.

Server log files

The provider of
this website and its pages automatically collects and stores information in
so-called server log files, which your browser communicates to us
automatically.
The information comprises:

·
The type and version
of browser used

·
The used operating system

·
Referrer URL

·
The hostname of
the accessing computer

·
The time of the
server inquiry

·
The IP address

This data is not
merged with other data sources.

This data is
recorded on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator of the
website has a legitimate interest in the technically error free depiction and
the optimization of the operator’s website. In order to achieve this, server
log files must be recorded.

Request by e-mail, telephone or fax

If you contact
us by e-mail, telephone 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 pass these data on without your consent.

These data are
processed on the basis of Art. 6 Sect. 1 lit. b GDPR if your inquiry is related
to the fulfillment of a contract or is required for the performance of
pre-contractual measures. In all other cases, the data are processed on the
basis of our legitimate interest in the effective handling of inquiries
submitted to us (Art. 6 Sect. 1 lit. f GDPR) or on the basis of your consent
(Art. 6 Sect. 1 lit. a GDPR) if it has been obtained.

The data sent by
you to us via contact requests remain with us until you request us to delete,
revoke your consent to the storage or the purpose for the data storage lapses
(e.g. after completion of your request). Mandatory statutory provisions – in
particular statutory retention periods – remain unaffected.

5. Analysis tools and advertising

Google Analytics

This website
uses functions of the web analysis service Google Analytics. The provider of
this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street,
Dublin 4, Ireland.

Google Analytics
enables the website operator to analyze the behavior patterns of website
visitors. To that end, the website operator receives a variety of user data,
such as pages accessed, time spent on the page, the utilized operating system
and the user’s origin. Google may consolidate these data in a profile that is
allocated to the respective user or the user’s device.

Google Analytics
uses technologies that make the recognition of the user for the purpose of
analyzing the user behavior patterns (e.g. cookies or device fingerprinting).
The website use information recorded by Google is, as a rule transferred to a
Google server in the United States, where it is stored.

This analysis
tool is used on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator of this
website has a legitimate interest in the analysis of user patterns to optimize
both, the services offered online and the operator’s advertising activities. If
a corresponding agreement has been requested (e.g. an agreement to the storage
of cookies), the processing takes place exclusively on the basis of Art. 6
para. 1 lit. a GDPR; the agreement can be revoked at any time.

IP anonymization

On this website,
we have activated the IP anonymization function. As a result, your IP address
will be abbreviated by Google within the member states of the European Union or
in other states that have ratified the Convention on the European Economic Area
prior to its transmission to the United States. The full IP address will be
transmitted to one of Google’s servers in the United States and abbreviated
there only in exceptional cases. On behalf of the operator of this website,
Google shall use this information to analyze your use of this website to
generate reports on website activities and to render other services to the
operator of this website that are related to the use of the website and the
Internet. The IP address transmitted in conjunction with Google Analytics from
your browser shall not be merged with other data in Google’s possession.

Browser plug-in

You can prevent the recording and processing of your
data by Google by downloading and installing the browser plugin available under
the following link: 
https://tools.google.com/dlpage/gaoptout?hl=en.

For more information about the handling of user data
by Google Analytics, please consult Google’s Data Privacy Declaration at: 
https://support.google.com/analytics/answer/6004245?hl=en.

Contract data processing

We have executed
a contract data processing agreement with Google and are implementing the
stringent provisions of the German data protection agencies to the fullest when
using Google Analytics.

Archiving period

Data on the user or incident level stored by Google
linked to cookies, user IDs or advertising IDs (e.g. DoubleClick cookies,
Android advertising ID) will be anonymized or deleted after 14 month. For
details please click the following link: 
https://support.google.com/analytics/answer/7667196?hl=en

Facebook Pixel

To measure
conversion rates, this website uses the visitor activity pixel of Facebook. The
provider of this service is Facebook Ireland Limited, 4 Grand Canal Square,
Dublin 2, Ireland. According to Facebook’s statement the collected data will be
transferred to the USA and other third-party countries too.