▼ Table of Contents

1. Responsible Authority
2. General Information
   1. Inventory Data
   2. Usage Data
3. Hoster
   1. ALL-INKL.COM
   2. Firebase
4. First Contact through Electronic Request
5. Consent
6. Storage Period
7. Cookies
   1. More then essential Cookies
      1. Borlabs
         1. Borlabs Cookie
8. Users‘ Rights
   1. Deletion, Correction, Limitation
   2. Objection
   3. Data Transfer
   4. Complaint
9. Changes to the Privacy Policy
10. Website Analysis
    1. Matomo
       1. with Cookies
11. Map services
    1. OpenStreetMap
12. Cloud Storagesolutions
    1. Amazon Web Services

1 Responsible Authority

We are happy about you visiting our website. We would like to introduce you to the responsible authority in terms of data protection law as applicable:

Placed GmbH
represented by the Manager
Tom Leppin, Kjell Ole Beckmann
Mühlenstr. 8a
14167 Berlin
Phone: +49 30 99405770
E-mail: info@placed.digital

2 General Information

Pursuant to our statutory obligations, we would like to inform you about the collection and use of your personal data.

When you use our website, personal data about you will be collected. This may happen by you entering the data yourself, for example your e-mail address. But our system also collects your data automatically, for example whenever you visit our website. This happens irrespective of the device or the software that you use to visit our website.

All data that you enter in our app is provided voluntarily; there are no disadvantages to you if you do not provide data. But without certain data, we are unable to provide services or to conclude contracts. Whenever such information is necessary, we will point it out to you.

On this website, the user’s personal data is only collected within the framework of the existing data-protection law, in particular the General Data Protection Regulation (GDPR). The legal terms used in the text are defined in Art. 4 of the GDPR.

The GDPR allows data processing in three cases in particular:

• in accordance with Art. 6 para. 1 (a) and 7 GDPR, when you have consented to us processing your data; in this Privacy Policy and in the cases of consent pursuant to Art. 4 no. 11 GDPR, we will inform you in detail and each time for what purposes and under what circumstances your data will be processed by us;
• in accordance with Art. 6 para. 1 (b) GDPR, when processing your personal data is necessary for negotiating, concluding or performing a contract;
• in accordance with Art. 6 para. 1 (f) GDPR, if the balancing of interests leads to the conclusion that the processing is necessary to protect our legitimate interests; this means in particular our interests to analyse, optimise and secure the offers on our website – meaning primarily the analysis of user behaviour, setting up profiles for advertisement purposes and storage of access data as well as the use of third-party providers.

2.1 Inventory Data

We collect inventory data as far as it is necessary to establish, negotiate or amend a contract (including one without remuneration) between us and the user. This can be: customer data (for example name, address), contact data (for example e-mail address, phone number), service data (for example services ordered, duration, payment). Upon establishing the user relationship, we will ask you for this data (for example name, address and e-mail address) and will also tell you which of the information is required to establish the user relationship.

2.2 Usage Data

We also collect usage data to allow users to use the services on our website. These may consist of: usage information (for example visited websites or parts, duration of visit, interest in services), content data (for example data, text, images, sounds, videos entered or uploaded by you), meta data (for example identity of your device, location, IP address).

We will only combine usage data if and insofar as it is necessary for billing purposes. Otherwise, we will only put together usage data pseudonymously and only insofar as you have not objected. You may send this objection to the address indicated in the “About Us” section or the responsible authority indicated in this Privacy Policy at any time.

The legal basis for this data processing are our legitimate interests pursuant to Art. 6 para. 1 (f) GDPR in analysing the website and your use, possibly also the statutory permission to store data as part of the negotiation of a contract pursuant to Art. 6 para. 1 (b) GDPR.

