Your Full-Service-Agentur in Berlin, Hamburg and Madrid

1. Privacy Policy

1.1. An overview of data protection

1.1.1. General information

The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.

Data recording on this website

Who is the responsible party for the recording of data on this website (i.e., the “controller”)?

The data processing controller on this website is:

codafish><> GmbH

Am Altenfeldsdeich 56

25371 Seestermühe

Germany

Phone: +49 30 666384800

How do we record your data?

We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form.

Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.

What are the purposes we use your data for?

A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns.

What rights do you have as far as your information is concerned?

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.

Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.

1.1.3. Analysis tools and tools provided by third parties

There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs.
For detailed information about these analysis programs please consult our Data Protection Declaration below.

1.4.3. Data processing outside the EU

No processing of data if the level of data protection is inadequate

The GDPR prohibits the processing of personal data outside the EU if the level of data protection in what are known as “third countries” is inadequate (Articles 44 to 49 GDPR). Most notably, the countries that do not have an adequate level of data protection include the USA.

When it comes to processing data, the United States is even relevant for European companies: that is where global players such as Facebook, Microsoft and Google are based. The admissibility of data processing in the USA was primarily dependent on the Privacy Shield and standard contractual clauses. The other grounds for admissibility play a less significant role.

However, the ECJ ruling of 16 July 2020 resulted in both of these legal bases practically being invalidated (with only a narrow margin of discretion still remaining).

No data protection for EU citizens in the USA

As an effective level of data protection based on the European standard could not be guaranteed, the ECJ ruled that the Privacy Shield is inadmissible and the standard contractual clauses are only admissible as a basis for data transfers to the USA if an effective level of data protection is provided.

With regard to the United States, it was argued that US authorities have inspection rights that EU citizens are unable to oppose. In the landmark case, the claimant cited Section 702 of the Foreign Intelligence Surveillance Act (FISA 702), which permits access to the data of non-US citizens via electronic communication services, even without a court order or any legal protection.

For you, as a website user, this is important: In the ECJ’s opinion, the requirements of the Privacy Shield were no longer being met. The European Commission would be violating the core fundamental rights of EU citizens to a private life, data protection and an effective remedy if it allowed data transfers to the USA in spite of FISA 702 and the US authorities’ other access rights.

Data processing only possible with consent

In the absence of either an adequacy decision in accordance with Article 45(3) or appropriate safeguards in accordance with Article 46,including binding internal data protection rules, a transfer or a set of transfers of personal data to a third country or an international organisation is still permitted if the data subject has given their explicit consent for the proposed data transfer after being informed of the potential risks of such data transfers that could arise for them in the absence of an adequacy decision and without any appropriate safeguards. This information is provided in this chapter. Without using these services, which are explained in the Privacy Policy below, use of our website is only possible to a limited extent.

1.2. Hosting and Content Delivery Networks (CDN)

1.2.1. External Hosting

We are using our own servers for our website.

1.2.2. Cloudflare

We use the “Cloudflare” service provided by Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA. (hereinafter referred to as “Cloudflare”).

Cloudflare offers a content delivery network with DNS that is available worldwide. As a result, the information transfer that occurs between your browser and our website is technically routed via Cloudflare’s network. This enables Cloudflare to analyze data transactions between your browser and our website and to work as a filter between our servers and potentially malicious data traffic from the Internet. In this context, Cloudflare may also use cookies or other technologies deployed to recognize Internet users, which shall, however, only be used for the herein described purpose.

The use of Cloudflare is based on our legitimate interest in a provision of our website offerings that is as error free and secure as possible (Art. 6 Sect. 1 lit. f GDPR).

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:

https://www.cloudflare.com/privacypolicy/.

For more information on Cloudflare’s security precautions and data privacy policies, please follow this link: https://www.cloudflare.com/privacypolicy/.

Execution of a contract data processing agreement

In order to guarantee processing in compliance with data protection regulations, we have concluded an order processing contract with Cloudflare.

1.3. General information and mandatory information

1.3.1. Storage duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion 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., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

1.3.2. Information on data transfer to the USA and other non-EU countries

Among other things, tools of companies domiciled in the United States or other from a data protection perspective non-secure non-EU countries, are integrated into our website. If these tools are active, your personal data may potentially be transferred to these non-EU countries and may be processed there. We must point out that in these countries, a data protection level that is comparable to that in the EU cannot be guaranteed. For instance, U.S. enterprises are under a mandate to release personal data to the security agencies and you as the data subject do not have any litigation options to defend yourself in court. Hence, it cannot be ruled out that U.S. agencies (e.g., the Secret Service) may process, analyze, and permanently archive your personal data for surveillance purposes. We have no control over these processing activities.

1.3.3. Revocation of your consent to the processing of data

A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation.

1.3.4. Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)

IN THE EVENT THAT DATA ARE PROCESSED ON THE BASIS OF ART. 6 SECT. 1 LIT. E OR F GDPR, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA BASED ON GROUNDS ARISING FROM YOUR UNIQUE SITUATION. THIS ALSO APPLIES TO ANY PROFILING BASED ON THESE PROVISIONS. TO DETERMINE THE LEGAL BASIS, ON WHICH ANY PROCESSING OF DATA IS BASED, PLEASE CONSULT THIS DATA PROTECTION DECLARATION. IF YOU LOG AN OBJECTION, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA, UNLESS WE ARE IN A POSITION TO PRESENT COMPELLING PROTECTION WORTHY GROUNDS FOR THE PROCESSING OF YOUR DATA, THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS OR IF THE PURPOSE OF THE PROCESSING IS THE CLAIMING, EXERCISING OR DEFENCE OF LEGAL ENTITLEMENTS (OBJECTION PURSUANT TO ART. 21 SECT. 1 GDPR).

IF YOUR PERSONAL DATA IS BEING PROCESSED IN ORDER TO ENGAGE IN DIRECT ADVERTISING, YOU HAVE THE RIGHT TO AT ANY TIME OBJECT TO THE PROCESSING OF YOUR AFFECTED PERSONAL DATA FOR THE PURPOSES OF SUCH ADVERTISING. THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS AFFILIATED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR DIRECT ADVERTISING PURPOSES (OBJECTION PURSUANT TO ART. 21 SECT. 2 GDPR).

1.3.5. Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses.

1.3.6. Right to data portability

You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible.

1.3.7. SSL and/or TLS encryption

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line.

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties.

1.3.8. Information about, rectification and eradication of data

Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time.

1.3.9. Right to demand processing restrictions

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases:

  • In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data.
  • If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data.
  • If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication.
  • – If you have raised an objection pursuant to Art. 21 Sect. 1 GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data.

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU.

