PRIVACY POLICY

Introduction

We at CBDLifeUK. (“we”, “us” or “our”) are committed to protecting your personal privacy. This Privacy Policy (“policy”) applies to our website, including our associated mobile applications (“apps”), owned and controlled by us.

This policy describes how we collect, guard and use the personally identifiable information (“personal information”) you (“user”, “you”, “your” or “data subject”) may provide on our website and through any of its products or services (collectively, “websites” or “services”). It also outlines the choices accessible to you regarding our use of your personal information and how you can access and renew this information.

This policy does not apply to the practices of companies that we do not own or manage, or to individuals that we do not employ or manage. We understand that you are conscious of and care about your own personal privacy interests, and we take this seriously. This policy also describes our policies and practices regarding its collection and use of your personal data and sets forth your privacy rights. We acknowledge that information privacy is an ongoing responsibility, and so we will from time to time update this policy as we undertake new personal data practices or adopt new privacy policies.

General Data Protection Regulation is of a particularly high priority for the management of this website. The use of the internet pages of our website is possible without any indication of personal data; however, if a data subject wants to use special enterprise services via our website, processing of personal data could become essential. If the processing of personal data is required and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, country, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation, and in accordance with the country-specific data protection regulations applicable to our website. By means of this data protection declaration, we would like to acquaint the general public of the nature, scope, and purpose of the personal data we collect, manage and process. Moreover, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

As the controller, we have implemented numerous technical and organisational measures to ensure a complete protection of personal data processed through this website. Nonetheless, Internet-based data transmissions may in principle have security clefts, so faultless protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.

Please note that, by utilising our website, you consent to the data practices described in this policy. If you do not agree with the data practices described in this policy, you should not use our website.

Owner and Data Controller

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

CBDLife UK, 20-22 Wenlock Road, London, N1 7GU

Office e-mail: info@cbdlifeuk.com

1. Definitions

Our data protection declaration is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation. Our data protection declaration should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used. In this data protection declaration, we use, inter alia, the following terms:

1.1. Collection of general data and information

Our website collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files.

Collected may be:

  • the browser types and versions used,
  • the operating system used by the accessing system,
  • the website from which an accessing system reaches our website (so-called referrers),
  • the sub-websites,
  • the date and time of access to the Internet site,
  • an Internet protocol address (IP address),
  • the Internet service provider of the accessing system, and
  • any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, we do not draw any conclusions about the data subject. Rather, this information is needed to:

  • deliver the content of our website correctly,
  • optimise the content of our website as well as its advertisement,
  • ensure the long-term viability of our information technology systems and website technology, and
  • provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack.

Accordingly, we analyse anonymously collected data and information statistically, with the purpose of increasing the data protection and data security of our enterprise and to ensure an optimal 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 a data subject.

2. Key terms and principles

Before we get into the detail, here is a quick overview of some of the core elements of data protection and General Data Protection Regulation.

2.1. Data subject

A data subject is an individual whose personal data is stored by an organisation. A data subject is someone who can be identified by the data stored — i.e. the data includes their name, date of birth or address, email address. A user ID number can also be classified as personal data as the number can be linked to a specific person. Under the General Data Protection Regulation, there are several additions including IP addresses and location data.

Someone who cannot be identified by the data stored, or someone who has died, is not a data subject.

2.2. Personal data (or 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.

Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.

2.3. Controller or controller responsible for the processing (or owner)

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or another 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.

The natural person, legal person, public administration or any another body, association or organisation with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of our website.

2.4. Data processor (or data supervisor)

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.

A data processor is a legal individual, public authority, agency, or body which processes personal data on behalf of the controller.

The natural person, legal person, public administration or any other body, association or organisation authorised by the Data Controller to process the Personal Data in compliance with this policy.

2.5. Data controller

A data controller is the legal individual, public authority, agency or other body which, alone or jointly with others, determines the purposes of processing personal data.

Under the Data Protection Act (1998), only the data controller is liable for data protection. However, under General Data Protection Regulation, both processors and controllers will be held responsible. Processors will face more legal obligations, and therefore be at risk of fines for non-compliance.

2.6. Usage data

Information collected automatically from our website (or third-party services employed in our digital network), which can include:

  • the IP addresses or domain names of the computers utilised by the Users who use this website,
  • the URI addresses (Uniform Resource Identifier),
  • the time of the request,
  • the method utilised to submit the request to the server,
  • the size of the file received in response,
  • the numerical code indicating the status of the server’s answer (successful outcome, error, etc.),
  • the country of origin,
  • the features of the browser and the operating system utilised by the user,
  • the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited,
  • and other parameters about the device operating system and/or the user’s IT environment.

2.7. User

The individual using this website, which must coincide with or be authorised by the Data Subject, to whom the Personal Data refers.

2.8. 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.

2.9. 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.1.11. Recipient

The 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.

2.10. 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.

2.11. 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.

2.12. Website

The hardware or software means by which the Personal Data of the User is collected.

2.13. Restriction of processing

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

2.14. Cookies

The pages of our website use cookies. Cookies are text files that are stored in a computer system via an Internet browser.

Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which pages and servers can be assigned to the specific browser in which the cookie was stored. This allows visited websites and servers to differentiate the individual browser of the data subject from other browsers that contain other cookies. A specific browser can be recognised and identified using the unique cookie ID.

Through the use of cookies, we can provide the users of this website with more user-friendly services that would not be possible without the cookie setting.