3 Hoster

3.1 ALL-INKL.COM

Our Website is presented in the Internet by a service provider. We use the service of ALL-INKL.COM, Neue Medien Münnich, Owner: René Münnich, Hauptstraße 68, D-02742 Friedersdorf. We have concluded a data processing agreement with our provider. With this contract, our provider is obliged to process the data according to our instructions. You can find more information on data processing at our provider in his privacy policy at https://all-inkl.com/datenschutzinformationen/. The legal basis for this data processing is on the one hand our legitimate interest in a technologically perfect online offering and its design and optimization in an economically efficient manner pursuant to Art. 6 para. 1 (f) GDPR, and, on the other hand, our contractual or pre-contractual legal relationship in accordance with Art. 6 para. 1 (b) GDPR.
Furthermore, our provider stores information, the so-called server log files, each time the website is used; this is information which is automatically transferred by your browser. In detail, this data consists of:

• your IP address
• type and version of your browser
• host name
• time of visit
• the page from which you came to our page
• name of the page opened
• exact time of usage as well as
• the amount of data transferred

This data will only be used for statistical purposes and do not allow us to identify you as a user.“

3.2 Firebase

Our Website is presented in the Internet by a service provider. We use the service Firebase, Google Ireland Limited, Firebase, Gordon House, Barrow Street, Dublin 4, Irland. We have concluded a data processing agreement with our provider. With this contract, our provider is obliged to process the data according to our instructions. You can find more information on data processing at our provider in his privacy policy at https://firebase.google.com/support/privacy?hl=de. The legal basis for this data processing is on the one hand our legitimate interest in a technologically perfect online offering and its design and optimization in an economically efficient manner pursuant to Art. 6 para. 1 (f) GDPR, and, on the other hand, our contractual or pre-contractual legal relationship in accordance with Art. 6 para. 1 (b) GDPR.

Furthermore, our provider stores information, the so-called server log files, each time the website is used; this is information which is automatically transferred by your browser. In detail, this data consists of:

• your IP address
• type and version of your browser
• host name
• time of visit
• the page from which you came to our page
• name of the page opened
• exact time of usage as well as
• the amount of data transferred

This data will only be used for statistical purposes and do not allow us to identify you as a user.

4 First Contact through Electronic Request

If you contact us in electronic form (for example by mail, fax, phone, messenger, etc.), we store and process the data which you have given us (for example name, contact information, content of the request). This is based on our legitimate interest in an effective communication with customers in accordance with Article 6 para. 1 (a) GDPR and, as far as it concerns a request to enter into or to perform a contract, also with Article 6 para. 1 (b) GDPR.
We will only pass on this data to third parties as far as required for the performance of the contract (in accordance with Article 6 para. 1 (b) GDPR), by the overwhelming interest in effective services (in accordance with Article 6 para. 1 (f) GDPR) or based on your consent (in accordance with Article 6 para. 1 (a) GDPR) or if there is another legal permission or obligation.
You may ask us at any time and without any cost to provide information about the purpose of the processing, the origin and the recipient, if any, of your data. You may also request that we correct, delete or limit the processing of your personal data. You may object against the (further) processing of your data at any time and you have a right for the data to be made transferable as well as the right to file a complaint with the competent supervisory agency.
In general, your data will only remain stored as long as required by the purpose of the respective data processing. A longer storage is an option, in particular when required in order to pursue our rights, for other legitimate interests of ours or when there is a statutory duty to keep the data longer (for example record-keeping under tax law, statute of limitations).

5 Consent

Whenever we ask you for your consent for the processing of your data, we will inform you in clear language and in an easily accessible way about the cases for which you will be granting your consent. Any consent that we ask you for is voluntary. Any advantage that you wish to gain by granting consent is also available without consent; simply ask us.

Regarding any consent, you have the right to revoke any consent given to us for the processing of your personal data at any time. You just need to contact us without any particular formal requirement, for example through our contact form, an e-mail to the e-mail address indicated in the “About Us” section or a link to unsubscribe (if offered by us). Your withdrawal has no effect on the legality of the data processing carried out up to that point.

6 Storage Period

Generally, your data will only remain stored as long as required by the purpose of the respective data processing. Storage beyond that is possible in particular if it is still required for pursuing our rights or for other legitimate interests of ours.
For your inventory data which were necessary to perform a contract (including one without remuneration), this means that we store this data until the complete performance or termination of the contractual relationship plus the limitation period (which is generally 2 or 3 years) plus an adequate extra time for potential interruptions of the limitation period.
For your usage data which was collected in the course of your use of the website, this means that we will store it only for the time still required for the proper functionality of our website and as long as we still have a legitimate interest. Statistical information will be primarily stored by us in pseudonymous form.
Beyond that, we still store your data for as long as we are required to do so by law. This concerns in particular the tax-law requirements to keep records, usually for 6 or even 10 years.

