Data Protection


Introduction

With the following data protection, we would like to inform you about which types of personal data (hereinafter also referred to as "data") we process for what purposes and to what extent. The data protection applies to all processing of personal data carried out by us, both within the framework the provision of our services as well as in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer").

The terms used are not gender-specific.

As of December 13, 2019

 

TABLE OF CONTENTS

  • Introduction

  • Responsible

  • Processing overview

  • Relevant legal bases

  • Safety measures

  • Transmission and disclosure of personal data

  • Data processing in third countries

  • Use of cookies

  • Communication via messenger

  • Providing of the online offer and web hosting

  • Onlinemarketing

  • Presence in social networks

  • Plugins and embedded functions as well as content

  • Deletion of data

  • Change and update of the data protection declaration

  • Rights of data subjects

  • Conceptual definitions

 

Responsible

Christian Feuerstein
Calle Lluis Marti 10, Atico
07006 Palma de Mallorca
Mallorca/Spain


Authorized representatives:


Daniel Ogrodowczyk

George Sand 4
07170 Valldemossa
Mallorca/Spain

E-Mail: info@marexperts.es

Telefone: +34 692 486 799

 

Processing overview

The following overview summarizes the types of data processed and the purposes of their processing and refers to the data subjects.

 

Types of processed data

  • Inventory data (e.g. names, addresses).

  • Content data (e.g., text input, photographs, videos).

  • Contact details (e.g. email, telephone numbers).

  • Meta / communication data (e.g. device information, IP addresses).

  • Usage data (e.g. visited websites, interest in content, access times).

 

Categories of data subjects

  • Interested persons.

  • Communication partner.

  • Users (e.g. website visitors, users of online services).

 

Processing purposes

  • Provision of our online offer and user-friendliness.

  • Visit campaign evaluation.

  • Direct marketing (e.g. by email or post).

  • Interest-based and behavioral marketing.

  • Contact requests and communication.

  • Conversion measurement (measurement of the effectiveness of marketing measures).

  • Profiling (creating user profiles).

  • Remarketing.

  • Range measurement (e.g., access statistics, recurring visitor detection).

  • Safety measures.

  • Tracking (e.g. interest / behavioral profiling, use of cookies).

  • Contractual services and service.

  • Management and answering inquiries.

 

Relevant legal bases

In the following, we share the legal basis of the General Data Protection Regulation (GDPR), on the basis of which we process personal data. Please note that in addition to the provisions of the GDPR, the national data protection requirements in your or our country of residence and domicile may apply.

  • Consent (Art. 6 Para. 1 S. 1 lit. a GDPR) - The data subject has given their consent to the processing of their personal data for a specific purpose or several specific purposes.

  • Fulfillment of contract and pre-contractual inquiries (Art. 6 Para. 1 S. 1 lit. GDPR) - The processing is necessary for the fulfillment of a contract to which the data subject is a party or for the implementation of pre-contractual measures at the request of the data subject respectively.

  • Legitimate interests (Art. 6 Para. 1 S. 1 lit. GDPR) - The processing is necessary to safeguard the legitimate interests of the person responsible or a third party, unless the interests or fundamental rights and freedoms of the data subject that protect personal data require, outweigh.

 

Safety measures

We take appropriate technical and organizational measures in accordance with the legal requirements, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of processing, as well as the different occurrence probabilities and the extent of the threat to the rights and freedoms of natural persons to ensure a level of protection appropriate to the risk.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling the physical and electronic access to the data as well as the access, input, transfer, safeguarding of availability and their separation. We have also set up procedures to ensure the enjoyment of data subject rights, the erasure of data and responses to the threat to data. We also take the protection of personal data into account when developing or selecting hardware, software and processes in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

 

Transmission and disclosure of personal data

As part of our processing of personal information, data may be transmitted to or disclosed to other entities, companies, legally independent organizational units or individuals. The recipients of this data can e.g. Payment institutions in the context of payment transactions, service providers commissioned with IT tasks or providers of services and content that are integrated into a website. In such a case, we observe the legal requirements and in particular conclude corresponding contracts or agreements that serve to protect your data with the recipients of your data.

