This Privacy Policy serves to illustrate the type, scope and purpose of processing your personal data (hereinafter referred to as "data") from our online offers and associated websites, functions and contents as well as external online presences, e.g. our social media profile (hereinafter jointly referred to as "online offer"). Regarding the use of terms such as "processing" or "controller", we are referring to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Lohmühlenstraße 65, 12435 Berlin, Germany
hello@sepster.com
+49 (0) 15223590776
Managing Board: Sepideh Razazzadeh
Contact data protection officer:
info@sepster.com
"Cookies" are small files stored on the user's computer and which can hold different forms of data. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his or her visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online offer and closes his browser. Cookiesare considered "permanent" or "persistent" and remain stored even after the browser is closed. For example, the login status can besaved several days after users visit a site. Likewise, cookies may store the interests of users as used for range measurement or marketing purposes. “Third-partycookies” are cookies offered by providers other than the controller servicing the online offer (in which case they are referred to as "first-partycookies"). We may use temporary and permanent cookies and clarify this within the framework of our data protection declaration. If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.A general objection to the use of cookies used for online marketing purposes can be declared for many of the services, especially in thecase of tracking, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that in this case not all functions of this online offercan be used. For many services, especially in the case of tracking, a general objection to the use of cookies for online marketing purposes can be filed via the US site
http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore , prohibiting the storage of cookies can be achieved by deactivating them in the browser settings. Please note that in this case not all functions of this online offer can be used.
We ask you to inform yourself regularly about the contents ofour data protection declaration. We will adapt the data protection declarationas soon as changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.
When contacting us (e.g. via contact form, e-mail, telephone orsocial media), the user's details are processed for processing the contact enquiry and its processing in accordance with Art. 6 para. 1 lit. b. GDPR. User information can be stored in a customer relationship management system ("CRM system") or comparable request organization. When contacting us(e.g. via contact form, e-mail, telephone or social media), the user's detailsare processed in order to complete the contact enquiry and together with itsprocessing in accordance with Art. 6 para. 1 lit. b. GDPR. User information canbe stored in a customer relationship management system ("CRM system")or comparable request organization.We delete the requests if they are no longer necessary. Wereview this requirement every two years; the statutory archiving obligationsalso apply. Requests that are no longer needed are deleted. We review this requirement every two years; here statutory archiving obligations also apply.
With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter you agree to the receipt and the described procedures. The following information informs you about the contents of our newsletter as well as theregistration, dispatch and statistical evaluation procedure and your rights of objection. By subscribing to our newsletter you agree to the reception and the describedprocedures. Content of the newsletter: We send newsletters, e-mails andother electronic notifications containing advertising information (hereinafter"newsletters") only with the recipients consent or legal permission.If the content of a newsletter is specifically described as part of theregistration, this is are decisive for the users’ consent. In addition, ournewsletters contain information about us and our services.Double opt-in and logging: Subscription to our newsletter takesplace in a so-called double opt-in procedure. This means that afterregistration you will receive an e-mail asking you to confirm yourregistration. This confirmation is necessary so that no one can log in withother e-mail addresses. Subscriptions to the newsletter are logged in order tobe able to prove the registration process in accordance with legalrequirements. This includes the storage of the login and confirmation time, aswell as the IP address. The changes to your data stored with the shippingservice provider are also logged.Credentials: To subscribe to the newsletter, simply enter youre-mail address. Optionally, we ask you to enter a name in the newsletter inorder to address us personally. The dispatch of the newsletter and theperformance measurement associated with it are based on the recipient's consentpursuant to Art. 6 para. 1 lit. a, Art. 7 GDPR in conjunction with § 7 para. 2no. 3 UWG or, if consent is not required, on the basis of our legitimate interests in direct marketing pursuant to Art. 6 para. 1 lit. f. GDPR inconjunction with Section 7 para. 3 UWG. The registration procedure is recordedon the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR. We are interested in the use of a user-friendly and secure newslettersystem that serves both our business interests and the expectations of usersand also allows us to provide proof of consent. Cancellation/Withdrawal - Youcan cancel the receipt of our newsletter at any time, i.e. withdraw yourconsent, through a cancelation link at the end of each newsletter. In order toprove a previously given consent, we may store the unsubscribed e-mailaddresses for up to three years on the basis of our legitimate interests beforedeleting them. The processing of this data is limited to the purpose of apossible defence against claims. An individual application for cancellation ispossible at any time, provided that a former existence of a consent isconfirmed at the same time.
