| Information about the Processing of Personal
Data |
| This privacy policy describes how we collect, use and share your
personal data when you use our website. In doing so, we inform you about
our processing operations and fulfill our legal obligations, in
particular those arising from the EU General Data Protection Regulation
(GDPR). |
| Personal data is all data that can be related to you personally,
e.g. name, e-mail address, your health information and user
behavior. |
| The data controller pursuant to Art. 4 (7) GDPR is Soofia
UG(haftungsbeschränkt), Glogauer Strasse 11a, 10999 Berlin, Germany,
info@soofia.co (see our imprint) (also
referred to as “we”, “us” or “our”). |
| We may use carefully selected and monitored service providers for
certain functions of our offer or we may use your data for advertising
purposes. If this is the case, we will inform you in detail below about
the processes involved, including the specified storage period. |
| Your Rights |
You have the following rights towards us regarding personal data
concerning you:
- right to information (Art. 15 GDPR),
- right to rectification (Art. 16 GDPR),
- right to erasure (Art. 17 GDPR),
- right to restriction of processing (Art. 18 GDPR),
- right to data portability (Art 20 GDPR),
- right to object against automated processing (Art. 21 GDPR),
- right to withdraw the data protection consent declaration, and
- right to complain to a data protection supervisory authority about our processing of your personal data.
|
| Processing of Personal Data when Visiting our
Website |
If you visit our website for informational purposes only, i.e. if
you visit our website without registering or otherwise providing us with
information, we automatically collect the following personal data that
your browser transmits to our server:
- Your IP address,
- date and time of the access,
- time zone difference from Greenwich Mean Time (GMT),
- web pages accessed by your system through our website,
- access status/HTTP status code,
- data volume transferred in each case,
- web pages from which your system accessed our website,
- browser type as well as the version and language used, and
- your operating system.
|
| These data are technically necessary to display our website to you
and to ensure the stability and security of the system. |
| The legal basis for the processing of the aforementioned data is
Art. 6 (1) sentence 1 lit. f GDPR. Our legitimate interest lies in
providing a functional and secure website. |
| The data will be deleted as soon as they are no longer required to
fulfill the purpose of their collection, but no later than after seven
days. |
| Data Security |
| We use appropriate technical and organizational measures to protect
your data from manipulation, loss, destruction or unauthorized access.
In doing so, we take into account the state of the art, the
implementation costs and the nature, scope, context and purpose of the
processing. In addition, we regularly assess the risks of a possible
data breach, including its probability and impact. Our security measures
are continuously adapted to technological progress. |
| Objection or Withdrawal of Consent to Processing your
Personal Data |
| If you have consented to the processing of your data, you may
withdraw this consent at any time. The withdrawal applies from the time
at which you notify us of it and concerns the future processing of your
data. The permissibility of the processing of your data up to the time
of your withdrawal remains unaffected. |
| If we base the processing of your personal data on a balancing of
interests, you may object to the processing. We will in particular
undertake a balancing of interests if we process your data in the public
interest or based on our legitimate interests. When objecting against
the processing, please provide us with the reasons for your objection as
to why you reject the processing of your data in the previous form. We
will review your objection and will either discontinue or adjust the
processing, or explain to you our compelling legitimate reasons that
justify the continuation of the processing. |
| You may object to the processing of your personal data for purposes
of advertising and data analysis at any time. |
| Please contact us at info@soofia.co for any withdrawals or
objections. |
| Storage Periods of Your Personal Data |
| We only store your personal data for as long as is necessary to
fulfill the purposes we collected it for. This includes the fulfillment
of legal, tax and accounting obligations. When determining the storage
period, we take into account the scope, type and sensitivity of the
data, the potential risk of unauthorized use or disclosure, the purposes
of the processing, whether we can achieve these purposes by other means
and applicable legal requirements. |
| In some circumstances we may anonymize your personal data so that it
can no longer be associated with you, in which case we may use such
information without further notice to you. |
| If you have any questions on the way we retain your personal data
you can contact us via the contact details provided above. |
| Other Functions and Offers on our Website |
| In addition to the use of our website for informational purposes, we
offer various services and features that you can use if you are
interested and that we describe in detail below. In doing so, we also
use analysis and marketing functions, which we will also explain in more
detail below. Usually, you will need to provide additional personal data
for this, which we process in order to provide these services. All
principles described above apply to these data processings. |
| In some cases, we use external service providers to process your
data. These are carefully selected by us, are bound by our instructions
and are regularly monitored. |
| Furthermore, we may pass on your personal data to third parties if
we provide services together with partners. Depending on the service,
the partners may also collect your data on their own responsibility. You
will receive more information when you provide your data or below in the
description of the respective offers. |
| If our service providers or partners are based in a country outside
the European Economic Area (EEA), we will inform you about the
consequences of this circumstance in the relevant offer description
below. |
| Use of Cookies |
| General: In addition to the data already mentioned,
we use technical aids such as cookies, which are stored on your end
device. When you visit our website and also thereafter, you have the
choice of whether you want to allow cookies in general or select