Data transfer within the organization: We can transfer personal data to other locations within our organization or grant them access to this data. If this transfer takes place for administrative purposes, the transfer of the data is based on our legitimate business and business interests or takes place if it is necessary to fulfill our contractual obligations or if the data subject has given his consent or if he has a legal permit.

 

Data processing in third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing as part of the use of third-party services or the disclosure or transmission of data to other people, bodies or companies takes place, this takes place only in accordance with the legal requirements.

Subject to express consent or contractually or legally required transmission, we process or leave the data only in third countries with a recognized data protection level, to which the US processors certified under the "Privacy Shield" belong, or on the basis of special guarantees, e.g. process contractual obligations through so-called standard protection clauses of the EU Commission, the presence of certifications or binding internal data protection regulations (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

 

Use of cookies

Cookies are text files that contain data from visited websites or domains and are saved by a browser on the user's computer. A cookie is primarily used to store information about a user during or after visiting an online offer.
For the stored information e.g. the language settings on a website, the login status, a shopping cart or the place where a video was watched. The term cookies also includes other technologies that perform the same functions as cookies (e.g. if user information is saved using pseudonymous online identifiers, also known as "user IDs")

A distinction is made between the following types of cookies and functions:

  • Temporary cookies (also: session or session cookies): Temporary cookies are deleted at the latest after a user leaves an online offer and closes his browser.

  • Permanent cookies: Permanent cookies remain saved even after the browser is closed. For example, the login status can be saved or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users who are used for range measurement or for marketing purposes can be saved in such a cookie.

  • First-party cookies: We set first-party cookies ourselves.

  • Third-party cookies (also: third-party cookies): Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.

  • Necessary (also: essential or absolutely necessary) cookies: Cookies may be absolutely necessary for the operation of a website (e.g. to save logins or other user inputs or for security reasons).

  • Statistics, marketing and personalization cookies: In addition, cookies are usually also used in the scope of range measurement and when the interests of a user or his behavior (e.g. viewing certain content, use of functions, etc.) on individual websites in a user profile get saved. Such profiles serve to e.g. Display content that corresponds to your potential interests. This process is also referred to as "tracking", i.e. tracking the potential interests of the users. Insofar as we use cookies or "tracking" technologies, we will inform you separately in our data protection declaration or as part of obtaining consent.

Notes on legal bases: The legal basis on which we process your personal data with the help of cookies depends on whether we ask you for your consent. If this is the case and you consent to the use of cookies, the legal basis for the processing of your data is the declared consent. Otherwise, the data processed using cookies will be processed based on our legitimate interests (e.g. in a business operation of our online offer and its improvement) or, if the use of cookies is necessary, to fulfill our contractual obligations.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to revoke your consent or to object to the processing of your data by cookie technologies ( collectively referred to as "opt-out"). You can first declare your objection using the settings of your browser, e.g. by deactivating the use of cookies (which may also limit the functionality of our online offering). An objection to the use of cookies for online marketing purposes can also be declared using a variety of services, especially in the case of tracking, via the websites http://optout.aboutads.info and http://www.youronlinechoices.com/ become. In addition, you can receive further contradiction notices in the context of the information on the service providers and cookies used.

Processing of cookie data based on consent: Before we process or have data processed as part of the use of cookies, we ask users for consent that can be revoked at any time. Before consent has not been given, cookies are used that are necessary for the operation of our online offer. Their use is based on our interest and the interest of the users in the expected functionality of our online offer.

  • Processed data types: usage data (e.g. visited websites, interest in content, access times), meta / communication data (e.g. device information, IP addresses).

  • Affected persons: users (e.g. website visitors, users of online services).

  • Legal basis: consent (Art. 6 Para. 1 Clause 1 a) GDPR), legitimate interests (Art. 6 Para. 1 Clause 1 lit. GDPR).

 

Communication via messenger

We use messenger services for communication purposes and therefore ask that you observe the following information on the functionality of the messenger, encryption, use of the metadata for communication and your options for objection.

You can also contact us in alternative ways, e.g. contact by phone or email. Please use the contact options provided to you or the contact options specified within our online offer.

In the case of end-to-end encryption of content (i.e. the content of your message and attachments), we would like to point out that the communication content (i.e. the content of the message and attached images) will be encrypted from end to end. This means that the content of the messages is not visible, not even through the messenger providers themselves. You should always use a current version of the messenger with activated encryption, so that the encryption of the message content is ensured.