By means of a cookie, the information and offers on our website can be optimised for the user in mind. Cookies allow us, as previously mentioned, to recognise our website users. The purpose of this recognition is to make it easier for users to utilise our website. The website user that uses cookies e.g. does not have to enter access data each time the website is accessed, because this is taken over by the website, and the cookie is thus stored on the user’s computer system.

Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.

The data subject may, at any time, prevent the setting of cookies through our website by means of corresponding settings of the browser used, and may thus permanently deny the setting of cookies. Moreover, already set cookies may be deleted at any time via browser or other software programs. This is possible in all popular browsers.

If the data subject deactivates the setting of cookies in the browser used, not all functions of our website may be entirely usable.

3. The Data Protection Act

The Data Protection Act was implemented by the United Kingdom government in 1998 to control how personal information is used by organisations and give legal rights to individuals.

The Data Protection Act includes strict ‘data protection principles’, stating that data must be:

  • used fairly and lawfully
  • used for limited, specifically stated, purposes
  • used in a way that is adequate, relevant and not excessive
  • accurate
  • kept for no longer than is absolutely necessary
  • handled according to people’s data protection rights
  • kept safe and secure
  • not transferred outside the European Economic Area without adequate protection

4. Our principles

We do our very best to protect your privacy by using security technology appropriately. This means:

  • we make sure that we have appropriate security measures to protect your information; and
  • we make sure that when we ask another organisation to provide a service for us, they have appropriate security measures.

We will respect your privacy. You should receive marketing (whether by e-mail, post, SMS or telephone) only from us and, if you agree, from other organisations we have carefully chosen. We will make sure it is clear when you can make these choices, for example, we have boxes you need to tick if you want to receive marketing and you can change your preferences if you no longer want to receive it. Notwithstanding, we may e-mail you occasionally with information or inquiries about your registration, your subscription account or postings, for example, with reminders, warnings or copyright requests.

We will collect and use individual user details only if we have your permission or we have sensible business reasons for doing so, such as collecting enough information to manage subscriptions.

  • We will be clear in our dealings with you as to what information about you we will collect and how we will use it.
  • We will use personal data information only for the purposes for which it was originally collected and we will make sure we delete it securely.

Our website is accessible via the internet, meaning that people around the world who access our website can see anything you publish on the website, for example, comments about an article.

If we or our service providers transfer any information out of the European Economic Area, it will only be done with the relevant protection being in place.

5. Types of Data collected

Among the types of Personal Data that we collect, by itself or through third parties, there are: Cookies, Usage Data, company name, address, country, city, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), first name, last name, e-mail address, password, username and website.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this policy or by specific explanation texts displayed prior to the Data collection.

The Personal Data may be freely provided by the user, or, in case of Usage Data, collected automatically when using our website.

All Data requested by our website is mandatory and failure to provide this Data may make it impossible for us to provide our services. In cases where our website specifically states that some Data is not mandatory, users are free not to communicate this Data without any consequences on the availability or the functioning of the service.

Any use of Cookies — or of other tracking tools — by our website or by the owners of third-party services used by our website serves the purpose of providing the service required by the user, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through our website and confirm that they have the third-party’s consent to provide the Data to the Owner.

We collect information on you:

  • when you register or become a member of our website, and when you browse the website, or
  • through cookies,
  • if you choose to reveal information in postings, and
  • when you enter sales promotions and competitions.

Certain services that we provide may involve us collecting additional information (membership, for example), such as where you are, so the service can be provided as designed. This may also apply to certain mobile applications that you download, or which we provide.

6. Mode and place of processing the Data

We process the Data of users in a proper manner and shall take appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.

The Data processing is carried out using computers and/or IT-enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, e-mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by us. The updated list of these parties may be requested from the Data Controller at any given time.

6.1. Place

The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved in the processing are located.

6.2. Retention time

The Data is kept for the time necessary to provide the service requested by the user, or stated by the purposes outlined in this document, and the user can always request that the Data Controller suspend or remove the data.

6.3. Routine erasure and blocking of personal data

The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.

If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.

7. The use of the collected Data

The Data concerning the user is collected to allow us to provide our services, as well as for the following purposes:

  • Advertising,
  • Contacting the user,
  • SPAM protection,
  • Analytics,
  • Remarketing and behavioural targeting,
  • Commercial affiliation,
  • Interaction with external social networks and platforms,
  • Registration and authentication,
  • Content commenting,
  • Content performance and features testing (A/B testing),
  • Displaying content from external platforms,
  • Handling payments gateways,
  • Hosting and backend infrastructure,
  • Infrastructure monitoring,
  • Interaction with data collection platforms and other third-parties,
  • Managing contacts and sending messages, and
  • Tag Management.

We will not share your personal information with others for marketing purposes unless you have given us your permission. If we have your permission, we will share your information only with other organisations we have chosen carefully.

If you are a registered user and attend an event organised by an event partner, data may be shared for event administration purposes.

We may make other organisations’ services available, through our website, although we are not necessarily operating these websites. We process any information which we collect when you access a service provided by another organisation under this policy. The information these other organisations collect is governed by their own privacy policies.

We can access and release personal information to keep relevant laws and government requests, to operate our systems properly and to protect both us and our users.

Any other organisations who access your information in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your information and keep to general data protection regulation and privacy laws which apply. We may also independently audit these service providers to make sure that they meet our standards. We may use service providers to help us run these websites (or services available on the websites), some of whom may be based outside the European Economic Area.