On the basis of our legitimate interests (i.e. interest in theanalysis, optimisation and economic operation of our online offer in the senseof Art. 6 para. 1 lit. f. GDPR), in our website and in all subdomains we makeuse of Google Analytics, a web analysis service of Google Ireland Limited,Gordon House, Barrow Street, Dublin 4, Ireland ("Google") inaccordance with the following GDPR principles . Google uses cookies. The informationgenerated by the cookie about the use of the online offer by the user isusually transferred to a Google server in the USA and stored there.Google is certified under the Privacy Shield Agreement andthereby offers a guarantee of compliance with European privacy laws (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).Google will use this information on our behalf to evaluate theuse of our online services by users, to compile reports on the activitieswithin this online service and to provide us with other services associatedwith the use of this online service and the Internet. Pseudonymous userprofiles of the users can be created from the processed data.We only use Google Analytics with IP anonymization enabled. Thismeans that the IP address of the user is shortened by Google within memberstates of the European Union or in other contracting states of the Agreement onthe European Economic Area. Only in exceptional cases is the full IP addresstransmitted to a Google server in the USA and shortened there.The IP address transmitted by the user's browser is not mergedwith other Google data. Users may refuse the use of cookies by selecting theappropriate settings on their browser, they may also refuse the use of cookiesby selecting the appropriate settings on their browser, they may refuse thecollection of information by Google regarding the use of cookies and theprocessing of such information by Google by selecting the appropriate settingson their browser, and they may refuse the use of cookies by selecting theappropriate settings on their browser, and they may refuse the use of cookiesby selecting the appropriate settings on their browser, and by downloading andinstalling the browser plug-in available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.Further information on the use of data by Google, setting andobjection options can be found in Google's privacy policy (https://policies.google.com/privacy) and in thesettings for the display of advertising by Google (https://adssettings.google.com/authenticated).The personal data of the users will be deleted or anonymizedafter 14 months.
We use Google Analytics in the form of "universalanalytics". "Universal Analytics" refers to a Google Analyticsprocess in which user analysis is performed on the basis of a pseudonymous userID, thereby creating a pseudonymous profile of the user with information from theuse of various devices (so-called "cross-device tracking").
We use Google Analytics to display ads placed by Google and itspartners within our advertising services only to users who have shown aninterest in our online services or who have specific characteristics (e.g.interests in specific topics or products determined on the basis of the websites visited) that we transmit to Google (so-called "remarketing"or "Google Analytics Audiences"). With the help of remarketing audiences, we also want to ensure that our ads match the potential interest of users.
On the basis of our legitimate interests (i.e. interest in theanalysis, optimisation and economic operation of our online offer within themeaning of Art. 6 para. 1 lit. f. GDPR) we use the services of Google IrelandLimited, Gordon House, Barrow Street, Dublin 4, Ireland, ("Google").Google is certified under the Privacy Shield Agreement and thus offers aguarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).We use the online marketing tool Google "AdWords" to place ads in theGoogle Advertising Network (e.g., in search results, in videos, on websites,etc.) so that they are displayed to users who have a presumed interest in theads. This allows us to display ads for and within our online offer and morespecifically present users only with ads that potentially correspond to theirinterests. For example, if a user is shown ads for products in which they havedisplayed prior interest in other online offers, this is referred to as"remarketing". For these purposes, when our website and others onwhich the Google Advertising Network is active are accessed, Google directlyexecutes a code from Google and (re)marketing tags (invisible graphics or code,also known as "web beacons") are integrated into the website. Withtheir help, an individual cookie, i.e. a small file, is stored on the user'sdevice (comparable technologies can also be used instead of cookies). In thisfile it is noted which websites the user visits, which content they areinterested in and which offers the user has clicked on, technical informationon the browser and operating system, referring websites, visiting time andfurther information on the use of the online offer. We also receive anindividual "conversion cookie". The information collected with thehelp of cookies is used by Google to generate conversion statistics for us.However, we only see the total number of anonymous users who clicked on our adand were redirected to a page with a conversion tracking tag. However, we donot receive any information that personally identifies users. User data isprocessed pseudonymously within the Google advertising network. This means thatGoogle does not store and process, for example, the names or e-mail addressesof users, but processes the relevant data cookie-related within pseudonymous user profiles. This means from Google's point of view, the ads are not managedand displayed for a specifically identified person, but for the cookie holder,regardless of who this cookie holder is. This does not apply if a user hasexpressly permitted Google to process the data without this pseudonymisation. The information collected about the users is transmitted to Google and storedon Google's servers in the USA. Further information on data use by Google, possible settings and objections can be found in Google's data protection declaration (
https://policies.google.com/technologies/ads) and in the settings for the display of advertisements by Google (https://adssettings.google.com/authenticated). You may also object to the use of cookies for range measurement and advertisingpurposes via the deactivation page of the network advertising initiative (http://optout.networkadvertising.org/) andadditionally the US website (
http://www.aboutads.info/choices) or the European website (http://www.youronlinechoices.com/uk/your-ad-choices/).