However, we would also like to point out to our communication partners that the providers of Messenger do not see the content, but can find out that and when communication partners communicate with us, as well as technical information about the device used by the communication partner and, depending on the settings of their device, location information ( so-called metadata) are processed.
Notes on legal bases: If we ask communication partners for permission before communicating with them via Messenger, the legal basis for our processing of their data is their consent. Incidentally, if we do not ask for consent and e.g. On our own initiative to contact us, we use Messenger in relation to our contractual partners and within the framework of contract initiation as a contractual measure and in the case of other interested parties and communication partners based on our legitimate interests in fast and efficient communication and meeting the needs of our communication partners communication via messengers. We would also like to point out that we will not transmit the contact details provided to us to Messenger for the first time without your consent.

Revocation, objection and deletion: You can revoke your consent at any time and object to communicate with us via Messenger at any time. In the case of communication via Messenger, we delete the messages in accordance with our general deletion guidelines (eg, as described above, after the end of contractual relationships, in the context of archiving requirements, etc.) and otherwise, as soon as we can assume that we have answered any information from the communication partners, if no reference to a previous conversation is to be expected and the deletion does not conflict with any statutory retention requirements.

Reservation of the reference to other communication channels: In conclusion, we would like to point out that for reasons of your security we reserve the right not to answer inquiries via Messenger. This is the case if e.g. Contract internals require special confidentiality or an answer via messenger does not meet the formal requirements. In such cases, we refer you to more adequate communication channels.

  • Processed data types: contact data (e.g. email, telephone numbers), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

  • Affected persons: communication partner.

  • Purposes of processing: contact inquiries and communication, direct marketing (e.g. by email or post).

  • Legal basis: consent (Art. 6 Para. 1 Clause 1 a) GDPR), legitimate interests (Art. 6 Para. 1 Clause 1 lit. GDPR).

Services and service providers used:

 

Provision of the online offer and web hosting

In order to be able to provide our online offer securely and efficiently, we use the services of one or more web hosting providers, from whose servers (or servers managed by them) the online offer can be accessed. For these purposes, we can use infrastructure and platform services, computing capacity, storage space and database services as well as security and technical maintenance services.

The data processed as part of the provision of the hosting offer can include all information relating to the users of our online offer, which is incurred in the context of use and communication. This regularly includes the IP address that is necessary to be able to deliver the content of online offers to browsers and all entries made within our online offer or on websites. Email sending and hosting: The web hosting services we use also include the sending, receiving and storage of emails. For these purposes, the addresses of the recipients and senders as well as further information regarding the sending of e-mails (e.g. the providers involved) and the content of the respective e-mails are processed. The aforementioned data can also be processed for the purpose of detecting SPAM. We ask you to note that e-mails are generally not sent encrypted on the Internet. As a rule, e-mails are encrypted during transport, but (unless an end-to-end encryption process is used) not on the servers from which they are sent and received. We can therefore accept no responsibility for the transmission path of the emails between the sender and the receipt on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on every access to the server (so-called server log files). The server log files can include the address and name of the accessed websites and files, date and time of access, transferred data volumes, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page) and, as a rule, IP Addresses and the requesting provider belong.

The server log files can be used on the one hand for security purposes, e.g. to avoid overloading the server (in particular in the event of abusive attacks, so-called DDoS attacks) and on the other hand to ensure the server's load and stability.

  • Processed data types: content data (e.g. text input, photographs, videos), usage data (e.g. visited websites, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

  • Affected persons: users (e.g. website visitors, users of online services).

  • Purposes of processing: contractual services and service.

  • Legal basis: legitimate interests (Art. 6 Para. 1 S. 1 lit. GDPR).

Services and service providers used:

 

Onlinemarketing

We process personal data for the purposes of online marketing, which in particular includes the marketing of advertising space or the display of advertising and other content (collectively referred to as "content") based on potential interests of the users and the measurement of their effectiveness.
For these purposes, so-called user profiles are created and saved in a file (so-called "cookie") or similar processes are used by means of which the information relevant to the presentation of the aforementioned content about the user is saved. For this information, e.g. Content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on times of use. If users have consented to the collection of their location data, this can also be processed.

