Privacy Policy
This is a convenience translation. The German version is legally binding.
1. Data protection at a glance
General information
The following information provides a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to personally identify you. For detailed information on data protection, please refer to our privacy policy set out below this text.
Data collection on this website
Who is responsible for data collection on this website?
Data processing on this website is carried out by the website operator. You can find the operator's contact details in the section "Information on the controller" in this privacy policy.
How do we collect your data?
On the one hand, your data is collected when you provide it to us. This may, for example, be data you enter into a contact form.
Other data is collected automatically or with your consent by our IT systems when you visit the website. This is primarily technical data (e.g. internet browser, operating system or time of the page request). This data is collected automatically as soon as you enter this website.
What do we use your data for?
Some of the data is collected to ensure that the website is provided without errors. Other data may be used to analyze your user behavior. If contracts can be concluded or initiated via the website, the transmitted data is also processed for contract offers, orders or other order inquiries.
What rights do you have regarding your data?
You have the right at any time to receive information free of charge about the origin, recipients and purpose of your stored personal data. You also have the right to request the rectification or erasure of this data. If you have given your consent to data processing, you can revoke this consent at any time with effect for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.
You can contact us at any time regarding this and any other questions on the subject of data protection.
Analysis tools and third-party tools
When you visit this website, your surfing behavior may be statistically analyzed. This is done primarily with so-called analysis programs.
Detailed information on these analysis programs can be found in the following privacy policy.
2. Hosting
We host the contents of our website with the following provider:
External hosting
This website is hosted externally. The personal data collected on this website is stored on the servers of the host(s). This may include, in particular, IP addresses, contact requests, meta and communication data, contract data, contact details, names, website accesses and other data generated via a website.
External hosting is carried out for the purpose of fulfilling contracts with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of a secure, fast and efficient provision of our online offering by a professional provider (Art. 6(1)(f) GDPR). If corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG (German Telecommunications Digital Services Data Protection Act), insofar as the consent covers the storage of cookies or access to information in the user's end device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be revoked at any time.
Our host(s) will only process your data to the extent necessary to fulfill their performance obligations and will follow our instructions with regard to this data.
We use the following host(s):
Novosky, Owner Lucas Teichmann
Holzhofstraße 8
55116 Mainz, Germany
The servers are operated in a Microsoft Azure data center (Microsoft Ireland Operations Ltd.) in the West Europe region (Netherlands); no transfer to third countries outside the EU/EEA takes place for hosting.
Data processing agreement
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law, which ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.
3. General notes and mandatory information
Data protection
The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.
When you use this website, various personal data is collected. Personal data is data that can be used to personally identify you. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.
We would like to point out that data transmission over the internet (e.g. when communicating by email) may be subject to security vulnerabilities. Complete protection of data against access by third parties is not possible.
Information on the controller
The controller responsible for data processing on this website is:
circolution GmbH
Münchener Straße 10 | 60329 Frankfurt am Main, Germany
Phone: +49 (0) 174 8995096
Email: datenschutz@circolution.com
The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, email addresses, etc.).
Storage period
Unless a more specific storage period is stated within this privacy policy, your personal data will remain with us until the purpose for the data processing no longer applies. If you assert a legitimate request for erasure or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, erasure takes place once these reasons no longer apply.
General information on the legal bases for data processing on this website
If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, insofar as special categories of data pursuant to Art. 9(1) GDPR are processed. In the event of express consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or to access to information in your end device (e.g. via device fingerprinting), data processing is additionally carried out on the basis of § 25 (1) TDDDG. Consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, we process your data insofar as it is required to fulfill a legal obligation on the basis of Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. The legal bases applicable in each individual case are explained in the following paragraphs of this privacy policy.
Recipients of personal data
In the course of our business activities, we work with various external parties. In some cases, this also requires the transfer of personal data to these external parties. We only pass on personal data to external parties if this is necessary in the context of fulfilling a contract, if we are legally obliged to do so (e.g. passing on data to tax authorities), if we have a legitimate interest in the transfer pursuant to Art. 6(1)(f) GDPR, or if another legal basis permits the transfer of data. When using processors, we only pass on personal data of our customers on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.
Revocation of your consent to data processing
Many data processing operations are only possible with your express consent. You can revoke consent you have already given at any time. The lawfulness of the data processing carried out up to the revocation remains unaffected by the revocation.