On the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer in the senseof Art. 6 para. 1 lit. f. GDPR), we make use of Hotjar, a web analytics tool provided by Hotjar Ltd (Level 2, 3, Elia Zammit Street, St Julians STJ 1000,Malta, Europe), to record randomly selected, individual visits (only with ananonymous IP address). This creates a log of mouse movements and clicks withthe intention of randomly displaying individual website visits and deriving potential improvements for the website. In addition we use Hotjar in order to obtain user feedback for improving customer experience. The data which is collected by Hotjar is by default not visible for and will not be disclosed by us. Hotjar uses cookies and other technologies to collect data onour users’ behavior and their devices (in particular device's IP address(captured and stored only in anonymized form), device screen size, device type(unique device identifiers), browser information, geographic location (countryonly), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will everuse this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link. https://www.hotjar.com/legal/compliance/opt-out You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link. More information about what information Hotjar Ltd. collects and what security measures they use can be found in the terms and conditions http://hotjar.com/terms and the privacy policy
http://www.hotjar.com/privacy of Hotjar Ltd.
Within our online offer we use the service Visual Website Optimizer (a product of Wingify Software Private Limited, 404, Gopal Heights, Netaji Subhash Place, Pitam Pura, Delhi 110034, India). The personal data ofthe users are processed on the basis of our legitimate interests (i.e. interest in the analysis, optimisation and economic operation of our online offer in the sense of Art. 6 Para. 1 lit. f. GDPR). Visual Website Optimizer allows you to track the effects of various changes to a website (e.g. changes to input fields, design, etc.) within the framework of so-called "A/B-Testings", "Clicktracking" and "Heatmaps". A/B tests serve to improve the user-friendliness and performance of online offers. For example, users are presented with different versions of a website or its elements, such as input forms, on which the placement of the contents or labels of the navigation elements can differ. The behaviour of the users, e.g. lengthy stay on the website or morefrequent interaction with the elements, can then be used to determine which ofthese websites or elements correspond more closely to the needs of the users."Clicktracking" allows the user to keep track of the movements withinan entire online offering. Since the results of these tests are more accurateif the user's interaction can be followed over a certain period of time (e.g.if a user would like to return), cookies are usually stored on the user'scomputer for these test purposes. "Heatmaps" are mouse movements of theusers, which are combined to an overall picture, with the help of which it canbe recognized, for example, which web page elements are preferred and which webpage elements users prefer less.Cookies are only stored on users' devices for these test purposes.Only pseudonymous user data is processed. For more information about the VisualWebsite Optimizer please click on the following link: https://vwo.com/privacy-policy/.
We maintain online presences within social networks andplatforms in order to communicate with active customers, interested parties andusers and to inform them about our services. When accessing the respectivenetworks and platforms, the terms and conditions and the data processingguidelines of their respective operators apply. Unless otherwise stated in ourprivacy policy, we process the data of users who communicate with us withinsocial networks and platforms, e.g. write articles on our websites or send usmessages. We maintain online presences within social networks and platforms inorder to communicate with active customers, interested parties and users and toinform them about our services.We would like to point out that user data can be processed outsidethe European Union. This can pose risks for users because, for example, theenforcement of users' rights could be made more difficult. With regard to USproviders certified under the Privacy Shield, we would like to point out thatthey commit themselves to comply with EU data protection standards.Furthermore, user data is usually processed for market research and advertisingpurposes. Thus, for example, user profiles can be created from the userbehavior and the resulting interests of the users. The usage profiles can inturn be used, for example, to place advertisements inside and outside theplatforms that presumably correspond to the interests of the users. For thesepurposes, cookies are usually stored on the user's computer, in which theuser's usage behavior and interests are stored. Furthermore, data can also bestored in the user profiles independently of the devices used by the users(especially if the users are members of the respective platforms and are loggedin to these). The processing of users' personal data is carried out on thebasis of our legitimate interests in effective user information andcommunication with users pursuant to Art. 6 para. 1 lit. f. GDPR. If the usersare asked by the respective providers for consent to data processing (i.e. togive their consent e.g. by ticking a checkbox or confirming a button), thelegal basis of processing is Art. 6 para. 1 lit. a., Art. 7 GDPR. For adetailed description of the respective processing and the possibilities ofobjection (opt-out), we refer to the information provided by the providerslinked below. Also in the case of requests for information and the assertion ofuser rights, we point out that these can be asserted most effectively with theproviders. Only the providers have access to the data of the users and candirectly take appropriate measures and provide information. If you still needhelp, you can contact us. Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) - Privacy Policy:
https://www.facebook.com/about/privacy/, Opt-Out:
https://www.facebook.com/settings?tab=ads and
http://www.youronlinechoices.com, Privacy Shield:
https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active. Google/ YouTube (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) - Privacy Policy:
https://policies.google.com/privacy, Opt-Out:
https://adssettings.google.com/authenticated, Privacy Shield:
https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active. Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) - Privacy Policy/ Opt-Out:
http://instagram.com/about/legal/privacy/. Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) - Privacy Policy:
https://twitter.com/de/privacy, Opt-Out:
https://twitter.com/personalization, Privacy Shield:
https://www.privacyshield.gov/participant?id=a2zt000000000TORzAAO&status=Active. LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland) - Privacy Policy
https://www.linkedin.com/legal/privacy-policy Opt-Out:
https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out, Privacy Shield:
https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active.