1.3.10. Rejection of unsolicited e-mails

We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in our Site Notice to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages.

1.4. Recording of data on this website

1.4.1. Cookies

Our websites and pages use what the industry refers to as “cookies.” Cookies are small text files that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser.

In some cases, it is possible that third-party cookies are stored on your device once you enter our site (third-7 / 19 party cookies). These cookies enable you or us to take advantage of certain services offered by the third party (e.g., cookies for the processing of payment services).

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of the cookies (e.g., the shopping cart function or the display of videos). The purpose of other cookies may be the analysis of user patterns or the display of promotional messages.

Cookies, which are required for the performance of electronic communication transactions (required cookies) or for the provision of certain functions you want to use (functional cookies, e.g., for the shopping cart function) or those that are necessary for the optimization of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6 Sect. 1 lit. f GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of cookies to ensure the technically error free and optimized provision of the operator’s services. If your consent to the storage of the cookies has been requested, the respective cookies are stored exclusively on the basis of the consent obtained (Art. 6 Sect. 1 lit. a GDPR); this consent may be revoked at any time.

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited.

In the event that third-party cookies are used or if cookies are used for analytical purposes, we will separately notify you in conjunction with this Data Protection Policy and, if applicable, ask for your consent.

1.4.2. Cookie Consent with Borlabs Cookie

Our website uses the Borlabs cookie consent technology to obtain your consent to the storage of certain cookies in your browser and for their data privacy protection compliant documentation The provider of this technology is Borlabs – Benjamin A. Bornschein, Rübenkamp 32, 22305 Hamburg, Germany (hereinafter referred to as Borlabs).

Whenever you visit our website, a Borlabs cookie will be stored in your browser, which archives any declarations or revocations of consent you have entered. These data are not shared with the provider of the Borlabs technology.

The recorded data shall remain archived until you ask us to eradicate them, delete the Borlabs cookie on your own or the purpose of storing the data no longer exists. This shall be without prejudice to any retention obligations mandated by law. To review the details of Borlabs’ data processing policies, please visit https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/

We use the Borlabs cookie consent technology to obtain the declarations of consent mandated by law for the use of cookies. The legal basis for the use of such cookies is Art. 6 Sect. 1 Sentence 1 lit. c GDPR.

1.4.3. Server log files

The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises:

  • The type and version of browser used
  • The used operating system
  • Referrer URL
  • The hostname of the accessing computer
  • The time of the server inquiry
  • The IP address

This data is not merged with other data sources.
This data is recorded on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.

1.4.4. Contact form

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent.

The processing of these data is based on Art. 6 para. 1 lit. b GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6 Para. 1 lit. f GDPR) or on your agreement (Art. 6 Para. 1 lit. a GDPR) if this has been requested.

The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions, in particular retention periods.

1.4.5. Request by e-mail, telephone, or fax

If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent.

These data are processed on the basis of Art. 6 Sect. 1 lit. b GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6 Sect. 1 lit. f GDPR) or on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR) if it has been obtained.

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.

1.4.6. Appointment scheduling via Zoho Bookings

You have the option to make appointments with us on our website. We use the “Zoho Bookings” tool for making appointments. The provider is Zoho Corporation GmbH, c/o Mütze Korsch Rechtsanwaltsgesellschaft mbH, Trinkausstraße 7, 40213 Düsseldorf, Germany (hereinafter “Zoho CRM”).

To make an appointment, you enter the data requested and your preferred date into the form provided. The data entered is used for preparing for, carrying out and, if necessary, following up on the appointment. The details of the appointment are stored on Zoho CRM’s servers for us. You can find details on Zoho CRM’s features here: https://www.zoho.com/de/crm/help/getting-started/key-features.html.

We retain the data you have entered until you ask us to erase it or you withdraw your consent to its storage, or until the purpose of the data storage ceases to apply. Mandatory legal provisions — particularly retention periods — remain unaffected.

The legal basis for the data processing is Article 6(1)(f) GDPR. The website owner has a legitimate interest in making scheduling appointments with customers and prospective customers as simple as possible. Where consent is requested, the legal basis is Article 6(1)(a) GDPR; consent can be withdrawn at any time.

Data transfer to third countries outside the European Union is based on the standard contractual clauses of the European Commission. You can find further details here: https://www.zoho.com/privacy/dpa/DPA_zoho_com.pdf.
https://www.zoho.com/privacy/dpa/DPA_zoho_com.pdf.

You can find further details in Zoho CRM’s privacy policy:
https://www.zoho.com/privacy.html and https://www.zoho.com/gdpr.html.

Execution of a contract data processing agreement

We have concluded a data processing agreement with Zoho CRM. It is an agreement as required under data protection law, which guarantees that Zoho CRM will only process our website visitors’ personal data as instructed by us and in accordance with the GDPR.

1.4.7. Communication via WhatsApp

For communication with our customers and other third parties, one of the services we use is the instant messaging service WhatsApp. The provider is WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.

The communication is encrypted end-to-end (peer-to-peer), which prevents WhatsApp or other third parties from gaining access to the communication content. However, WhatsApp does gain access to metadata created during the communication process (for example, sender, recipient, and time). We would also like to point out that WhatsApp has stated that it shares personal data of its users with its U.S.-based parent company Facebook. Further details on data processing can be found in the WhatsApp privacy policy at: https://www.whatsapp.com/legal/#privacy-policy.

The use of WhatsApp is based on our legitimate interest in communicating as quickly and effectively as possible with customers, interested parties and other business and contractual partners (Art. 6(1)(f) GDPR). If a corresponding consent has been requested, data processing is carried out exclusively on the basis of the consent; this consent may be revoked at any time with effect for the future.

The communication content exchanged between and on WhatsApp remains with us until you request us to delete it, revoke your consent to storage or the purpose for which the data is stored ceases to apply (e.g. after your request has been processed). Mandatory legal provisions, in particular retention periods, remain unaffected.

We use WhatsApp in the “WhatsApp Business” variant.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:
https://www.whatsapp.com/legal/business-data-transfer-addendum?lang=en.

1.4.8. Zoho CRM

We use Zoho CRM on this website. Provider is Zoho Corporation GmbH, c/o Mütze Korsch Rechtsanwaltsgesellschaft mbH, Trinkausstraße 7, 40213 Düsseldorf, Germany (hereinafter “Zoho CRM”).

Zoho CRM enables us, in particular, to manage existing and potential customers and customer contacts and to organize sales and communication processes. Using the CRM system also enables us to analyze and optimize our customer-related processes. The customer data is stored on Zoho CRM’s servers. Details of Zoho CRM’s functions can be found here:
https://www.zoho.com/de/crm/help/getting-started/kev-functions.html.