Right to object to data collection in special cases and to direct advertising (Art. 21 GDPR)
If data processing is carried out on the basis of Art. 6(1)(e) or (f) GDPR, you have the right at any time to object to the processing of your personal data on grounds relating to your particular situation; this also applies to profiling based on these provisions. The respective legal basis on which processing is based can be found in this privacy policy. If you object, we will no longer process your personal data concerned unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defense of legal claims (objection pursuant to Art. 21(1) GDPR).
If your personal data is processed for the purpose of direct advertising, you have the right to object at any time to the processing of personal data concerning you for the purpose of such advertising; this also applies to profiling insofar as it is associated with such direct advertising. If you object, your personal data will subsequently no longer be used for the purpose of direct advertising (objection pursuant to Art. 21(2) GDPR).
Right to lodge a complaint with the competent supervisory authority
In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged violation. The right to lodge a complaint exists without prejudice to any other administrative or judicial remedy. The supervisory authority responsible for us is the Hessian Commissioner for Data Protection and Freedom of Information (HBDI), Postfach 3163, 65021 Wiesbaden, Germany.
Right to data portability
You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a commonly used, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.
Information, rectification and erasure
Within the framework of the applicable statutory provisions, you have the right at any time to free information about your stored personal data, its origin and recipients and the purpose of the data processing and, if applicable, a right to rectification or erasure of this data. You can contact us at any time regarding this and any other questions on the subject of personal data.
Right to restriction of processing
You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restriction of processing exists in the following cases:
- If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
- If the processing of your personal data was/is unlawful, you can request the restriction of data processing instead of erasure.
- If we no longer need your personal data but you need it for the exercise, defense or establishment of legal claims, you have the right to request the restriction of the processing of your personal data instead of erasure.
- If you have lodged an objection pursuant to Art. 21(1) GDPR, a balancing of your interests and ours must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.
If you have restricted the processing of your personal data, this data may – apart from its storage – only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the European Union or a Member State.
SSL or TLS encryption
For security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.
If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
Objection to advertising emails
We hereby object to the use of contact data published within the scope of the legal notice obligation for the transmission of advertising and information materials not expressly requested. The operators of the pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, for example through spam emails.
4. Data collection on this website
Cookies
Our website uses so-called "cookies". Cookies are small data packets and do not cause any damage to your end device. They are stored on your end device either temporarily for the duration of a session (session cookies) or permanently (permanent cookies). Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your end device until you delete them yourself or they are automatically deleted by your web browser.
Cookies can originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services provided by third-party companies within websites (e.g. cookies for processing payment services).
Cookies have various functions. Numerous cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies may be used to analyze user behavior or for advertising purposes.
Cookies that are required to carry out the electronic communication process, to provide certain functions you have requested (e.g. for the shopping cart function) or to optimize the website (e.g. cookies for measuring the web audience) (necessary cookies) are stored on the basis of Art. 6(1)(f) GDPR, unless another legal basis is stated. The website operator has a legitimate interest in the storage of necessary cookies for the technically error-free and optimized provision of its services. If consent to the storage of cookies and comparable recognition technologies has been requested, processing is carried out exclusively on the basis of this consent (Art. 6(1)(a) GDPR and § 25 (1) TDDDG); consent can be revoked at any time.
You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general, and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited.
This website itself does not set any cookies without your consent; only if you consent to web analysis via the cookie notice are the cookies described in the section "Google Analytics" set. You can change your selection at any time via "Cookie settings" in the page footer.
Server log files
The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are: browser type and browser version, operating system used, referrer URL, time of the server request and IP address. This data is not merged with other data sources. This data is collected on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of its website – for this purpose, the server log files must be collected.
Contact form
If you send us inquiries via the contact form, your details from the inquiry form, including the contact details you provide there, will be stored by us for the purpose of processing the inquiry and in the event of follow-up questions. We do not pass on this data without your consent.
For the processing and follow-up of inquiries, we transfer the data you enter in the contact form server-side to our customer relationship management system (CRM); for details, please refer to the section "HubSpot CRM" in this privacy policy.
This data is processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of inquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this has been requested; consent can be revoked at any time.
The data you enter in the contact form will remain with us until you request its erasure, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after your inquiry has been fully processed). Mandatory statutory provisions – in particular retention periods – remain unaffected.
5. Newsletter data
If you would like to receive the newsletter offered on the website, we require an email address from you as well as information that allows us to verify that you are the owner of the email address provided and that you agree to receive the newsletter. No further data is collected, or only on a voluntary basis. We use this data exclusively for sending the requested information and do not pass it on to third parties.