Some of our website pages use plugins from other organisations (such as the ‘Facebook Recommend’ function). These other organisations may use information about your visit to our websites on their pages. If you browse these pages while still also logged in to your account with us, the information they collect may be connected to your account on their website.

For more information on how these organisations use information, please read their privacy policies.

The Personal Data used for each purpose is outlined in the specific sections of this document.

8. Analytics

The services contained in this section enable us to monitor and analyse web traffic and can be used to keep track of user behaviour.

8.1. Google Analytics (Google Inc.)

Google Analytics is an analysis service provided by Google Inc. (“Google”). Google utilises the Data collected to track and examine the use of our website, to prepare reports on its activities and share them with other Google services.

We use Google Analytics on our website for anonymous reporting of website usage and for advertising on the website. Furthermore, Google may use the Data collected to contextualise and personalise the advertisements of its own advertising network.

8.2. Facebook Ads conversion tracking (Facebook, Inc.)

Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on our website.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America

8.3. Facebook Analytics for Apps (Facebook, Inc.)

Facebook Analytics for Apps is an analytics service provided by Facebook, Inc.

Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.

Place of processing: United States of America

8.4. Google AdWords conversion tracking (Google Inc.)

Google AdWords conversion tracking is an analytics service provided by Google Inc. that connects data from the Google AdWords advertising network with actions performed on our website.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America

8.5. Twitter Ads conversion tracking (Twitter, Inc.)

Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on our website.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America

8.6. Google Analytics with anonymised IP (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilises the Data collected to track and examine the use of and performance of our website, also to prepare reports on its activities and share them with other Google services.

Google may use the Data collected to contextualise and personalise the advertisements of its own advertising network.

This integration of Google Analytics anonymises your IP address. It works by shortening users’ IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the United States of America.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America

9. Data protection provisions about the application and use of Google Analytics (with anonymization function)

On this website, we have integrated the component of Google Analytics (with the anonymiser function). Google Analytics is an analytics service. Analytics is the collection, gathering, and analysis of data about the behaviour of visitors to websites. An analysis service collects, inter alia, data about the website from which a person has come (the so-called referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Analytics are mainly used for the optimisation of a website and in order to carry out a cost-benefit analysis of digital advertising.

The operator of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States of America.

For the analytics, through Google Analytics the controller uses the application “_gat. _anonymizeIp”. By means of this application, the IP address of the connection of the data subject is abridged by Google and anonymised when accessing our websites from a Member State of the European Union or another Contracting State to the Agreement on the European Economic Area.

The purpose of the Google Analytics component is to analyse the traffic on our website. Google uses the collected data and information, inter alia, to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our website for us.

Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyse the use of our website. With each call-up to one of the individual pages of this website, which is operated by the controller and into which a Google Analytics component was integrated, the browser on the information technology system of the data subject will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google, inter alia, to understand the origin of visitors and clicks, and subsequently create commission settlements.

The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits to our website by the data subject. With each visit to our website, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third-parties.

The data subject may, as stated above, prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the browser used and thus permanently deny the setting of cookies. Such an adjustment to the browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a browser or other software programs.

10. Content commenting

Our website offers users the possibility to leave individual comments on individual article contributions, which is on the website of the controller. A blog is a web-based, publicly-accessible portal, through which one or more people called bloggers or web-bloggers may post articles or write down thoughts in so-called blogposts. Blogposts may usually be commented by third-parties.

Content commenting services allow Users to make and publish their comments on the contents of our website.

Depending on the settings chosen by us, Users may also leave anonymous comments. If there is an e-mail address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.

If a data subject leaves a comment on an article published on this website, the comments made by the data subject are also stored and published, as well as information on the date of the commentary and on the user’s (pseudonym) chosen by the data subject. In addition, the IP address assigned by the Internet service provider (ISP) to the data subject is also logged. This storage of the IP address takes place for security reasons, and in case the data subject violates the rights of third-parties or posts illegal content through a given comment. The storage of these personal data is, therefore, in the own interest of the data controller, so that he can exculpate in the event of an infringement.

This collected personal data will not be passed to third-parties unless such a transfer is required by law or serves the aim of the defence of the data controller.

10.1. Comment system managed directly

Our website has its own internal content comment system.

Personal Data collected: Cookies, email address, first name, last name, username and website.

10.2. Comment Subscriptions

The comments made on our website may be subscribed to by third-parties. In particular, there is the possibility that a commenter subscribes to the comments following his comments on a particular article published.

If a data subject decides to subscribe to the option, the controller will send an automatic confirmation e-mail to check the double opt-in procedure as to whether the owner of the specified e-mail address decided in favour of this option. The option to subscribe to comments may be terminated at any time.

11. Contact forms

Our website contains information that enables a quick electronic contact, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a 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. There is no transfer of this personal data to third-parties.

By filling in the contact form with their Data, the User authorises us to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data collected: address, city, company name and country.

12. Newsletter Subscriptions

On our website, users are given the opportunity to subscribe to our enterprise’s newsletter. The input mask used for this purpose determines what personal data are transmitted, as well as when the newsletter is ordered from the controller.

CBDLife UK informs its subscribers, customers and business partners regularly by means of a newsletter about enterprise offers, highlighted content and exclusive features. The enterprise’s newsletter may only be received by the data subject if:

  • the data subject has a valid e-mail address and
  • the data subject registers for the newsletter shipping.