Twitter
If the users are members of the Twitter platform, Twitter canassign calling up the above content and functions to the users' profiles there.Twitter is certified under the Privacy Shield Agreement and thus offers aguarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active).Privacy Policy:
https://twitter.com/de/privacy, Opt-Out: https://twitter.com/personalization.
Within our online offer, functions and contents of the Instagramservice, offered by Instagram Inc, 1601 Willow Road, Menlo Park, CA, 94025,USA, can be integrated. This may include, for example, content such as images,videos or texts and buttons that users can use to share content from thisonline offering within Instagram. If the users are members of the Instagramplatform, Instagram can assign the call of the above contents and functions tothe profiles of the users there. Instagram Privacy Policy: http://instagram.com/about/legal/privacy/.
Within our online offer, functions and contents of the LinkedInservice, offered by LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2,Ireland, can be integrated. This may include, for example, content such asimages, videos or texts and buttons with which users can share content fromthis online offer within LinkedIn. If the users are members of the LinkedInplatform, LinkedIn can assign the call of the above contents and functions tothe profiles of the users there. Privacy Policy of LinkedIn: https://www.linkedin.com/legal/privacy-policy.LinkedIn is certified under the Privacy Shield Agreement and thus offers aguarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active).Privacy Policy:
https://www.linkedin.com/legal/privacy-policy,Opt-Out: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.On the basis of our legitimate interests (i.e. interest in theanalysis of our online offer in the sense of Art. 6 para. 1 lit. f. GDPR), wemake use of some services from LinkedIn Ireland Unlimited Company (WiltonPlace, Dublin 2, Ireland) as described below. We use the site-wide Insight Tagon all our website pages to record actions taken by members reaching a specificURL and also the event-specific pixel to track conversions without anassociated URL. The LinkedIn Insight Tag enables the collection of data regardingmembers’ visits to your website, including the URL, referrer, IP address,device and browser characteristics, timestamp, and page views. This data isencrypted, then de-identified within seven days, and then de-identified data isdeleted within 90 days. LinkedIn does not share the personal data with us, itonly provides aggregated reports about the website audience and ad performance.LinkedIn also provides retargeting for website visitors, enabling us to showpersonalized ads off the website by using this data, but without identifyingthe member.You can opt-out to the data processing through LinkedIn byfollowing this opt-out link: https://www.linkedin.com/psettings/advertising. Incase you are not a LinkedIn Member you can opt-out by going to this link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.You can read LinkedIn Privacy Policy on the following link: https://www.linkedin.com/legal/privacy-policy.
We use the conversion and tracking tool Microsoft Advertising(formerly "Bing Ads") with the UET function (Universal EventTracking) of Microsoft Ireland Operations Limited (One Microsoft Place, SouthCounty Business Park, Leopardstown, Dublin 18, D18 P521) within our onlineservice due to our legitimate interests in the analysis, optimisation andeconomic operation of our online service (as defined in Art. 6 para. 1 lit. f.DSGVO).Microsoft stores cookies on users' devices in order to enable ananalysis of the use of our online services by users if users have reached ouronline services via a Microsoft Bing display (so-called "conversionmeasurement"). In this way, Microsoft and we can recognize that someonehas clicked on an advertisement, has been redirected to our online service andhas reached a predetermined target page ("conversion page"). We onlyget to know the total number of users who clicked on a Bing ad and wereredirected to the conversion page. No IP addresses are stored. No personalinformation about the identity of the users will be communicated.Microsoft is certified under the Privacy Shield Agreement andthereby assures compliance with European and Swiss data protection laws (https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&status=Active).If you do not wish to participate in the tracking process ofMicrosoft Advertising, you can also deactivate the necessary setting of acookie via your browser setting or use the opt-out page of Microsoft: http:/choice.microsoft.com/de-DE/opt-out.For more information about privacy and the use of cookies byMicrosoft Advertising, please see Microsoft's Privacy Statement: https://privacy.microsoft.com/de-de/privacystatement.