7 Cookies

7.1 More then essential Cookies

Upon opening the website, we have asked you to consent to the storing of certain cookies which will be placed while you visit our website. Based on your consent pursuant to Art 6 para. 1 (a) GDPR, our website thus uses cookies, so that our offer can be used in a better, more effective and more secure way.
A cookie is a record of information that is stored on your terminal device (computer, tablet, smartphone, etc.). These can be “session cookies”, which are automatically deleted when you leave our website. Other cookies are stored on your computer permanently until you delete them. That allows us to recognize your browser when you visit our website again and to provide you with features or offers according to your previous usage.

Your browser allows you to prevent the use of cookies in general or in specific cases. Please check the instructions for your browser to find out more about this. You can also delete cookies following these instructions which we have listed for you:

for Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=en
for Safari: https://support.apple.com/en-gb/guide/safari/sfri11471/mac
for Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox
for Edge: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
for Internet Explorer: https://support.microsoft.com/en-gb/help/278835/how-to-delete-cookie-files-in-internet-explorer

Blocking cookies may limit the functionality of our website and of other websites visited by you.
More information on this topic, in particular how you can administer, limit or completely disable third-party cookies and technologies with a similar purpose, can be found at:
https://www.aboutads.info/choices
https://www.youronlinechoices.eu
https://www.networkadvertising.org/choices

7.1.1 Borlabs

In order to obtain your consent to store certain cookies on your device and to document this in line with data protection law, and in line with our legal obligations under Art. 6 para. 1 sentence 1 (c) GDPR and our legitimate interest in accordance with Art. 6 para. 1 (f) GDPR, we use the Cookie Consent Manager “Borlabs Cookie“ provided by Borlabs - Benjamin A. Bornschein, Georg-Wilhelm-Str. 17, 21107 Hamburg, Germany.
Borlabs Cookie only places cookies that are technologically necessary. When you open our website, the following data will be sent to Borlabs Cookie: your consent or the withdrawal of your consent for placing cookies, a cookie placed on your browser by Borlabs Cookie, the duration and version of the cookie, domain and path of the WordPress website and the UID. The UID is a randomly generated ID and no personal information.
Borlabs Cookie processes no personal data. If you want to withdraw the consent to place certain cookies, simply delete the cookie in your browser. When you re-enter/reload the website, you will be asked for your consent to place cookies again.
You can find detailed information about the privacy policy of Borlabs Cookies at: https://de.borlabs.io/datenschutz/

7.1.1.1 Borlabs Cookie

For the Cookie Opt In we use the Wordpress plugin from Borlabs (https://borlabs.io/borlabs-cookie/) and you can adapt here your settings.
Borlabs Cookie Settings

8 Users‘ Rights

You may request us anytime to provide information about the personal data stored about you free of charge. To avoid misuse, this will require personal identification.

8.1 Deletion, Correction, Limitation

You may at any time demand from us that we correct (or complete) incorrect data as well as a limitation of the processing of data or deletion of your data. This applies in particular if the reason for processing the data is no longer valid, if a required consent has been revoked and there is no other legal basis or if our data processing is unlawful. We will then correct, block or even delete your personal data without delay as far as permitted by law.

8.2 Objection

The right to object to advertisement is governed by our text regarding consent:
Regarding any consent, you have the right to revoke any consent given to us for the processing of your personal data at any time. You just need to contact us without any particular formal requirement, for example through our contact form, an e-mail to the e-mail address indicated in the “About Us” section or a link to unsubscribe (if offered by us). Your withdrawal has no effect on the legality of the data processing carried out up to that point.

8.3 Data Transfer

You may request us to transfer the data stored about you in machine-readable form.

8.4 Complaint

If you feel that our data processing has violated any of your rights, you may file a complaint with the competent regulatory agency (here you find a list of the agencies).

9 Changes to the Privacy Policy

If and when factual or legal reasons will compel us to amend the Privacy Policy, we will update this page accordingly. This will not change the consent provided by the user.

10 Website Analysis

10.1 Matomo

Based on our legitimate interest in a technologically perfect online offering and its design and optimisation in an economically efficient manner pursuant to Art. 6 para. 1 (f) GDPR, we use the open-source programme Matomo, a web analysis tool.

