This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online offer and the websites, functions and contents connected to it, as well as external online presences, such as our social media profile (hereinafter collectively referred to as "online offer"). With regard to the terms used, such as "processing" or "responsible", we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Publisher (legal entity):
Company "ooo Герой" (ooo Geroy), registered company
OGRN 1172375019959, reg. Krasnodar, Russian Federation
350088 Krasnodar, Russian Federation
✆ Germany: + 49-40-22861140
✆ Austria: + 43-1-3649234
✆ Russia: + 7-499-6094132
✆ USA: + 1-408-7695407
Types of processed data:
- Inventory data (e.g., names, addresses).
- Contact details (eg, e-mail, telephone numbers).
- Content data (eg, text input, photographs, videos).
- Usage data (eg, visited websites, interest in content, access times).
- Meta / communication data (eg, device information, IP addresses).
Categories of affected persons
Visitors and users of the online offer (hereinafter we refer to the affected persons as "users").
Purpose of processing
- Provision of the online offer, its functions and contents.
- Answering contact requests and communicating with users.
- Safety measures.
- Reach Measurement / Marketing
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter the "data subject"); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (eg cookie) or to one or more special features, are the expression of the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.
"Processing" means any process performed with or without the aid of automated procedures, or any such process associated with personal data. The term goes far and includes virtually every handling of data.
"Pseudonymisation" means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data not assigned to an identified or identifiable natural person.
"Profiling" means any kind of automated processing of personal data that involves the use of such personal information to evaluate certain personal aspects pertaining to a natural person, in particular aspects relating to job performance, economic situation, health, personal To analyze or predict preferences, interests, reliability, behavior, whereabouts, or relocation of that natural person.
'Responsible person' means the natural or legal person, public authority, body or body which, alone or in concert with others, decides on the purposes and means of processing personal data.
"Processor" means a natural or legal person, public authority, body or body that processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Art. 13 GDPR, we will inform you of the legal basis for our data processing. Unless the legal basis is mentioned in the data protection declaration, the following applies: The legal basis for obtaining consent is Art. 6 Para. 1 lit. a and Art. 7 GDPR, the legal basis for processing for the performance of our services and implementation of contractual measures as well as answering inquiries is Art. 6 Para. 1 lit. b GDPR, the legal basis for processing to fulfill our legal obligations is Art. 6 Para. 1 lit. c GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6 Para. 1 lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d GDPR serves as the legal basis.
In accordance with Art. 32 GDPR, we take into account suitable technical considerations, taking into account the state of the art, the implementation costs and the type, scope, circumstances and purposes of the processing as well as the different probability and severity of the risk to the rights and freedoms of natural persons and organizational measures 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 access to the data, as well as the access, input, transfer, securing availability and their separation. Furthermore, we have set up procedures that guarantee the exercise of data subject rights, deletion of data and reaction to data threats. Furthermore, we 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 data protection-friendly default settings (Art. 25 GDPR).
Collaboration with processors and third parties
If we disclose data to other people and companies (processors or third parties) as part of our processing, transmit them to them or otherwise grant them access to the data, this will only be done on the basis of legal permission (e.g. if the data is transmitted to third parties, as to payment service providers, in accordance with Art. 6 Para. 1 b GDPR for the fulfillment of the contract), you have consented, a legal obligation provides for this or based on our legitimate interests (e.g. when using agents, web hosts, etc.).
If we commission third parties to process data on the basis of a so-called "order processing contract", this is done on the basis of Art. 28 GDPR.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this takes place within the scope of the use of third-party services or disclosure or transmission of data to third parties, this will only take place if it is carried out to fulfill our (pre) contractual obligations, based on your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only if the special requirements of Art. 44 ff. GDPR are met. This means that processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to the EU (e.g. for the USA through the "Privacy Shield") or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").
Rights of data subjects
You have the right to request confirmation as to whether the data in question are being processed and for information about this data and for further information and a copy of the data in accordance with Art. 15 GDPR.
You have accordingly. Art. 16 DSGVO the right to request the completion of the data concerning you or the correction of the incorrect data concerning you.
In accordance with Art. 17 GDPR, you have the right to request that the data in question be deleted immediately, or alternatively, in accordance with Art. 18 GDPR, to request that the processing of the data be restricted.
You have the right to request that the data concerning you, which you have provided to us, be received in accordance with Art. 20 GDPR and to request their transmission to other responsible parties.
You have also gem. Art. 77 GDPR the right to lodge a complaint with the competent supervisory authority.
You have the right to give consent in accordance with Revoke Art. 7 Para. 3 GDPR with effect for the future
You can object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection can in particular be made against processing for direct marketing purposes.
Cookies and right to object in direct mail
"Cookies" are small files that are stored on users' computers. Different information can be stored within the cookies. A cookie serves primarily to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, for example, the content of a shopping cart in an online shop or a login status can be saved. "Persistent" or "persistent" refers to cookies that remain stored even after the browser has been closed. For example, the login status can be saved if users visit them after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for range measurement or marketing purposes. A "third-party cookie" refers to cookies that are offered by providers other than the person responsible for providing the online offer (otherwise, if only their cookies are called "first-party cookies").