A confirmation e-mail will be sent to the e-mail address registered by a data subject for the first time for newsletter shipping, for legal reasons, in the double opt-in procedure. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorised to receive the newsletter.

During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of the registration, as well as the date and time of the registration. The collection of this data is necessary in order to understand the (possible) misuse of the e-mail address of a data subject at a later date, and it, therefore, serves the aim of the legal protection of the controller.

The personal data collected as part of a registration for the newsletter will only be used to send our newsletter. In addition, subscribers to the newsletter may be informed by e-mail, as long as this is necessary for the operation of the newsletter service or a registration in question, as this could be the case in the event of modifications to the newsletter offer, or in the event of a change in technical circumstances. There will be no transfer of personal data collected by the newsletter service to third-parties.

The subscription to our newsletter may be terminated by the data subject at any time. The consent to the storage of personal data, which the data subject has given for shipping the newsletter, may be revoked at any time. For the purpose of revocation of consent, a corresponding hyperlink is found in each newsletter. It is also possible to unsubscribe from the newsletter at any time directly on the website of the controller or to communicate this to the controller in a different way.

12.1. Newsletter Tracking

Our newsletter contains so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such e-mails, which are sent in HTML format to enable log file recording and analysis. This allows a statistical analysis of the success or failure of online marketing campaigns.

Based on the embedded tracking pixel, we may see if and when an e-mail was opened by a data subject, and which hyperlinks in the e-mail were called up by data subjects.

Such personal data collected in the tracking pixels contained in the newsletters are stored and analysed by the controller in order to optimize the shipping of the newsletter, as well as to adapt the content of future newsletters even better to the interests of the data subject. These personal data will not be passed on to third-parties. Data subjects are at any time entitled to revoke the respective separate declaration of consent issued by means of the double-opt-in procedure. After a revocation, these personal data will be deleted by the controller.

We will honour and automatically regards a withdrawal from the receipt of the newsletter as a revocation.

13. Content performance and features testing (A/B testing)

The services contained in this section allow us to track and analyse the User response concerning web traffic or behaviour regarding changes to the structure, text or any other component of our website.

13.1. Google Website Optimiser (Google Inc.)

Google Website Optimiser is an A/B testing service provided by Google Inc.

Google may use Personal Data to contextualise and personalise the advertisements of its own advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America

14. Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of our website and interact with them.

This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

14.1. Google Fonts (Google Inc.)

Google Fonts is a typeface visualisation service provided by Google Inc. that allows our website to incorporate resources of this kind on its pages.

Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.

Place of processing: United States of America

14.2. Google Maps widget (Google Inc.)

Google Maps is a maps visualisation service provided by Google Inc. that allows our website to incorporate resources of this kind on its pages.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America

14.3. Gravatar (Automattic Inc.)

Gravatar is an image visualisation service provided by Automattic Inc. that allows our website to incorporate the resources of this kind on its pages.

Please note that if Gravatar images are used for comment forms, the commenter’s email address or parts of it may be sent to Gravatar – even if the commenter has not signed up for that service.

Personal Data collected: email address and Usage Data.

Place of processing: United States of America

15. Handling payments

Payment processing services enable us to process payments by credit card, bank transfer or other means. To ensure greater security, we share only the information necessary to execute the transaction with the financial intermediaries handling the transaction.

Some of these services may also enable the sending of timed messages to the User, such as e-mails containing invoices or notifications concerning the payment.

15.1. PayPal (PayPal Inc.)

PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States of America

16. Payment Method: Data protection provisions about the use of Paylike as a payment processor

On this website, we have integrated components of Paylike. Paylike is an online payment service provider. Payments are processed via payments using any Card accepted by the Card Network within the rules established by the Card Network. Included in our service is the establishment of a Merchant Agreement with the Card Network through the acquiring bank Clearhaus A/S. You accept that Paylike may sign such an Merchant Agreement on your behalf which includes Clearhaus A/s’ General terms for Merchant Agreements(https://www.clearhaus.com/others/assets/General_Terms_en.pdf) which is incorporated in this agreement by reference. Paylike do not assume any liability for products or services charged using our service. It is the Merchant’s responsibility to make sure that any use of our services happens in accordance with the terms of service and the rules set forth by the Card Network (see “Card Network rules”).

17. Hosting and backend infrastructure

This type of service has the purpose of hosting Data and files that enables our website to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of our website. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

18. Infrastructure monitoring

This type of service allows our website to monitor the use and behaviour of its components so its performance, operation, maintenance and troubleshooting can be improved.

Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of our website.

19. Interaction with data collection platforms and other third-parties

This type of service allows Users to interact with data collection platforms or other services directly from the pages of our website for the purpose of saving and reusing data.

If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

19.1. MailChimp widget (The Rocket Science Group, LLC.)

The MailChimp widget is a service for interacting with the MailChimp e-mail address management and message sending service provided by The Rocket Science Group LLC.

Personal Data collected: Cookies, email address, first name, last name and Usage Data.

Place of processing: United States of America

20. Interaction with external social networks and platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of our website.

The interaction and information obtained through our website are always subject to the User’s privacy settings for each social network.

This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

20.1. Buffer button and social widgets (Buffer)

The Buffer button and social widgets are services allowing interaction with the Buffer service provided by Buffer, Inc.

Personal Data collected: Usage Data.