The use of Zoho CRM is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest the most efficient customer management and customer communication. If consent has been requested, processing will be performed exclusively on the basis of Art. 6 para. 1 letter a GDPR; consent may be revoked at any time.

The data transfer to third countries outside the European Union is based on the standard contractual clauses of the EU Commission. Details can be found here: https://www.zoho.com/privacy/dpa/DPA_zoho_com.pdf.

Details can be found in the Zoho CRM privacy policy: https://www.zoho.com/privacy.html y https://www.zoho.com/gdpr.html.

Execution of a contract data processing agreement

We have concluded an order processing contract with Zoho CRM. This is a contract that is required by data protection law and ensures that Zoho CRM processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

1.4.9. ProvenExpert

We have included evaluation seals from ProvenExpert on this website. The provider is Expert Systems AG,
Quedlinburger Str. 1, 10589 Berlín, https://www.provenexpert.com.

The ProvenExpert seal enables us to display on our website customer reviews that have been submitted to ProvenExpert about our company. When you visit our website, a connection to ProvenExpert is established so that ProvenExpert can determine that you have visited our website. Furthermore, ProvenExpert records your language settings to display the seal in the chosen language.

The use of ProvenExpert is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the most comprehensible presentation of customer reviews. If the corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR; consent may be revoked at any time.

1.5. Analysis tools and advertising

1.5.1. Google Tag Manager

We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States.

The Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and administration of various tools on his website. If the relevant consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR; consent may be revoked at any time.

1.5.2. Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. Google may consolidate these data in a profile that is allocated to the respective user or the user’s device.

Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the user behavior patterns (e.g., cookies or device fingerprinting). The website use information recorded by Google is, as a rule transferred to a Google server in the United States, where it is stored.

This analysis tool is used on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator of this website has a legitimate interest in the analysis of user patterns to optimize both, the services offered online and the operator’s advertising activities. If a corresponding agreement has been requested (e.g., an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; consent may be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.

IP anonymization

On this website, we have activated the IP anonymization function. As a result, your IP address will be abbreviated by Google within the member states of the European Union or in other states that have ratified the Convention on the European Economic Area prior to its transmission to the United States. The full IP address will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator of this website, Google shall use this information to analyze your use of this website to generate reports on website activities and to render other services to the operator of this website that are related to the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.

Browser plug-in

You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link:
https://tools.google.com/dlpage/gaoptout?hl=en.

For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.
https://support.google.com/analytics/answer/6004245?hl=en.

Contract data processing

We have executed a contract data processing agreement with Google and are implementing the stringent provisions of the German data protection agencies to the fullest when using Google Analytics.

Demographic parameters provided by Google Analytics

This website uses the “demographic characteristics” function of Google Analytics, to be able to display to the website visitor compatible ads within the Google advertising network. This allows reports to be created that contain information about the age, gender, and interests of the website visitors. The sources of this information are interest-related advertising by Google as well as visitor data obtained from third-party providers. This data cannot be allocated to a specific individual. You have the option to deactivate this function at any time by making pertinent settings changes for advertising in your Google account or you can generally prohibit the recording of your data by Google Analytics as explained in section “Objection to the recording of data”.

Duration of storage

Data on the user or incident level stored by Google linked to cookies, user IDs or advertising IDs (e.g.,DoubleClick cookies, Android advertising ID) will be anonymized or deleted after 14 month. For details, please click the following link: https://support.google.com/analytics/answer/7667196?hl=en

1.5.3. Google Ads

The website operator uses Google Ads. Google Ads is an online promotional program of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Ads enables us to display ads in the Google search engine or on third-party websites, if the user enters certain search terms into Google (keyword targeting). It is also possible to place targeted ads based on the user data Google has in its possession (e.g., location data and interests; target group targeting). As the website operator, we can analyze these data quantitatively, for instance by analyzing which search terms resulted in the display of our ads and how many ads led to respective clicks.

The use of Google Ads is based on Art. 6 Sect. 1 lit. et seq. GDPR. The website operator has a legitimate interest in marketing the operator’s services and products as effectively as possible.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://policies.google.com/privacy/frameworks and https://privacy.google.com/businesses/controllerterms/mccs/.

1.5.4. Google Conversion-Tracking

This website uses Google Conversion Tracking. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

With the assistance of Google Conversion Tracking, we are in a position to recognize whether the user has completed certain actions. For instance, we can analyze the how frequently which buttons on our website have been clicked and which products are reviewed or purchased with particular frequency. The purpose of this information is to compile conversion statistics. We learn how many users have clicked on our ads and which actions they have completed. We do not receive any information that would allow us to personally identify the users. Google as such uses cookies or comparable recognition technologies for identification purposes.

We use Google Conversion Tracking on the basis of Art. 6 Sect. 1 lit. et seq. GDPR. The operator of the website has a legitimate interest in the analysis of the user patterns with the aim of optimizing both, the operator’s web presentation and advertising. If a respective declaration of consent was requested (e.g.,concerning the storage of cookies), processing shall occur exclusively on the basis of Art. 6 Sect. 1 lit. GDPR; the given consent may be revoked at any time.

For more information about Google Conversion Tracking, please review Google’s data protection policy at: https://policies.google.com/privacy?hl=en

1.5.5. Facebook Pixel

To measure conversion rates, this website uses the visitor activity pixel of Facebook. The provider of this service is Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. According to Facebook’s statement the collected data will be transferred to the USA and other third-party countries too.

This tool allows the tracking of page visitors after they have been linked to the website of the provider after clicking on a Facebook ad. This makes it possible to analyze the effectiveness of Facebook ads for statistical and market research purposes and to optimize future advertising campaigns.

For us as the operators of this website, the collected data is anonymous. We are not in a position to arrive at any conclusions as to the identity of users. However, Facebook archives the information and processes it, so that it is possible to make a connection to the respective user profile and Facebook is in a position to use the data for its own promotional purposes in compliance with the Facebook Data Usage Policy. This enables Facebook to display ads on Facebook pages as well as in locations outside of Facebook. We as the operator of this website have no control over the use of such data.

The use of Facebook Pixel is based on Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in effective advertising campaigns, which also include social media. If a corresponding agreement has been requested (e.g., an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here:https://www.facebook.com/legal/EU_data_transfer_addendum and
https://de-de.facebook.com/help/566994660333381.