The IP addresses of the users are also saved. However, we use available IP masking procedures (i.e. pseudonymization by shortening the IP address) to protect users. In general, no clear user data (such as e-mail addresses or names) is stored as part of the online marketing process, but pseudonyms. This means that we, as well as the providers of the online marketing process, do not know the actual identity of the user, but only the information stored in their profiles.

The information in the profiles is usually saved in the cookies or by means of similar processes. These cookies can generally later also be read on other websites that use the same online marketing process and analyzed for the purpose of displaying content, as well as supplemented with further data and stored on the server of the online marketing process provider.

In exceptional cases, clear data can be assigned to the profiles. This is the case if the users e.g. Are members of a social network whose online marketing process we use and the network connects the profiles of the users in the aforementioned information. We ask you to note that users have additional agreements with the providers, e.g. by consent in the context of registration.

We generally only have access to summarized information about the success of our advertisements. However, as part of so-called conversion measurements, we can check which of our online marketing processes have led to a so-called conversion, i.e. e.g., to conclude a contract with us. The conversion measurement is used solely to analyze the success of our marketing measures.
Unless otherwise stated, we ask you to assume that the cookies used will be stored for a period of two years.

Notes on the legal basis: If we ask the users for their consent to the use of third-party providers, the legal basis for the processing of data is the consent. Otherwise, the data of the users are processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.

  • Processed data types: usage data (e.g. visited websites, interest in content, access times), meta / communication data (e.g. device information, IP addresses).

  • Affected persons: users (e.g. website visitors, users of online services), interested parties.

  • Purposes of processing: tracking (e.g. interest / behavioral profiling, use of cookies), remarketing, visitor action evaluation, interest-based and behavioral marketing, profiling (creation of user profiles), conversion measurement (measuring the effectiveness of marketing measures), range measurement (e.g. access statistics, recognition of recurring events) visitors).

  • Security measures: IP masking (pseudonymization of the IP address).

  • Legal basis: consent (Art. 6 Para. 1 Clause 1 a) GDPR), legitimate interests (Art. 6 Para. 1 Clause 1 lit. GDPR).

  • Opposition option (opt-out): We refer to the data protection information of the respective provider and the options for objection given to the providers (so-called "opt-out"). Unless an explicit opt-out option has been specified, there is the possibility that you can deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore also recommend the following opt-out options, which are offered in summary for each area: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-Territory: http://optout.aboutads.info.

Services and service providers used:

 

Presence in social networks

We maintain online presences within social networks in order to communicate with the users active there or to offer information about us there.
We would like to point out that data from users outside the European Union can be processed. This can result in risks for the user, because e.g. enforcing users' rights could be difficult. With regard to US providers who are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we would like to point out that they are committed to complying with EU data protection standards.

Furthermore, the data of users within social networks are usually processed for market research and advertising purposes. For example, user profiles are created on the basis of user behavior and the resulting interests of users. The usage profiles can in turn be used to e.g. Place advertisements inside and outside the networks that are believed to correspond to the interests of the users. For these purposes, cookies are usually stored on the users' computers, in which the usage behavior and interests of the users are stored. Furthermore, data can be stored in the usage profiles regardless of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).

For a detailed description of the respective processing forms and the possibilities of objection (opt-out), we refer to the data protection declarations and information from the operators of the respective networks.
In the case of requests for information and the assertion of data subject rights, we would like to point out that these can be most effectively asserted by the providers. Only the providers have access to user data and can take appropriate measures and provide information directly. If you still need help, you can contact us.

  • Processed data types: inventory data (e.g. names, addresses), contact details (e.g. email, telephone numbers), content data (e.g. text input, photographs, videos), usage data (e.g. visited websites, interest in content, access times), meta/communication data (e.g. device information, IP addresses).

  • Affected persons: users (e.g. website visitors, users of online services).

  • Purposes of processing: contact requests and communication, tracking (e.g. interest / behavior-related profiling, use of cookies), remarketing, range measurement (e.g. access statistics, recognition of returning visitors).