Place of processing: United States of America

20.2. Facebook Like button and social widgets (Facebook, Inc.)

The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America

20.3. Google+ +1 button and social widgets (Google Inc.)

The Google+ +1 button and social widgets are services allowing interaction with the Google+ social network provided by Google Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America

20.4. LinkedIn button and social widgets (LinkedIn Corporation)

The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America

20.5. Paylike button and widgets (Paylike Inc.)

The Paylike button and widgets are services allowing interaction with the Paylike platform provided by Paylike Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: See the Paylike privacy policy

20.6. Pinterest “Pin it” button and social widgets (Pinterest)

The Pinterest “Pin it” button and social widgets are services allowing interaction with the Pinterest platform provided by Pinterest Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America

27.7. Twitter Tweet button and social widgets (Twitter, Inc.)

The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America

28. Data protection provisions about the application and use of Facebook (Facebook, Inc.)

On this website, we have integrated components of the enterprise Facebook. Facebook is a social network.

A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.

The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

With each call-up to one of the individual pages of this Internet website, which is operated by the controller and into which a Facebook component (Facebook plugins) was integrated, the web browser on the information technology system of the data subject is automatically prompted to download display of the corresponding Facebook component from Facebook through the Facebook component.

During the course of this technical procedure, Facebook is made aware of what specific sub-site of our website was visited by the data subject.

If the data subject is logged in at the same time on Facebook, Facebook detects with every call-up to our website by the data subject — and for the entire duration of their stay on our Internet site — which specific sub-website of our Internet page was visited by the data subject. This information is collected through the Facebook component and associated with the respective Facebook account of the data subject. If the data subject clicks on one of the Facebook buttons integrated into our website, e.g. the “Like” button, or if the data subject submits a comment, then Facebook matches this information with the personal Facebook user account of the data subject and stores the personal data.

Facebook always receives, through the Facebook component, information about a visit to our website by the data subject, whenever the data subject is logged in at the same time on Facebook during the time of the call-up to our website. This occurs regardless of whether the data subject clicks on the Facebook component or not. If such a transmission of information to Facebook is not desirable for the data subject, then he or she may prevent this by logging off from their Facebook account before a call-up to our website is made.

In addition, it is explained there what setting options Facebook offers to protect the privacy of the data subject. Also, different configuration options are made available to allow the elimination of data transmission to Facebook. These applications may be used by the data subject to eliminate a data transmission to Facebook.

29. Data protection provisions about the application and use of Google+

On this website, we have integrated the Google+ button as a component. Google+ is a so-called social network. A social network is a social meeting place on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or enable the Internet community to provide personal or business-related information. Google+ allows users of the social network to include the creation of private profiles, upload photos and network through friend requests.

The operating company of Google+ is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, United States of America.

With each call-up to one of the individual pages of this website, which is operated by the controller and on which a Google+ button has been integrated, the Internet browser on the information technology system of the data subject automatically downloads a display of the corresponding Google+ button of Google through the respective Google+ button component. During the course of this technical procedure, Google is made aware of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in at the same time to Google+, Google recognises with each call-up to our website by the data subject and for the entire duration of his or her stay on our Internet website, which specific sub-pages of our Internet page were visited by the data subject. This information is collected through the Google+ button and Google matches this with the respective Google+ account associated with the data subject.

If the data subject clicks on the Google+ button integrated on our website and thus gives a Google+ 1 recommendation, then Google assigns this information to the personal Google+ user account of the data subject and stores the personal data. Google stores the Google+ 1 recommendation of the data subject, making it publicly available in accordance with the terms and conditions accepted by the data subject in this regard. Subsequently, a Google+ 1 recommendation given by the data subject on this website together with other personal data, such as the Google+ account name used by the data subject and the stored photo, is stored and processed on other Google services, such as search-engine results of the Google search engine, the Google account of the data subject or in other places, e.g. on Internet pages, or in relation to advertisements. Google is also able to link the visit to this website with other personal data stored on Google. Google further records this personal information with the purpose of improving or optimising the various Google services.

Through the Google+ button, Google receives information that the data subject visited our website, if the data subject at the time of the call-up to our website is logged in to Google+. This occurs regardless of whether the data subject clicks or doesn’t click on the Google+ button.

If the data subject does not wish to transmit personal data to Google, he or she may prevent such transmission by logging out of his Google+ account before calling up our website.

30. Data protection provisions about the application and use of Instagram

On this website, we have integrated components of the service Instagram. Instagram is a service that may be qualified as an audio-visual platform, which allows users to share photos and videos, as well as disseminate such data in other social networks.

The operating company of the services offered by Instagram is Instagram LLC, 1 Hacker Way, Building 14 First Floor, Menlo Park, CA, United States of America.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which an Instagram component (Insta button) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to the download of a display of the corresponding Instagram component of Instagram. During the course of this technical procedure, Instagram becomes aware of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in at the same time on Instagram, Instagram detects with every call-up to our website by the data subject — and for the entire duration of their stay on our Internet site — which specific sub-page of our Internet page was visited by the data subject. This information is collected through the Instagram component and is associated with the respective Instagram account of the data subject. If the data subject clicks on one of the Instagram buttons integrated on our website, then Instagram matches this information with the personal Instagram user account of the data subject and stores the personal data.