Insofar as personal data is collected on our website with the help of the tool described here and forwarded to Facebook, we and Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are jointly responsible for this data processing (Art. 26 DSGVO). The joint responsibility is limited exclusively to the collection of the data and its forwarding to Facebook. The processing by Facebook that takes place after the onward transfer is not part of the joint responsibility. The obligations incumbent on us jointly have been set out in a joint processing agreement. The wording of the agreement can be found under: The wording of the agreement can be found under:

https://www.facebook.com/legal/controller_addendum. According to this agreement, we are responsible for providing the privacy information when using the Facebook tool and for the privacy-secure implementation of the tool on our website. Facebook is responsible for the data security of Facebook products. You can assert data subject rights (e.g., requests for information) regarding data processed by Facebook directly with Facebook. If you assert the data subject rights with us, we are obliged to forward them to Facebook.

In Facebook’s Data Privacy Policies, you will find additional information about the protection of your privacy at: https://www.facebook.com/about/privacy/.

You also have the option to deactivate the remarketing function “Custom Audiences” in the ad settings section under: https://www.facebook.com/ads/preferences/?entry_product=ad settings_screen. To do this, you first have to log into Facebook.

If you do not have a Facebook account, you can deactivate any user-based advertising by Facebook on the website of the European Interactive Digital Advertising Alliance: http://www.youronlinechoices.com/de/praferenzmanagement/.

1.5.6. LinkedIn Insight Tag

This website uses the Insight tag from LinkedIn. This service is provided by LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

Data processing by LinkedIn Insight tag

We use the LinkedIn Insight tag to obtain information about visitors to our website. Once a website visitor is registered with LinkedIn, we can analyze the key occupational data (e.g., career level, company size, country, location, industry, job title) of our website visitors to help us better target our site to the relevant audience. We can also use LinkedIn Insight tags to measure whether visitors to our websites make a purchase or perform other actions (conversion measurement). Conversion measurement can also be carried out across devices (e.g. from PC to tablet). LinkedIn Insight Tag also features a retargeting function that allows us to display targeted advertising to visitors to our website outside of the website. According to LinkedIn, no identification of the advertising addressee takes place.

LinkedIn itself also collects log files (URL, referrer URL, IP address, device and browser characteristics and time of access). The IP addresses are shortened or (if they are used to reach LinkedIn members across devices) hashed (pseudonymized). The direct identifiers of LinkedIn members are deleted by LinkedIn after seven days. The remaining pseudonymized data will then be deleted within 180 days.

The data collected by LinkedIn cannot be assigned by us as a website operator to specific individuals. LinkedIn will store the personal data collected from website visitors on its servers in the USA and use it for its own promotional activities. For details, please see LinkedIn’s privacy policy at : https://www.linkedin.com/legal/privacy-policy#choices-oblig.

Legal basis

The use of LinkedIn Insight is based on Art. 6(1)(f) GDPR. The website operator has a legitimate interest in effective advertising measures, including social media. If a corresponding agreement has been requested (e.g., an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.linkedin.com/legal/l/dpa y https://www.linkedin.com/legal/l/eu-sccs.

Objection to the use of LinkedIn Insight Tag

You can object to LinkedIn’s analysis of user behavior and targeted advertising at the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

In addition, LinkedIn members can control the use of their personal information for promotional purposes in the account settings. To prevent LinkedIn from linking information collected on our site to your LinkedIn account, you must log out of your LinkedIn account before you visit our site.

Execution of a contract data processing agreement

We have entered into a contract data processing agreement with LinkedIn.

1.5.7. Zoho Sales IQ

When you visit our website, anonymised usage data is collected via the ZOHO service SalesIQ (https://zoho.eu/salesiq). SalesIQ uses what are known as “cookies”, which enable analysis of our website. You can disable this “tracking” via the corresponding settings in your browser. We store your data exclusively for statistical purposes. In accordance with legislation, IP addresses are shortened by the last few digits to guarantee anonymity.

1.5.8. Zoho Page Sense

When you visit our website, anonymised usage data is collected via the ZOHO service PageSense (https://zoho.eu/pagesense). PageSense merely records visits to and clicks on our website, completely anonymously. I It does not enable individual visitors to be identified. PageSense merely allows us to assess general use of our website in the form of a heat map and, as a result of this, it allows us to show you key content at the right place on individual web pages. No usage data or personal data is collected or stored.

1.6. Newsletter

1.6.1. Newsletter data

If you would like to subscribe to the newsletter offered on this website, we will need from you an e-mail address as well as information that allow us to verify that you are the owner of the e-mail address provided, and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis. We shall use such data only for the sending of the requested information and shall not share such data with any third parties.

The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR). You may revoke the consent you have given to the archiving of data, the e-mail address and the use of this information for the sending of the newsletter at any time, for instance by clicking on the “Unsubscribe” link in the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date.

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter or after the purpose has ceased to apply. We reserve the right to delete or block e-mail addresses from our newsletter distribution list at our own discretion within the scope of our legitimate interest in accordance with Art. 6(1)(f) GDPR.

After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used only for this purpose and 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 para. 1 lit. f GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.

1.6.2. Zoho Marketing Hub

This website uses Zoho Marketing Hub to send out newsletters. Provider is Zoho Corporation GmbH., c/o Mütze Korsch Rechtsanwaltsgesellschaft mbH, Trinkausstraße 7, 40213 Düsseldor Germany (hereinafter “Zoho Marketing Hub”).

Zoho Marketing Hub is a service that can be used, in particular, to organize and analyze the sending of newsletters. The information you enter to subscribe to the newsletter is stored on Zoho Marketing Hub’s servers.

Data analysis by Zoho Marketing Hub

Zoho Marketing Hub allows us to analyze our newsletter campaigns. For example, we can see whether a newsletter message has been opened and which links have been clicked on, if any. In this way we can determine which links have been clicked on most often.

We can also see if certain previously defined actions were performed after opening/clicking (conversion rate). For example, we can see whether you have made a purchase after clicking on the newsletter. If you do not want to receive analyses of Zoho Marketing Hub, you must unsubscribe from the newsletter. We provide a link to this in every newsletter message. Zoho Marketing Hub also allows us to classify the recipients of the newsletter into different categories (“clustering”). The newsletter recipients can be classified, for example, by age, gender, or place of residence. In this way, the newsletter can be better adapted to the respective target groups. If you do not wish to receive analyses of Zoho Marketing Hub, you must unsubscribe from the newsletter. You will find a link to this in every newsletter message.

Detailed information about the characteristics of Zoho Marketing Hub can be found at the following link: https://www.zoho.com/campaigns/features.html.

The Zoho Marketing Hub’s privacy policy can be found at: https://www.zoho.com/privacy.html and https://www.zoho.com/gdpr.html.

Legal basis

The data processing is based on your consent (Art. 6 para. 1 lit. a GDPR). You can revoke this consent at any time with effect for the future.

The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here:
https://www.zoho.com/privacy/dpa/DPA_zoho_com.pdf.