  • Legal basis: legitimate interests (Art. 6 Para. 1 S. 1 lit. GDPR).
    Services and service providers used:

 

Plugins and embedded functions as well as content

We integrate functional and content elements into our online offer, which are obtained from the servers of their respective providers (hereinafter referred to as "third-party providers"). These can be, for example, graphics, videos or social media buttons and contributions (hereinafter: uniformly referred to as "content").

The integration always presupposes that the third-party providers of this content process the IP address of the users, since without the IP address they could not send the content to their browser. The IP address is therefore required to display this content or functions. We strive to only use content whose respective providers only use the IP address to deliver the content. Third-party providers can also use so-called pixel tags (invisible graphics, also known as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information can also be stored in cookies on the user's device and contain, among other things, technical information about the browser and the operating system, referring websites, the time of visit and other information on the use of our online offer, as well as being linked to such information from other sources.

Notes on the legal basis: If we ask the users for their consent to the use of third-party providers, the legal basis for the processing of data is the consent. Otherwise, the data of the users are processed on the basis of our legitimate interests (i.e. interest in efficient, economical and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.

  • Processed data types: usage data (e.g. visited websites, interest in content, access times), meta / communication data (e.g. device information, IP addresses), contact details (e.g. email, telephone numbers), content data (e.g. text input, photographs, videos) , Inventory data (e.g. names, addresses).

  • Affected persons: users (e.g. website visitors, users of online services), communication partners.

  • Purposes of processing: provision of our online offer and user-friendliness, contractual services and service, contact inquiries and communication, direct marketing (e.g. by email or post), tracking (e.g. interest / behavior-related profiling, use of cookies), interest-based and behavior-related marketing, profiling (Creation of user profiles), security measures, administration and answering inquiries.

  • Legal basis: legitimate interests (Art. 6 para. 1 sentence 1 lit. GDPR), consent (Art. 6 para. 1 sentence 1 lit. a GDPR), contract fulfillment and pre-contractual inquiries (Art. 6 para. 1 sentence 1 GDPR) 1 lit.b GDPR).

Services and service providers used:

 

Deletion of data

The data processed by us will be deleted in accordance with the legal requirements as soon as their consent for processing is revoked or other permits no longer apply (e.g. if the purpose of processing this data has ceased to apply or if it is not necessary for the purpose).

If the data is not deleted because it is required for other and legally permissible purposes, its processing is restricted to these purposes. This means that the data is blocked and not processed for other purposes. This applies e.g. for data that must be kept for commercial or tax law reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.

Further information on the deletion of personal data can also be given in the context of the individual data protection information in this data protection declaration.

 

Change and update of the data protection declaration

We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes make it necessary to act on your part (e.g. consent) or other individual notification.

If we provide addresses and contact information of companies and organizations in this data protection declaration, please note that the addresses can change over time and ask you to check the information before contacting us.

 

Rights of the data subjects

As the person concerned, you have various rights under the GDPR, which arise in particular from Articles 15 to 18 and 21 GDPR:

  • Right of objection: You have the right, for reasons that arise from your particular situation, at any time against the processing of your personal data, which is based on Art. 6 Para. 1 lit. e or f GDPR occurs to file an objection; this also applies to profiling based on these provisions. If the personal data concerning you are processed for direct marketing purposes, you have the right to object at any time to the processing of your personal data for the purpose of such advertising; this also applies to profiling insofar as it is connected to such direct advertising.

  • Right to withdraw consent: You have the right to withdraw consent at any time.

  • Right to information: You have the right to request confirmation as to whether the data in question is being processed and to request information about this data as well as further information and a copy of the data in accordance with the legal requirements.

  • Right to correction: In accordance with the legal requirements, you have the right to request the completion of the data concerning you or the correction of the incorrect data concerning you.

  • Right to deletion and restriction of processing: In accordance with the legal requirements, you have the right to request that the data relating to you be deleted immediately or, alternatively, to request that the processing of the data be restricted in accordance with the legal requirements.

  • Right to data portability: You have the right to receive data relating to you that you have provided to us in a structured, common and machine-readable format in accordance with legal requirements or to request that it be transmitted to another person responsible.

  • Complaint to the supervisory authority: You also have the right, in accordance with the legal requirements, to a supervisory authority, in particular in the member state of your habitual residence, your place of work or the place of the alleged infringement, if you believe that the processing of your personal data violates the GDPR.

 

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