10.1.1 with Cookies

To optimise the offered website, Matomo will place cookies. Cookies are text files which are stored on your computer and which transmit information about the use of the page, including the user's shortened IP address, to the provider. The user's IP address will immediately be anonymised, so that the user cannot be identified by the provider. The data collected in that way will not be passed on to third parties by the operator of this website.

You may prevent the use of cookies by changing the preferences in the browser. Here you find instructions in German: http://www.akademie.de/wissen/do-not-track-datenschutz. This may however impede the use of this and of other websites.

If you do not agree with the storing and analysis of your data, you subsequently have the opportunity to object to the analysis by Matomo.

Opt-out complete; your visits to this website will not be recorded by the Web Analytics tool. Note that if you clear your cookies, delete the opt-out cookie, or if you change computers or Web browsers, you will need to perform the opt-out procedure again.

You may choose to prevent this website from aggregating and analyzing the actions you take here. Doing so will protect your privacy, but will also prevent the owner from learning from your actions and creating a better experience for you and other users.

You are not opted out. Uncheck this box to opt-out. You are currently opted out. Check this box to opt-in.

The tracking opt-out feature requires cookies to be enabled.

11 Map services

11.1 OpenStreetMap

Based on your consent pursuant to Art.6 para. 1 (a) GDPR, we use the HTMP geo-location API provided by the open-source OpenStreetMap Foundation, 132 Maney Hill Road, Sutton Coldfield, West Midlands, B72 1JU, UK, to use your location for location-specific offers.
If you use the location detection function via HTML5 geolocation API, the OpenStreetMap API transmits the location data you entered to the OpenStreetMap search engine, which determines the coordinates of your current location and converts it into an address. However, your IP address will not be transmitted.
Further information about the use of your data by OpenStreetMap can be found in the privacy policy of OpenStreetMap https://wiki.osmfoundation.org/wiki/Privacy_Policy. Your data will only be used there in anonymous form.
If you don't want your data to be transmitted, you don't need to activate the location data.

12 Cloud Storagesolutions

12.1 Amazon Web Services

For our data processing, we use the cloud solution Amazon Webservices, a service of Amazon Web Services Inc. 410 Terry Avenue North, Seattle WA 98109, United States.

The legal bases for this data processing are
- our contractual or pre-contractual legal relationship with you pursuant to Art. 6 para. 1 lit. b GDPR as well as
- our legitimate interest in a technically proper online offer and its economically efficient design and optimization pursuant to Art.6 para. 1 lit.f GDPR.

Since we use this provider as a cloud solution, it is possible for this cloud provider to take note of our data. This is also data that can identify a person with manageable effort ("personal data"). This personal data is in principle all data that you share with us on the occasion of the use of the website and in connection with our general communication and which we then process or enter by means of this cloud provider.

This may include contact information (such as email address or phone number), billing information (name, billing address, payment method, and bank account information), information relating to related third party accounts (such as the email address or username for a related PayPal, Google, or Facebook account), scanned identification documents provided to us (such as ID, driver's license, passport, or official company registration documents), and any other personal information (if you have provided it to us). However, our cloud provider will not evaluate or use this data.

We have entered into an order processing agreement with this provider, according to which this provider will only process your data on our behalf within the scope of the GDPR and according to our instructions.

When using this provider, it may happen that your data is transferred to the USA. However, we have ensured that your data is only transferred to the USA on the basis of a contract in accordance with the standard contractual clauses. According to the GDPR and the EuGH, this is a legal basis for the transfer of data to the USA. Furthermore this provider is certified according to the EU-US Data Privacy Framework. This means that the transfer of data to the USA is possible in a legally secure manner on the basis of the adequacy decision concluded on 10.07.2023.

For more information on data processing by this provider, you can read its privacy policy at https://aws.amazon.com/de/privacy/?nc1=f_pr.

Aufgrund unserer Unternehmensgröße sind wir gem. §38 Abs. 1 Bundesdatenschutzgesetz gesetzlich nicht verpflichtet, einen Datenschutzbeauftragten zu bestellen. Richten Sie bitte Ihre Fragen zum Datenschutz an unseren Geschäftsführer Herr Leppin
- per E-Mail datenschutz@placed.digital oder
- postalisch mit dem Zusatz „Datenschutz“ an die oben genannte Adresse.

This is our current valid privacy policy from 16.05.2024