Duration of storage

The data that you provide us with for the purpose of subscribing to 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 or deleted after the newsletter has been cancelled. We reserve the right to delete email addresses within the scope of our legitimate interest under Art. 6 para. 1 lit. f GDPR. Data stored by us for other purposes remain unaffected.

After you have been removed from the newsletter distribution list, your email address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist will only be used for this purpose and will not be 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 para. 1 lit. f GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.

Execution of a contract data processing agreement

We have concluded an order processing contract with Zoho Marketing Hub. Se trata de un contrato requerido por las leyes de protección de datos y garantiza que Zoho Campaigns trata los datos personales de las personas que visitan nuestro sitio web según las instrucciones y en cumplimiento con el RGPD.

1.7. Plug-ins and Tools

1.7.1. Font Awesome

This page uses Font Awesome for the uniform representation of fonts and symbols. Provider is Fonticons, Inc. 6 Porter Road Apartment 3R, Cambridge, Massachusetts, USA.

When you call up a page, your browser loads the required fonts into its browser cache to display texts, fonts, and symbols correctly. For this purpose, the browser you use must connect to the servers of Font Awesome. This allows Font Awesome to know that your IP address has been used to access this website. The use of Font Awesome is based on Art. 6(1)(f) GDPR. We have a legitimate interest in the uniform presentation of the typeface on our website. If consent has been requested (e.g., consent to the storage of cookies), processing will be carried out exclusively on the basis of Art. 6(1)(a) GDPR; consent may be revoked at any time.

If your browser does not support Font Awesome, a standard font from your computer will be used.

Further information about Font Awesome can be found in the Font Awesome privacy policy at: https://fontawesome.com/privacy.

1.8. eCommerce and payment service providers

1.8.1. Processing of data (customer and contract data)

We collect, process, and use personal data only to the extent necessary for the establishment, content organization or change of the legal relationship (data inventory). These actions are taken on the basis of Art. 6 Sect. 1 lit. b GDPR, which permits the processing of data for the fulfilment of a contract or pre-contractual actions. We collect, process, and use personal data concerning the use of this website (usage data) only to the extent that this is necessary to make it possible for users to utilize the services and to bill for them.
The collected customer data shall be eradicated upon completion of the order or the termination of the business relationship. This shall be without prejudice to any statutory retention mandates.

1.8.2. Data transfer when concluding a contract for services and digital content

We only transfer personal data to third parties if necessary for contract processing, e.g. to the bank commissioned with handling payments. You also transfer personal data to third parties when you pay our service invoices by bank transfer and our bank therefore receives data from you.

No further data is transferred, or it is only transferred if you have given your explicit consent to such transfer. Your data is not shared with third parties without your explicit consent, e.g. for marketing purposes.

The basis for the data processing is Article 6(1)(b) GDPR, which permits data processing for the performance of a contract or steps prior to entering into a contract.

1.8.3. Payment services

We integrate payment services from third parties into our website. When you make a purchase from us, your payment details (e.g. name, payment amount, account details, credit card number) are processed by the payment service provider for the purpose of handling the payment. The relevant provider’s applicable contract and data protection provisions apply for these transactions. Payment service providers are used on the basis of Article 6(1)(b) GDPR (contract processing) and in the interests of the smoothest, easiest and most secure payment process possible (Article 6(1)(f) GDPR). When your consent is requested for certain actions, Article 6(1)(a) GDPR is the legal basis of the data processing; consent can be withdrawn at any time with future effect.

We use the following payment services/payment service providers on this website:

PayPal

The provider of this payment service is PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg (hereinafter “PayPal”).

Data transfer to third countries outside the European Union is based on the standard contractual clauses of the European Commission. You can find further details here:
https://www.paypal.com/de/webapps/mpp/ua/pocpsa-full.

Encontrará más información sobre la política de privacidad de PayPal en: https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

Stripe

The provider for customers within the EU is Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, Ireland (hereinafter “Stripe”).

Data transfer to third countries outside the European Union is based on the standard contractual clauses of the European Commission.

You can find further details here:

https://stripe.com/de/privacy

and: https://stripe.com/de/guides/general-data-protection-regulation.

https://stripe.com/de/guides/general-data-protection-regulation.

You can access further details in Stripe’s privacy policy via the following link: https://stripe.com/de/privacy.

1.9. Online-based Audio and Video Conferences (Conference tools)

1.9.1. Data processing

We use online conference tools, among other things, for communication with our customers. The tools we use are listed in detail below. If you communicate with us by video or audio conference using the Internet, your personal data will be collected and processed by the provider of the respective conference tool and by us. The conferencing tools collect all information that you provide/access to use the tools (email address and/or your phone number). Furthermore, the conference tools process the duration of the conference, start and end (time) of participation in the conference, number of participants and other “context information” related to the communication process (metadata).

Furthermore, the provider of the tool processes all the technical data required for the processing of the online communication. This includes, in particular, IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or loudspeaker and the type of connection.

Should content be exchanged, uploaded, or otherwise made available within the tool, it is also stored on the servers of the tool provider. Such content includes, but is not limited to, cloud recordings, chat/ instant messages, voicemail uploaded photos and videos, files, whiteboards, and other information shared while using the service.

Please note that we do not have complete influence on the data processing procedures of the tools used. Our possibilities are largely determined by the corporate policy of the respective provider. Further information on data processing by the conference tools can be found in the data protection declarations of the tools used, and which we have listed below this text.

Purpose and legal bases

The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6 para. 1 sentence 1 lit. b GDPR). Furthermore, the use of the tools serves to generally simplify and accelerate communication with us or our company (legitimate interest in the meaning of Art. 6 para. 1 lit. f GDPR). Insofar as consent has been requested, the tools in question will be used on the basis of this consent; the consent may be revoked at any time with effect from that date.

Duration of storage

Data collected directly by us via the video and conference tools will be deleted from our systems immediately after you request us to delete it, revoke your consent to storage, or the reason for storing the data no longer applies. Stored cookies remain on your end device until you delete them. Mandatory legal retention periods remain unaffected.

We have no influence on the duration of storage of your data that is stored by the operators of the conference tools for their own purposes. For details, please directly contact the operators of the conference tools.

Conference tools used

We employ the following conference tools:

1.9.2. Microsoft Teams

We use Microsoft Teams. The provider is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. For details on data processing, please refer to the Microsoft Teams privacy policy: : https://privacy.microsoft.com/en-us/privacystatement.

Execution of a contract data processing agreement

We have entered into a contract data processing agreement with the provider of Microsoft Teams and implement the strict provisions of the German data protection agencies to the fullest when using Microsoft Teams.

1.9.3. Zoho Meeting

We use Zoho Meeting. The provider is Zoho Corporation c/o Mütze Korsch Rechtsanwaltsgesellschaft mbH, Trinkausstraße 7, 40213 Düsseldorf, Germany (hereinafter “Zoho CRM”).