Instagram receives information via the Instagram component that the data subject has visited our website provided that the data subject is logged in at Instagram at the time of the call to our website. This occurs regardless of whether the person clicks on the Instagram button or not. If such a transmission of information to Instagram is not desirable for the data subject, then he or she can prevent this by logging off from their Instagram account before a call-up to our website is made.

31. Data protection provisions about the application and use of LinkedIn

We have integrated components of the LinkedIn Corporation on this website. LinkedIn is a web-based social network that enables users with existing business contacts to connect and to make new business contacts. Over 400 million registered people in more than 200 countries use LinkedIn. Thus, LinkedIn is currently the largest platform for business contacts and one of the most visited websites in the world.

The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court Mountain View, CA 94043, United States of America. For privacy matters outside of the United States of America: LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible.

With each call-up to one of the individual pages of this Internet website, which is operated by the controller and on which a LinkedIn component (LinkedIn plugin) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to the download of a display of the corresponding LinkedIn component of LinkedIn.

During the course of this technical procedure, LinkedIn gains knowledge of what specific sub-page of our website was visited by the data subject.

If the data subject is logged in at the same time on LinkedIn, LinkedIn detects with every call-up to our website by the data subject — and for the entire duration of their stay on our Internet website — which specific sub-page of our Internet page was visited by the data subject. This information is collected through the LinkedIn component and associated with the respective LinkedIn account of the data subject. If the data subject clicks on one of the LinkedIn buttons integrated on our website, then LinkedIn assigns this information to the personal LinkedIn user account of the data subject and stores the personal data.

LinkedIn receives information via the LinkedIn component that the data subject has visited our website, provided that the data subject is logged in on LinkedIn at the time of the call-up to our website. This occurs regardless of whether the person clicks on the LinkedIn button or not. If such a transmission of information to LinkedIn is not desirable for the data subject, then he or she may prevent this by logging off from their LinkedIn account before a call-up to our website is made.

LinkedIn provides under https://www.linkedin.com/psettings/guest-controls the possibility to unsubscribe from e-mail messages, SMS messages and targeted advertising, as well as the ability to manage advertising settings. LinkedIn also uses affiliates such as Eire, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua, and Lotame.

32. Data protection provisions about the application and use of Pinterest

On this website, we have integrated components of Pinterest Inc. Pinterest is a so-called social network. A social network is an Internet social meeting place, an online community that allows users to communicate and interact with each other in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences, or allow the Internet community to provide personal or company-related information. Pinterest enables the users of the social network to publish, inter alia, picture collections and individual pictures as well as descriptions on virtual pinboards (so-called pins), which can then be shared by other user’s (so-called re-pins) or commented on.

The operating company of Pinterest is Pinterest Inc., 808 Brannan Street, San Francisco, CA 94103, United States of America.

With each call-up to one of the individual pages of this Internet website, which is operated by the controller and on which a Pinterest component (Pinterest plug-in) was integrated, the Internet browser on the information technology system of the data subject automatically prompted to download through the respective Pinterest component a display of the corresponding Pinterest component.

During the course of this technical procedure, Pinterest gains knowledge of what specific sub-page of our website is visited by the data subject.

If the data subject is logged in at the same time on Pinterest, Pinterest detects with every call-up to our website by the data subject — and for the entire duration of their stay on our Internet website — which specific sub-page of our Internet page was visited by the data subject. This information is collected through the Pinterest component and associated with the respective Pinterest account of the data subject. If the data subject clicks on one of the Pinterest buttons, integrated on our website, then Pinterest assigns this information to the personal Pinterest user account of the data subject and stores the personal data.

Pinterest receives information via the Pinterest component that the data subject has visited our website, provided that the data subject is logged in at Pinterest at the time of the call-up to our website. This occurs regardless of whether the person clicks on the Pinterest component or not. If such a transmission of information to Pinterest is not desirable for the data subject, then he or she may prevent this by logging off from their Pinterest account before a call-up to our website is made.

33. Data protection provisions about the application and use of Twitter

On this website, we have integrated components of Twitter. Twitter is a multilingual, publicly-accessible microblogging service on which users may publish and spread so-called ‘tweets,’ e.g. short messages, which are limited to 140 characters. These short messages are available for everyone, including those who are not logged on to Twitter. The tweets are also displayed to so-called followers of the respective user. Followers are other Twitter users who follow a user’s tweets. Furthermore, Twitter allows you to address a wide audience via hashtags, links or retweets.

The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, United States of America.

With each call-up to one of the individual pages of this Internet site, which is operated by the controller and on which a Twitter component (Twitter button) was integrated, the Internet browser on the information technology system of the data subject is automatically prompted to download a display of the corresponding Twitter component of Twitter.

During the course of this technical procedure, Twitter gains knowledge of what specific sub-page of our website was visited by the data subject. The purpose of the integration of the Twitter component is a retransmission of the contents of this website to allow our users to introduce this web page to the digital world and increase our visitor numbers.

If the data subject is logged in at the same time on Twitter, Twitter detects with every call-up to our website by the data subject and for the entire duration of their stay on our Internet site which specific sub-page of our Internet page was visited by the data subject. This information is collected through the Twitter component and associated with the respective Twitter account of the data subject. If the data subject clicks on one of the Twitter buttons integrated on our website, then Twitter assigns this information to the personal Twitter user account of the data subject and stores the personal data.

Twitter receives information via the Twitter component that the data subject has visited our website, provided that the data subject is logged in on Twitter at the time of the call-up to our website. This occurs regardless of whether the person clicks on the Twitter component or not. If such a transmission of information to Twitter is not desirable for the data subject, then he or she may prevent this by logging off from their Twitter account before a call-up to our website is made.

