This data protection declaration informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within our online offer and the websites, functions and content associated with it, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as “online service”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Aloma Online Marketing
Prop. Tobias Sasse
22926 Ahrensburg (Germany)
Types of data processed:
– Inventory data (e.g., names, addresses)
– Contact details (e.g., email, phone numbers)
– Content data (e.g., text input, photographs, videos)
– Usage data (e.g., web pages visited, interest in content, access times).
– Meta/communication data (e.g., device information, IP addresses)
Categories of persons impacted
Visitors and users of the online offer (hereinafter we also refer to the data subjects collectively as “users” or “visitors”).
– Provision of the online offer, its functions and contents
– Responding to contact requests and communicating with users
– Establishing the contact of the users with our clients
– Security measures
– Reach measurement/marketing
“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “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 (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and encompasses virtually any handling of data.
“Pseudonymization” means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures which ensure that the personal data are not attributed to an identified or identifiable natural person;
“Profiling” means any automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or change of location;
The term “controller” refers to 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.
“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller;
Relevant legal bases
We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk in accordance with Article 32 of the GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons.
The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, entry into, disclosure of, assurance of availability of and separation of the data. Furthermore, we have established procedures to ensure the exercise of data subject rights, deletion of data, and response to data compromise. Furthermore, we already take the protection of personal data into account during the development or selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings ( Art. 25 GDPR).
Cooperation with processors and third parties
If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is required for the performance of the contract pursuant to Art. 6 (1) lit. b GDPR), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
If we commission third parties with the processing of data on the basis of a so-called “order processing agreement”, this is done on the basis of Art. 28 GDPR.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using third-party services or disclosing or transferring data to third parties, this will only be done if it is done to fulfill our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or allow the processing of data in a third country only if the special requirements of Art. 44 et seq. GDPR are met. This means, for example, that processing takes place on the basis of special guarantees, such as the officially recognized determination of a level of data protection that corresponds to that of the EU (e.g., for the USA through the “Privacy Shield”) or compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).
Rights of the data subjects
You have the right to request confirmation as to whether data in question is being processed and to information about this data, as well as further information and a copy of the data in accordance with Art. 15 GDPR.
In accordance with Art. 16 GDPR, you have the right to request the completion of data impacting you or the correction of incorrect data impacting you.
In accordance with Article 17 of the GDPR, you have the right to demand that the data in question be deleted without delay, or alternatively, in accordance with Article 18 of the GDPR, to demand restriction of the processing of the data.
You have the right to request to receive the data impacting you that you have provided to us in accordance with Article 20 of the GDPR and to request its transfer to other data controllers.
You also have the right to lodge a complaint with the competent supervisory authority pursuant to Art. 77 GDPR.
Right of withdrawal
You have the right to revoke given consents according to Art. 7 para. 3 GDPR with effect for the future
Right of objection
You may object to the future processing of data relating to you in accordance with Art. 21 GDPR at any time. The objection can be made in particular against the processing for purposes of direct advertising.
Deletion of data
According to legal requirements in Germany, the storage takes place in particular for 10 years in accordance with §§ 147 Abs. 1 AO, 257 Abs. 1 No. 1 and 4, Abs. 4 HGB (books, records, management reports, accounting vouchers, commercial books, for taxation relevant documents, etc.) and 6 years in accordance with § 257 Abs. 1 No. 2 and 3, Abs. 4 HGB (commercial letters).
According to legal requirements in Austria, storage is carried out in particular for 7 years in accordance with Section 132 (1) BAO (accounting records, vouchers/invoices, accounts, receipts, business papers, statement of income and expenses, etc.), for 22 years in connection with real property and for 10 years for records in connection with electronically provided services, telecommunications, radio and television services provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.
The hosting services used by us serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, security services and technical maintenance services, which we use for the purpose of operating this online service.
In doing so, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer pursuant to Art. 6 para. 1 lit. f GDPR in conjunction with. Art. 28 GDPR (conclusion of order processing contract).