The use of Zoho Meeting is based on Article 6(1)(f) GDPR. The website owner has a legitimate interest in communicating with customers as efficiently as possible. Where consent is requested, the legal basis is Article 6(1)(a) GDPR; consent can be withdrawn at any time.

Data transfer to third countries outside the European Union is based on the standard contractual clauses of the European Commission. You can find further details here: https://www.zoho.com/privacy/dpa/DPA_zoho_com.pdf.

You can find further details in Zoho CRM’s privacy policy: https://www.zoho.com/privacy.html and https://www.zoho.com/gdpr.html.

Conclusion of a data processing agreement

We have concluded a data processing agreement with the provider of Zoho Meeting and implement in full the strict provisions laid out by the German data protection authorities when using Zoho Meeting.

1.10. Cookies

2. Privacy Policy for our Clients

In this Privacy Policy, we would like to give you information on how we process the data that you provide to us in order to conduct our pre-contractual relations and perform the contract with you, and on your rights in connection with this data processing.

2.1. Controller

The Data Controller is

codafish ><> GmbH
Am Altenfeldsdeich 56
25371 Seestermühe

Germany

Phone: +49 30 666384800

Email: hello@codafish.net.

2.2. Purposes of processing and legal basis

Your personal data is processed in accordance with the provisions of the General Data Protection Regulation (GDPR), the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG) and other relevant data protection regulations. The processing and use of specific data depends on the agreed service. You can find further details and information on the purposes of the processing in our quotations, contract documentation, forms, declarations of consent and the other information/documents provided to you.

2.2.1. Consent (Article 6(1)(a) GDPR)

If you have given your consent for the processing of personal data, such consent forms the legal basis for the processing specified therein. You can withdraw your consent at any time with future effect.

2.2.2. Compliance with contractual obligations (Article 6(1)(b) GDPR)

We process your personal data in order to perform our contracts with you, particularly our contracts for work and services. Your personal data is also processed in order to take measures and carry out activities within the context of pre-contractual relations.

2.2.3. Compliance with legal obligations (Article 6(1)(c) GDPR)

We process your personal data when this is necessary to comply with legal obligations (e.g. trade and tax laws). We also process your data if necessary to comply with monitoring and notification obligations under tax law, for archiving data for the purposes of data protection and data security, and for auditing by the tax office (Finanzamt) and other authorities. It may also be necessary to disclose personal data within the course of official or judicial procedures for the purposes of gathering evidence, criminal prosecution or enforcing civil law claims.

2.2.4. Our legitimate interests, or those of third parties (Article 6(1)(f) GDPR)

We may also use your personal data for the purpose of our legitimate interests or those of third parties, based on a balance of interests. For example, this may be for the following purposes:

  • For marketing or market research, if you have not objected to the use of your data;
  • For obtaining information and exchanging data with credit reference agencies, if your contract affects our risk-bearing capacity
  • For establishing legal claims and for defence in legal disputes.

2.3. Categories of personal data that we process

We process basic data concerning our contract partners and contact persons and the business relationship with our contract partners, which we refer to collectively as “master data”. In particular, this includes:

  1. a. All information that is provided to us when establishing the business relationship and/or that we have requested from our contract partner or a contact person:
  • Personal details (name, date of birth, place of birth, nationality, marital status, profession/industry and similar data);
  • Contact details (address, email address, telephone number and similar data);
  1. b. The data that we have recorded in connection with the establishment of the business relationship (particularly the details of the contracts concluded);

We also process personal data that arises in the course of the business relationship that is more than a simple amendment to the master data and that we refer to as “process data”. I In particular, this includes:

  1. a. Information regarding the services received by our contract partner based on the contracts concluded;
  2. b. Information regarding the services provided by us based on the contracts concluded;
  3. c. Information that our contract partner or a contact person provides in the course of the business relationship, either independently or when requested by us;
  4. d. Personal data that we receive from our contract partner, a contact person or a third party in another way in the course of our business relationship;

We may also store third-party personal data in the master data and process data to the extent permitted by law. For example, this includes data on our contract partner’s financial situation, if this is required in order to assess financial risks such as the risk of payment default.

We also process personal data from public sources (e.g. the Internet, media, press, register of companies and associations (Handels- und Vereinsregister), population register (Melderegister)). If necessary in order to provide our service, we process personal data that we have lawfully obtained from third parties (e.g. mailing list providers, credit reference agencies).

2.4. Who obtains your data?

We pass your personal data on to the departments within our company that need this data in order to comply with contractual and legal obligations and/or in order to exercise our legitimate interests.

The following parties may also obtain your data:

  • Processors that we use (Article 28 GDPR), service providers for supporting activities and other controllers as defined in the GDPR, particularly in the areas of IT services, logistics, courier services, printing services, external data centres, support with/maintenance of IT applications, archiving, document processing, accounting and controlling, data destruction, purchasing/procurement, customer administration, lettershops, marketing, telephone services, website management, tax consulting, auditing services, banks;
  • Public bodies and institutions, if we have a legal or official obligation requiring access, notification or the disclosure of data or if providing data is in the public interest;
  • Bodies and institutions based on our legitimate interest or the legitimate interests of third parties (e.g. authorities, credit reference agencies, debt collection agencies, law firms, courts, consultants and supervisory authorities);
  • Other bodies to which you have given us your consent to transmit data.

2.5. Transfer of your data to a third country or an international organisation

Data is not processed outside the EU or the EEC.

2.6. How long do we store your data for?

Where necessary, we process your personal data for the duration of our business relationship; this also includes the initiation and execution of a contract. Besides this, we are subject to various retention and documentation obligations under laws such as the German Commercial Code (Handelsgesetzbuch, HGB) and the German Fiscal Code (Abgabenordnung, AO). The retention and documentation periods laid out therein are up to 10 years from the end of the business relationship and/or the pre-contractual legal relationship. Finally, the storage period is also determined based on the statutory periods of limitation that — in accordance with Articles 195 et seqq. of the German Civil Code (Bürgerliches Gesetzbuch, BGB), for example — are usually three years but may even be up to thirty years in certain cases.

2.7. Automated decision-making (including profiling)?

We deal with you and your enquiries personally and, as a rule, we do not make use of any automated decision-making procedures or profiling in accordance with Article 22 GDPR.

2.8. Your data protection rights

You have the right of access in accordance with Article 15 GDPR, the right to rectification in accordance with Article 16 GDPR, the right to erasure in accordance with Article 17 GDPR, the right to restriction of processing in accordance with Article 18 GDPR and the right to data portability in accordance with Article 20 GDPR. In addition, you have the right to lodge a complaint with a data protection authority in accordance with Article 77 GDPR (see Section 10).