34. Managing contacts and sending messages

This type of service makes it possible to manage a database of e-mail contacts, phone contacts or any other contact information to communicate with the User.

These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

34.1. MailChimp (The Rocket Science Group, LLC.)

MailChimp is an e-mail address management and message sending service provided by The Rocket Science Group, LLC.

Personal Data collected: e-mail address.

Place of processing: United States of America

35. Registration and authentication

By registering or authenticating, Users allow us to identify them and give them access to dedicated services.

Depending on what is described below, third-parties may provide registration and authentication services. In this case, our website will be able to access some Data, stored by these third-party services, for registration or identification purposes.

35.1. Direct registration

The data subject has the possibility to register on the website of the controller with the indication of personal data. Which personal data are transmitted to the controller is determined by the respective input mask used for the registration. The personal data entered by the data subject are collected and stored exclusively for internal use by the controller, and for his own purposes. The controller may request the transfer to one or more processors (e.g. a parcel service) that also uses personal data for an internal purpose which is attributable to the controller.

By registering on the website of the controller, the IP address — assigned by the Internet service provider (ISP) and used by the data subject — date, and time of the registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and, if necessary, to make it possible to investigate committed offences. Insofar, the storage of this data is necessary to secure the controller. This data is not passed on to third parties unless there is a statutory obligation to pass on the data, or if the transfer serves the aim of criminal prosecution.

The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject contents or services that may only be offered to registered users due to the nature of the matter in question. Registered persons are free to change the personal data specified during the registration at any time, or to have them completely deleted from the data stock of the controller.

The data controller shall, at any time, provide information upon request to each data subject as to what personal data are stored about the data subject. In addition, the data controller shall correct or erase personal data at the request or indication of the data subject, insofar as there are no statutory storage obligations. The entirety of the controller’s employees are available to the data subject in this respect as contact persons.

The User registers by filling out the registration form and providing the Personal Data directly to the website.

Personal Data collected: e-mail address, first name, last name and password.

The minimum information we need to register you (as above stated) is your name, e-mail address and a password. We will ask you more questions about different services, including sales promotions. Unless we say otherwise, you have to answer all the registration questions.

We may also ask some other, voluntary questions during registration for certain services (for example, professional networks) so we can gain a clearer understanding of who you are. This also allows us to personalise services for you.

To assist us in our marketing, in addition to the data that you provide to us if you register, we may also obtain data from trusted third-parties to help us understand what you might be interested in. This ‘profiling’ information is produced from a variety of sources, including publicly available data or from sources such as surveys and polls where you have given your permission for your data to be shared. You can choose not to have such data shared with us from these sources by logging into your account and changing the settings in the privacy section.

After you have registered, and with your permission, we may send you emails we think may interest you. Newsletters may be personalised based on what you have been reading on the website. At any time you can decide not to receive these emails and will be able to ‘unsubscribe’.

35.2. Updating your personal information

We offer an ‘Edit My Profile’ page, where you can update your personal information at any time, as well as to change your marketing preferences. You can get to this page from most pages on the website – simply click on the ‘Edit My Profile’ link at the right upper corner of the screen when you are signed in.40

36. SPAM protection

This type of service analyses the traffic on our website, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognised as SPAM.

37. Tag Management

This type of service helps us to manage the tags or scripts needed on our website in a centralised fashion.

This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.

37.1. Google Tag Manager (Google LLC)

Google Tag Manager is a tag management service provided by Google LLC.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States of America

38. Further information about Personal Data

38.1. Push notifications

Our website may send push notifications to the User.

38.2. Selling goods and services online

The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by our website depends on the payment system used.

38.3. The Service is not directed to children under the age of 13

Users declare themselves to be adult according to their applicable legislation. Minors may use our website only with the assistance of a parent or guardian. However, except for academics, scholars and students, we do not knowingly collect or store any personal information about children under the age of 16 and we do not offer any of our products or services directly to children under the age of 13. Therefore, under no circumstance, persons under the age of 13 may use our website.

39. Cookie Policy

Our website uses Cookies. To learn more and for a detailed cookie notice, you may consult the Cookie Policy.

39.1. We use cookies for a number of reasons:

  • For statistical purposes to track how many users we have and how often they visit our website. We collect information listing which of our pages are most frequently visited, and by which types of users and from which countries.
  • We use other organisations to collect anonymous user information, sometimes through cookies and web beacons, (information embedded in images which allow them to analyse how the website is being used and the number of visitors). For example, our website may feature proprietary measurement software, which will allow you to contribute to market research, like Digital Content Ratings.
  • We and other advertisers may use statistical cookies to track who has seen an advert and clicked on it. You can find more information on this in the advertising section of this privacy policy.
  • Placing cookies on your computer means we can show you advertisements that you might be interested in, and allows us to control the number of times you see them and measure how effective the ad campaign has been. Advertising helps us to keep the website free for you to use. You can find more information on this in the advertising section of this privacy policy, including how you can ‘opt out’.
  • We may use ‘Flash’ cookies to store your preferences for your media player (for example, volume and so on). If we do not use them, you may not be able to watch some video content.
  • You can turn cookies off but if you do this, you may not be able to use all services on our website and you might see more pop-ups and other advertising. This is because we would not be able to limit what you see by using cookies. However, you will still be able to see our editorial content.
  • We or other third-party companies may use cookies to suggest and deliver content which we believe may interest you.