If users do not want cookies stored on their computer, they will be asked to disable the option in their browser's system settings. Saved 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 contradiction against the use of the cookies used for the purposes of online marketing can in a variety of services, especially in the case of tracking, on the US side http://www.aboutads.info/choices/ or the EU side http://www.youronlinechoices.com/ be explained. Furthermore, the storage of cookies can be achieved by switching them off in the settings of the browser. Please note that not all features of this online offer may be used.
Deletion of data
The data processed by us is deleted in accordance with Art. 17 and 18 GDPR or its processing is restricted. Unless expressly stated in this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory retention requirements. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be kept for commercial or tax law reasons.
According to legal requirements in Germany, storage is carried out in particular for 10 years in accordance with §§ 147 Paragraph 1 AO, 257 Paragraph 1 No. 1 and 4, Paragraph 4 HGB (books, records, management reports, accounting documents, trading books, more relevant for taxation Documents, etc.) and 6 years according to § 257 Paragraph 1 No. 2 and 3, Paragraph 4 HGB (commercial letters).
According to legal requirements in Austria, storage is carried out for 7 years in particular in accordance with Section 132 (1) BAO (accounting documents, receipts / invoices, accounts, receipts, business papers, statement of income and expenses, etc.) for 22 years in connection with land and for 10 years for documents in connection with electronically provided services, telecommunication, radio and television services, which are provided to non-entrepreneurs in EU member states and for which the Mini-One-Stop-Shop (MOSS) is used.
Participation in Affiliate Affiliate Programs
Within our online offering, we use our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offering) in accordance with. Art. 6 para. 1 lit. f GDPR, customary tracking measures insofar as these are necessary for the operation of the affiliate system. Below we explain the technical background to the users.
The services offered by our contractual partners can also be advertised and linked on other websites (so-called affiliate links or after-buy systems if, for example, links or third-party services are offered after a contract has been concluded). The operators of the respective websites receive a commission if users follow the affiliate links and then take advantage of the offers.
In summary, it is necessary for our online offer that we can track whether users who are interested in affiliate links and / or the offers available from us, then take advantage of the offers at the instigation of the affiliate links or our online platform. For this purpose, the affiliate links and our offers are supplemented by certain values that can be part of the link or otherwise, for example in a cookie. The values include in particular the initial website (referrer), time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking specific values such as advertising material ID, partner ID and categorizations.
The online identifiers of the users we use are pseudonymous values. This means that the online identifiers themselves do not contain any personal data such as names or email addresses. They only help us to determine whether the same user who clicked on an affiliate link or was interested in an offer via our online offer, took advantage of the offer, ie, for example, has concluded a contract with the provider. However, the online identifier is personal insofar as the partner company and also us have the online identifier together with other user data. This is the only way the partner company can tell us whether the user has taken advantage of the offer and we can, for example, pay out the bonus.
Amazon Affiliate Program
Further information on data use by Amazon and options for objection can be found in the company's data protection declaration: http://www.amazon.de/gp/help/customer/display.html/ref=footer_privacy?ie=UTF8&nodeId=3312401.
When contacting us (e.g. via contact form, e-mail, telephone or via social media), the information provided by the user for processing the contact request and processing it in accordance with Art. 6 para. 1 lit. b) GDPR processed. The information provided by users can be stored in a customer relationship management system (“CRM system”) or a comparable request organization.
We delete the requests, if they are no longer required. We check the requirement every two years; Furthermore, the legal archiving obligations apply.
Google Tag Manager
Google Tag Manager is a solution with which we can manage so-called website tags via an interface (and thus integrate Google Analytics and other Google marketing services into our online offer). The Tag Manager itself (which implements the tags) does not process any personal data of the users. With regard to the processing of users' personal data, reference is made to the following information about Google services. Usage guidelines: https://www.google.com/intl/de/tagmanager/use-policy.html.
Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offering and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous user profiles of the processed data can be created.
We only use Google Analytics with activated IP anonymization. This means that the IP address of the users is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.
The IP address submitted by the user's browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users may also prevent the collection by Google of the data generated by the cookie and related to their use of the online offer as well as the processing of this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
The personal data of users will be deleted or anonymized after 14 months.
Google Universal Analytics
We use Google Analytics in the form of "Universal Analytics" a. "Universal Analytics" refers to a process by Google Analytics in which the user analysis is based on a pseudonymous user ID and a pseudonymous profile of the user is created with information from the use of different devices (so-called "cross-device tracking") .
Targeting with Google Analytics
We use Google Analytics to display the advertisements displayed within Google's advertising services and its affiliates, only those users who have shown an interest in our online offering or who have certain characteristics (eg interest in specific topics or products visited by them) Web pages) that we submit to Google (so-called "Remarketing" or "Google Analytics Audiences"). With Remarketing Audiences, we also want to make sure that our ads meet the potential interest of users.
Integration of services and content of third parties
Based on our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit.f DSGVO), we make use of content or services offered by third-party providers in order to provide their content and services Integrate services such as videos or fonts (collectively referred to as "content").
This always presupposes that the third-party providers of this content perceive the IP address of the user, since without the IP address they could not send the content to their browser. The IP address is therefore required to display this content. 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 operating system, referring websites, time of visit and other information on the use of our online offer, as well as being linked to such information from other sources.
We integrate the videos of the platform “YouTube” from Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Data protection: https://www.google.com/policies/privacy/, Opt-out: https://adssettings.google.com/authenticated.