The data entered in the newsletter registration form is processed exclusively on the basis of your consent (Art. 6(1)(a) GDPR). You can revoke your consent to the storage of the data, the email address and its use for sending the newsletter at any time, for example via the "unsubscribe" link in the newsletter. The lawfulness of the data processing operations already carried out remains unaffected by the revocation.
The data you provide to us for the purpose of receiving the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and will be deleted from the newsletter distribution list after you unsubscribe from the newsletter or after the purpose no longer applies. We reserve the right to delete or block email addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest pursuant to Art. 6(1)(f) GDPR. Data stored by us for other purposes remains unaffected by this.
After you unsubscribe from the newsletter distribution list, your email address may be stored by us or the newsletter service provider in a blacklist, insofar as this is necessary to prevent future mailings. The data from the blacklist is only used for this purpose and is not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). Storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.
6. Analysis tools, plugins and tools
Google Analytics
This website uses – exclusively after your consent via the cookie notice – functions of the web analysis service Google Analytics 4. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics enables the website operator to analyze the behavior of website visitors. In doing so, the website operator receives various usage data, such as page views, length of stay, operating systems used and origin of the user. Google Analytics uses technologies that enable the recognition of the user for the purpose of analyzing user behavior (e.g. cookies or device fingerprinting). The information collected by Google about the use of this website is usually transferred to a Google server in the USA and stored there. We use Google Analytics with shortened (anonymized) IP addresses.
This service is used exclusively on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25 (1) TDDDG. Without your consent, Google Analytics is not loaded and no analysis takes place. Consent can be revoked at any time – via "Cookie settings" in the page footer.
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/. More information on how Google Analytics handles user data can be found in Google's privacy policy: https://support.google.com/analytics/answer/6004245?hl=en.
The company is certified under the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF commits to complying with these data protection standards. Further information on this can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/5780.
Google Maps (two-click integration)
This site uses the map service Google Maps. The provider is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland. This service enables us to embed map material on our website.
The map is only loaded when you activate it by clicking on "Load map"; no connection to Google is established when the page is merely opened. Only upon activation is it necessary to store your IP address in order to use the functions of Google Maps. This information is usually transferred to a Google server in the USA and stored there. The provider of this site has no influence on this data transfer. When Google Maps is activated, Google may use Google Fonts for the purpose of uniform display of fonts. When you open Google Maps, your browser loads the required web fonts into your browser cache in order to display texts and fonts correctly.
The activation of the map and the associated data processing are based on your consent pursuant to Art. 6(1)(a) GDPR and § 25 (1) TDDDG. Consent can be revoked at any time.
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://privacy.google.com/businesses/gdprcontrollerterms/ and https://privacy.google.com/businesses/gdprcontrollerterms/sccs/. More information on the handling of user data can be found in Google's privacy policy: https://policies.google.com/privacy?hl=en.
The company is certified under the "EU-US Data Privacy Framework" (DPF). Further information on this can be found at: https://www.dataprivacyframework.gov/participant/5780.
Cloudflare Turnstile
We use "Cloudflare Turnstile" (hereinafter "Turnstile") on this website. The provider is Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA.
Turnstile is used to check whether data entry on this website (e.g. in a contact form) is carried out by a human or by an automated program. For this purpose, Turnstile evaluates technical characteristics (e.g. IP address, browser properties) without interrupting the visitor with tasks and without advertising tracking. Turnstile is only used on pages with a contact form.
The storage and analysis of the data is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in protecting its web offerings from abusive automated spying and from spam. If corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG; consent can be revoked at any time.
Cloudflare is certified under the "EU-US Data Privacy Framework" (DPF). Further information can be found in Cloudflare's privacy policy: https://www.cloudflare.com/privacypolicy/.
HubSpot CRM
To manage contact inquiries, we use the customer relationship management system HubSpot. The provider is HubSpot Ireland Ltd., 1 Sir John Rogerson's Quay, Dublin 2, Ireland (parent company: HubSpot, Inc., USA).
When you submit our contact form, the data you enter (name, email address, message) is transmitted server-side to HubSpot and stored there in order to process and follow up on your inquiry. No HubSpot cookies are set on your end device and no HubSpot code is loaded in your browser.
Processing is carried out on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is necessary for the implementation of pre-contractual measures, and otherwise on the basis of our legitimate interest in the effective processing of inquiries (Art. 6(1)(f) GDPR).
HubSpot is certified under the "EU-US Data Privacy Framework" (DPF). Further information can be found in HubSpot's privacy policy: https://legal.hubspot.com/privacy-policy.
Source: eRecht24