2.9. Information on your right to object in accordance with Article 21 GDPR

You have the right to object to processing of your data that is being carried out in accordance with Article 6(1)(f) GDPR (data processing based on a balance of interests) at any time if there are grounds for this relating to your particular situation. If you do object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or the processing is for the purpose of the establishment, exercise or defence of legal claims.

We may also process your personal data for direct marketing purposes. If you do not wish to receive any marketing, you have the right to object to this at any time. We will then comply with this objection in the future.

We will no longer process your data for direct marketing purposes if you object to processing for these purposes. The objection can be sent to our address provided above or the email address also stated above in any form.

2.10. Right to lodge a complaint

You have the right to lodge a complaint regarding the processing of personal data by us with the competent supervisory authority for data protection. The competent supervisory authority is the one where our company is based:

Unabhängiges Landeszentrum für Datenschutz Schleswig-Holstein [Centro Independiente para la Protección de la Protección de la seguridad]Schleswig-Holstein (Alemania)]

PO Box 71 16, 24171 Kiel (Germany)

Telephone: +44 31 988-1200
Fax: +44 31 988 -1223

mail@datenschutzzentrum.de

2.11. Privacy Policy for Visitors to our Website

Please also read our Privacy Policy for the use of our website.

Privacy Policy for Suppliers and Business Partners

In this Privacy Policy, we would like to give you information on how we process the data that you provide to us in order to conduct our pre-contractual relations and perform the contract with you, and on your rights in connection with this data processing.

3.1. Controller

The Data Controller is

codafish ><> GmbH
Am Altenfeldsdeich 56
25371 Seestermühe

Germany

Phone: +49 30 666384800

Email: hello@codafish.net.

3.2. Purposes of processing and legal basis

Your personal data is processed in accordance with the provisions of the General Data Protection Regulation (GDPR), the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG) and other relevant data protection regulations. The processing and use of specific data depends on the agreed service. You can find further details and information on the purposes of the processing in our quotations, contract documentation, forms, declarations of consent and the other information/documents provided to you.

3.2.1. Consent (Article 6(1)(a) GDPR)

If you have given your consent for the processing of personal data, such consent forms the legal basis for the processing specified therein. You can withdraw your consent at any time with future effect.

3.2.2. Compliance with contractual obligations (Article 6(1)(b) GDPR)

We process your personal data in order to perform the contracts that we have concluded with you. Your personal data is also processed in order to take measures and carry out activities within the context of pre-contractual relations.

3.2.3. Compliance with legal obligations (Article 6(1)(c) GDPR)

We process your personal data when this is necessary to comply with legal obligations (e.g. trade and tax laws).

We also process your data if necessary to comply with monitoring and notification obligations under tax law, for archiving data for the purposes of data protection and data security, and for auditing by the tax office (Finanzamt) and other authorities. It may also be necessary to disclose personal data within the course of official or judicial procedures for the purposes of gathering evidence, criminal prosecution or enforcing civil law claims.

3.2.4. Our legitimate interests, or those of third parties (Article 6(1)(f) GDPR)

We may also use your personal data for the purpose of our legitimate interests or those of third parties, based on a balance of interests. For example, this may be for the following purposes:

  • For establishing legal claims and for defence in legal disputes
  • For preventing and investigating criminal acts, and
  • For managing and developing our business activities, including risk management.

3.3. Categories of personal data that we process

We process basic data concerning our contract partners and contact persons and the business relationship with our contract partners, which we refer to collectively as “master data”. In particular, this includes:

  1. a. All information that is provided to us when establishing the business relationship and/or that we have requested from our contract partner or a contact person:
  • Personal details (name, date of birth, place of birth, nationality, marital status, profession/industry and similar data);
  • Contact details (address, email address, telephone number and similar data);
  1. b. The data that we have recorded in connection with the establishment of the business relationship (particularly the details of the contracts concluded);

We also process personal data that arises in the course of the business relationship that is more than a simple amendment to the master data and that we refer to as “process data”. I In particular, this includes:

  1. a. Information regarding the services received by our contract partner based on the contracts concluded;
  2. b. Information regarding the services provided by us based on the contracts concluded;
  3. c. Information that our contract partner or a contact person provides in the course of the business relationship, either independently or when requested by us;
  4. d. Personal data that we receive from our contract partner, a contact person or a third party in another way in the course of our business relationship;

We may also store third-party personal data in the master data and process data to the extent permitted by law. For example, this includes data on our contract partner’s financial situation, if this is required in order to assess financial risks such as the risk of payment default.

We also process personal data from public sources (e.g. the Internet, media, press, register of companies and associations (Handels- und Vereinsregister), population register (Melderegister)). If necessary in order to provide our service, we process personal data that we have lawfully obtained from third parties (e.g. mailing list providers, credit reference agencies).

3.4. Who obtains your data?

We pass your personal data on to the departments within our company that need this data in order to comply with contractual and legal obligations and/or in order to exercise our legitimate interests.

The following parties may also obtain your data:

  • Processors that we use (Article 28 GDPR), service providers for supporting activities and other controllers as defined in the GDPR, particularly in the areas of IT services, logistics, courier services, printing services, external data centres, support with/maintenance of IT applications, archiving, document processing, accounting and controlling, data destruction, purchasing/procurement, customer administration, lettershops, marketing, telephone services, website management, tax consulting, auditing services, banks;
  • Public bodies and institutions, if we have a legal or official obligation requiring access, notification or the disclosure of data or if providing data is in the public interest;
  • Bodies and institutions based on our legitimate interest or the legitimate interests of third parties (e.g. authorities, credit reference agencies, debt collection agencies, law firms, courts, consultants and supervisory authorities);
  • Other bodies to which you have given us your consent to transmit data.

3.5. Transfer of your data to a third country or an international organisation

Data is not processed outside the EU or the EEC.

3.6. How long do we store your data for?

Where necessary, we process your personal data for the duration of our business relationship; this also includes the initiation and execution of a contract. Besides this, we are subject to various retention and documentation obligations under laws such as the German Commercial Code (Handelsgesetzbuch, HGB) and the German Fiscal Code (Abgabenordnung, AO). The retention and documentation periods laid out therein are up to 10 years from the end of the business relationship and/or the pre-contractual legal relationship. Finally, the storage period is also determined based on the statutory periods of limitation that — in accordance with Articles 195 et seqq. of the German Civil Code (Bürgerliches Gesetzbuch, BGB), for example — are usually three years but may even be up to thirty years in certain cases.

3.7. Automated decision-making (including profiling)?

We deal with you and your enquiries personally and, as a rule, we do not make use of any automated decision-making procedures or profiling in accordance with Article 22 GDPR.