By using the website, you are agreeing to the use of cookies as described.

40. Additional information about Data collection and processing

40.1. Legal action

The User’s Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of our website or the related services.

The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.

40.2. The legal basis for the processing

Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. 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, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, 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 be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third-party. Then the processing would be based on Art. 6(1) lit. d GDPR.

Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the above mentioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third-party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).

40.3. The legitimate interests pursued by the controller or by a third-party

Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favour of the well-being of all our employees and the shareholders.

40.4. Period for which the personal data will be stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After the expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract.

40.5. Provision of personal data as statutory or contractual requirement; Requirement necessary to enter into a contract; Obligation of the data subject to provide the personal data; possible consequences of failure to provide such data

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her.

The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact any employee. The employee clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary 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.

40.6. The existence of automated decision-making

As a responsible company, we do not use automatic decision-making or profiling.

40.7. Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, we may provide the User with additional and contextual information concerning particular services or the collection and processing of Personal Data upon request.

40.8. System logs and maintenance

For operation and maintenance purposes, we and any third-party services may collect files that record interaction with our website (System logs) or use for this purpose other Personal Data (such as IP Address).

40.9. Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

50. The rights of Users

Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.

Our website does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.

50.1. Right of confirmation

Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.

50.2. Right of access

Each data subject shall have the right granted by the European legislator to obtain from the controller-free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:

  • the purposes of the processing;
  • the categories of personal data concerned;
  • 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;
  • where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
  • the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
  • the existence of the right to lodge a complaint with a supervisory authority;
  • where the personal data are not collected from the data subject, any available information as to their source;
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

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

40.3.  Right to rectification

Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

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

40.4. Right to erasure (right to be forgotten)

This principle is commonly known as the ‘right to be forgotten’. General Data Protection Regulation enhances this concept to give individuals more power to request the removal or deletion of their personal data. Depending on the circumstances, organisations will also have to remove backups and archived data, as well as information shared with third parties.

Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:

  • The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • The data subject withdraws consent to which the processing is based according to the point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
  • The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
  • The personal data have been unlawfully processed.
  • The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
  • The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.

If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by CBD Life UK, he or she may, at any time, contact any employee of the controller. An employee of CBD Life UK shall promptly ensure that the erasure request is complied with immediately.

40.5. The right of restriction of processing

Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

  • The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
  • The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead of the restriction of their use instead.
  • The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
  • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.

If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by CBD Life UK, he or she may at any time contact any employee of the controller. The employee of CBD Life UK will arrange the restriction of the processing.

40.6. Right to data portability

Data portability is a new principle for data subjects. It allows individuals to obtain their personal data and reuse it elsewhere if they wish to. Organisations are obliged to comply with requests providing the information in question meets a specific set of criteria and must be provided in a commonly used and readable format.

Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

In order to assert the right to data portability, the data subject may at any time contact any employee of CBD Life UK.

40.7. Right to object

Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.

CBD Life UK shall no longer process the personal data in the event of the objection unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

If CBD Life UK processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to CBD Life UK to the processing for direct marketing purposes, then CBD Life UK will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by CBD Life UK for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, the data subject may contact any employee of CBD Life UK. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.

40.8. Automated individual decision-making, including profiling

Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision

  • is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or
  • is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or
  • is not based on the data subject’s explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, CBD Life UK shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.

If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of CBD Life UK.

40.9. Right to withdraw data protection consent

Each data subject shall have the right granted by the European legislator to withdraw his or her consent to the processing of his or her personal data at any time.

If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any employee of CBD Life UK.

41. Data protection for applications and the application procedures

The data controller shall collect and process the personal data of applicants for the purpose of the processing of the application procedure. The processing may also be carried out electronically. This is the case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a form on the website to the controller. If the data controller concludes an employment contract with an applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements. If no employment contract is concluded with the applicant by the controller, the application documents shall be automatically erased two months after notification of the refusal decision, provided that no other legitimate interests of the controller are opposed to the erasure. Another legitimate interest in this relation is, e.g. a burden of proof in a procedure under the General Equal Treatment Act (AGG).

42. Legal information

Under the European General Data Protection Regulation, we have to say who the ‘data controller’ is for our website and services provided through our website. The data controller is the organisation responsible for protecting information and, in our case, is CBDLife UK, 20-22 Wenlock Road, London, N1 7GU

Notice to European Users: this privacy statement has been prepared in fulfilment of the obligations under Art. 10 of EC Directive n. 95/46/EC, and under the provisions of Directive 2002/58/EC, as revised by Directive 2009/136/EC, on the subject of Cookies.

If you would like access to or a copy of the personal information we hold about you, to request a correction, or have any questions about how we may use it or to make a complaint, please contact the Data Protection Manager at the address shown above, or, e-mail to info@cbdlifeuk.com

Complaints will be dealt with by the Data Protection Manager and will be responded to within thirty days at the latest.

If you are not satisfied with the way your complaint was handled, you may be able to refer your complaint to your local data protection regulator.

43. Changes to this privacy policy

We reserve the right to make changes to this privacy policy at any time by giving notice to our Users on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using our website and can request that the Data Controller remove the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.

Where required by law, will we obtain your consent to make these changes.

This Policy applies from 24th May, 2018. If we change this Policy, we will announce its updated version on this page.