Collection of access data and log files
We and our hosting provider collect data on the basis of our legitimate interests within the meaning of Art. 6 (1) lit. f. GDPR, we collect data about every access to the server on which this service is located (so-called server log files). This data is used for technical monitoring of the server and defense against harmful actions (e.g. DDOS, hacking, spamming). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address and the requesting provider.
Anonymized log file information is stored for a maximum of 30 days and then automatically deleted. They are used for manual investigation of harmful actions and technical malfunctions.
Detailed log data, the storage of which is required for direct danger prevention, is stored for a period of 7 days and then automatically deleted. They are used for the automatic detection and defense against harmful actions to ensure the smooth and failure-free operation of the website.
Administration, financial accounting, office organization, contact management
We process data within the framework of administrative tasks as well as organization of our operations, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are impacted by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The cancellation of the data with regard to contractual services and contractual communication corresponds to the data mentioned in these processing activities.
We disclose or transfer data to the tax authorities, consultants, such as tax advisors or auditors, as well as other fee offices and payment service providers.
Furthermore, we store information on suppliers, event organizers and other business partners on the basis of our business interests, e.g. for the purpose of contacting them at a later date. We store this data, which is mostly company-related, permanently.
Users can create a user account. As part of the registration process, the required mandatory information is provided to users and processed on the basis of Art. 6 (1) lit. b GDPR for the purpose of providing the user account. The processed data includes in particular the login information (name, password as well as an e-mail address). The data entered during registration will be used for the purposes of using the user account and its purpose.
Users may be notified of information relevant to their user account, such as technical changes, by email. If users have terminated their user account, their data relating to the user account will be deleted, except in the case of a legal obligation to retain data. It is the responsibility of the users to back up their data before the end of the contract if the contract has been terminated. We are entitled to irretrievably delete all of the user’s data stored during the term of the contract.
In the course of using our registration and login functions as well as the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as those of users in protection against misuse and other unauthorized use. In principle, this data will not be passed on to third parties, unless it is necessary for the pursuit of our claims or there is a legal obligation to do so pursuant to Art. 6 para. 1 lit. c. GDPR. The IP addresses are anonymized or deleted after 7 days at the latest.
We offer the possibility to process financial contributions via the payment service provider PayPal (PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg). This is in line with our legitimate interest in offering an efficient and secure payment method (Art. 6 para. 1 lit. f GDPR). In this context, a pixel is set by PayPal after the user’s consent, insofar as it is necessary for the fulfillment of the contract (Art. 6 para. 1 lit b. GDPR). The entry of payment data – including personal data – is carried out by PayPal. We do not participate in this.
The processing of the data provided under this section is not required by law or contract. Without the transmission of your personal data, we cannot carry out a payment via PayPal. It is possible for you to choose another payment method and not give consent to PayPal cookies.
PayPal performs a credit check for various services such as payment by direct debit to ensure your willingness and ability to pay. This corresponds to PayPal’s legitimate interest (pursuant to Art. 6 para. 1 lit. f GDPR) and serves the execution of the contract (pursuant to Art. 6 para. 1 lit. b GDPR). For this purpose, your data (name, address and date of birth, bank account details) will be passed on to credit agencies. We have no influence on this process and only receive the result of whether the payment has been made, rejected or is pending verification.
You can find more information on objection and removal options vis-à-vis PayPal at: https://www.paypal.com/de/webapps/mpp/ua/privacy-full
Your data will be stored until the completion of payment processing. This includes the time required to process refunds, receivables management, and fraud prevention.
We use “Matomo” on this website for statistical analysis. That’s an open source tool for web analytics. Matomo does not transmit data to servers that are outside of our control. Matomo is disabled when you visit our website. Only if you actively consent, your usage behavior will be recorded anonymously.
Matomo uses so-called cookies. These are text files that are stored on your computer and make it possible by means of Matomo to analyze the use of its website.uses so-called cookies. For this purpose, the information about usage obtained by the cookie is transmitted to Matomo and stored so that usage behavior can be evaluated. Your IP address is anonymized immediately; thus you remain anonymous as a user. The information generated by the cookie about your use of this website will not be disclosed to third parties.