3.8. Your data protection rights

You have the right of access in accordance with Article 15 GDPR, the right to rectification in accordance with Article 16 GDPR, the right to erasure in accordance with Article 17 GDPR, the right to restriction of processing in accordance with Article 18 GDPR and the right to data portability in accordance with Article 20 GDPR. In addition, you have the right to lodge a complaint with a data protection authority in accordance with Article 77 GDPR (see Section 10).

3.9. Information on your right to object in accordance with Article 21 GDPR

You have the right to object to processing of your data that is being carried out in accordance with Article 6(1)(f) GDPR (data processing based on a balance of interests) at any time if there are grounds for this relating to your particular situation. If you do object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or the processing is for the purpose of the establishment, exercise or defence of legal claims.

We may also process your personal data for direct marketing purposes. If you do not wish to receive any marketing, you have the right to object to this at any time. We will then comply with this objection in the future.

We will no longer process your data for direct marketing purposes if you object to processing for these purposes. The objection can be sent to our address provided above or the email address also stated above in any form.

3.10. Right to lodge a complaint

You have the right to lodge a complaint regarding the processing of personal data by us with the competent supervisory authority for data protection. The competent supervisory authority is the one where our company is based:

Unabhängiges Landeszentrum für Datenschutz Schleswig-Holstein [Centro Independiente para la Protección de la Protección de la seguridad]Schleswig-Holstein (Alemania)]

PO Box 71 16, 24171 Kiel (Germany)

Telephone: +44 31 988-1200
Fax: +44 31 988 -1223

mail@datenschutzzentrum.de

3.11. Privacy Policy for Visitors to our Website

Please also read our Privacy Policy for the use of our website.

4. Privacy Policy for Applicants

You disclose personal data as part of your application. In this Privacy Policy, we would like to give you detailed information on how we process your data and on which rights you have in connection with this data processing.

4.1. Controller

The Data Controller is

codafish ><> GmbH
Am Altenfeldsdeich 56
25371 Seestermühe

Germany

Phone: +49 30 666384800

Email: hello@codafish.net.

4.2. Purposes of processing and legal basis

Your personal data is processed in accordance with the provisions of the General Data Protection Regulation (GDPR), the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG) and other relevant data protection regulations.

We process personal data concerning you for the purpose of your job application to the extent that this is necessary in order to make a decision on whether to enter into an employment contract with you. The legal basis for this is Article 26(1) in conjunction with Article 26(8) second sentence of the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG).

We may also process personal data concerning you to the extent that this is necessary in order to defend legal claims against us arising from the application process. The legal basis for this is Article 6(1)(f) GDPR; for example, legitimate interests include the burden of proof in proceedings in accordance with the German General Act on Equal Treatment (Allgemeines Gleichbehandlungsgesetz, AGG).

If we enter into an employment with you, we also process the personal data that we have already received from you in accordance with Article 26(1) BDSG for the purposes of the employment contract if this is necessary in order to perform or terminate the employment contract or to exercise or comply with the rights and obligations to represent employees’ interests arising from a law or a wage agreement, a works agreement or a service agreement (a collective agreement).

4.3. Categories of personal data that we process

We process data that is associated with your application. This may be general data concerning you personally (such as your name, address and contact details), details of your professional qualifications and education or details of your professional development, as well as other details that you provide to us in connection with your application. Besides this, we may process job-related information that you have made publicly accessible, such as profiles on professional social media networks.

4.4. Who obtains your data?

Your personal data is not disclosed to third parties during the application process. If an employment contract is concluded, passing data on to third parties — e.g. to comply with legal requirements (payment of income tax, social security contributions, etc.) — is unavoidable. A separate privacy policy for employees is then provided.

4.5. Transfer of your data to a third country or an international organisation

Data is not processed outside the EU or the EEC. If you send us your application data via our recruiting system at Zoho Corporation B.V. (Netherlands), your data will be stored exclusively in European data centres and will be encrypted not only during its transmission, but also within the data centres themselves. It may occasionally be necessary for our support staff to access data from India in order to provide support. When this happens, EU standard contractual clauses are agreed to guarantee an appropriate level of data protection.

4.6. How long do we store your data for?

In general, your personal application data is erased six months after the application process is completed. This does not apply if there are legal regulations preventing erasure, if it must be stored for longer for the purpose of keeping evidence or if you have given your explicit consent for it to be stored for longer.

If we cannot offer you a vacant position at that time but, based on your profile, we believe that your application may be of interest for future vacancies, we will store your personal application data for twelve months, provided that you explicitly consent to such storage and use.

4.7. Automated decision-making (including profiling)?

We deal with you and your application personally and, as a rule, we do not make use of any automated decision-making procedures or profiling in accordance with Article 22 GDPR.

4.8. Your data protection rights

You have the right of access in accordance with Article 15 GDPR, the right to rectification in accordance with Article 16 GDPR, the right to erasure in accordance with Article 17 GDPR, the right to restriction of processing in accordance with Article 18 GDPR and the right to data portability in accordance with Article 20 GDPR. In addition, you have the right to lodge a complaint with a data protection authority in accordance with Article 77 GDPR (see Section 10).

4.9. Information on your right to object in accordance with Article 21 GDPR

You have the right to object to processing of your data that is being carried out in accordance with Article 6(1)(f) GDPR (data processing based on a balance of interests) at any time if there are grounds for this relating to your particular situation. If you do object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or the processing is for the purpose of the establishment, exercise or defence of legal claims.

We may also process your personal data for direct marketing purposes. If you do not wish to receive any marketing, you have the right to object to this at any time. We will then comply with this objection in the future.

We will no longer process your data for direct marketing purposes if you object to processing for these purposes. The objection can be sent to our address provided above or the email address also stated above in any form.

4.10. Right to lodge a complaint

You have the right to lodge a complaint regarding the processing of personal data by us with the competent supervisory authority for data protection. The competent supervisory authority is the one where our company is based:

Unabhängiges Landeszentrum für Datenschutz Schleswig-Holstein [Centro Independiente para la Protección de la Protección de la seguridad]Schleswig-Holstein (Alemania)]

PO Box 71 16, 24171 Kiel (Germany)

Telephone: +44 31 988-1200
Fax: +44 31 988 -1223

mail@datenschutzzentrum.de

4.11. Privacy Policy for Visitors to our Website

Please also read our Privacy Policy for the use of our website.

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codafish ><> your digital agency

With us you will get all the services you need in a comprehensive way. Starting with conception, and ending with implementation, we take care of hosting, maintenance and assisting you in your digital transformation. Feel free to call us for a free first consultation. We’re happy to hear from you!

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