individual functions. You can adjust these settings via your browser or
our cookie consent manager. |
| What are cookies? Cookies are small text files or
database entries that are stored on your computer system. They contain a
characteristic string of characters that enables your browser to be
clearly identified when you return to the website. Cookies cannot
execute programs or transmit viruses. Their main purpose is to make our
website faster and more user-friendly. In the following, we explain the
different types of cookies we use, how they work, how long they are
stored for and the corresponding legal basis. |
| Necessary cookies: We use necessary cookies for the
technical operation of our website. Without these, the website cannot be
displayed completely or correctly, and certain support functions would
not be available. These cookies are usually temporary cookies (see below
for an explanation of this term). These cookies cannot be deselected if
you wish to use our website. You can find an overview of these cookies
in the cookie consent manager. The legal basis for this processing is
Art. 6 (1) sentence 1 lit. f GDPR. |
| Optional cookies: We only set these cookies after
you have given your consent, which you can do on your first visit to our
website using the cookie consent manager. They enable us to analyze and
improve the use of the website, to facilitate operation across different
browsers and devices, to recognize you when you visit again, or to place
advertisements that are tailored to your interests and to measure their
effectiveness. The legal basis for this processing is Art. 6 (1)
sentence 1 lit. a GDPR. You can revoke your consent at any time. |
| Storage period: The storage period depends on
whether the cookies are temporary or persistent (permanent). |
| Temporary cookies: These cookies, in particular
so-called session cookies, are automatically deleted when you close your
browser or log out. They contain a so-called session ID. This allows
various requests from your browser to be assigned to the same session,
and your computer to be recognized when you return to our website. |
| Persistent cookies: These are automatically deleted
after a specified period, which is set differently for each cookie. You
can view the cookies that have been set and their durations at any time
in your browser settings and delete the cookies manually. |
| Some of the third-party services we integrate may use their own
cookies. Information on how they work and process data can be found on
the websites of the respective service providers. The third-party
services we use are listed in this privacy policy. |
| If you are using Safari version 12.1 or later, cookies will be
automatically deleted after seven days. This also applies to opt-out
cookies that are set to prevent tracking. |
| Online Marketing / Analytics Tools |
| We use online marketing and analysis tools to tailor our website to
your needs and to continuously optimize its use. These measures are
based on your consent in accordance with Art. 6 (1) sentence 1 lit. a
GDPR. If data is transferred to a country outside the European Union
(so-called third country), this will only take place if you have
expressly consented to it, or if it is necessary for us to provide our
services to you, or if it is required by law (Art. 49 GDPR). Your data
will only be processed in third countries if certain measures ensure an
adequate level of data protection, e.g. through an adequacy decision by
the EU Commission or through appropriate safeguards in accordance with
Art. 44 et seqq. DSGVO. |
| Google Analytics |
| If you have given your consent, we use Google Analytics 4 on this
website, a web analysis service provided by Google LLC. For users in the
EU, the EEA and Switzerland, the responsible body is Google Ireland
Limited, Dublin, Ireland (“Google”). Google Analytics uses cookies to
analyze the use of our website and our marketing campaigns. The data
processing is carried out on the basis of your consent in accordance
with Art. 6 (1) sentence 1 lit. a GDPR. |
| The information collected by Google Analytics is usually transferred
to a Google server in the USA and stored there. Recipients of the data
may be Google Ireland Limited (Gordon House, Barrow Street, Dublin 4,
Ireland), Google LLC (1600 Amphitheatre Parkway Mountain View, CA 94043,
USA), or Alphabet Inc. (1600 Amphitheatre Parkway Mountain View, CA
94043, USA). On July 10, 2023, the European Commission issued an
adequacy decision for data transfers to the United States. Google LLC is
certified under the EU-US Privacy Framework. In addition, we have
concluded the EU Standard Contractual Clauses (SCC) with Google. |
| Google Analytics 4 has IP anonymization enabled by default. This
means that your IP address within the EU or the EEA is shortened before
it is transmitted to Google. Only in exceptional cases will the full IP
address be transmitted to the US and shortened there. According to
Google, the IP address transmitted by your browser will not be merged
with other Google data. |
| During your visit to our website, your user behavior is recorded in
the form of “events”. These include, for example, page views, first-time
visits to the website, start of the session, websites visited, your
“click path”, interactions with the website, scrolling actions (when a
user scrolls to the bottom of the page), clicks on external links,
internal search queries, interactions with videos, file downloads,
advertisements seen or clicked on, and your language setting. |
| In addition, your approximate location (region), date and time of
your visit, your IP address (in abbreviated form), technical information
about your browser and the end devices used (e.g. language setting,
screen resolution), your internet provider and the referrer URL (via
which website or which advertising medium you came to this website) are
recorded. |
| You can withdraw your consent at any time. The withdrawal applies
from the time you notify us of it and affects future processing. The
lawfulness of the processing up to your withdrawal remains
unaffected. |
| You can prevent the installation and storage of cookies by selecting
the appropriate settings on your browser; however, we would like to
point out that in this case you may not be able to use all the features
of this website to its full extent. |
| You can also prevent the data generated by cookies about your use of
the website (incl. your IP address) from being passed to Google, and the
processing of these data by Google, by downloading and installing the
browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de. |
| With the following link you can deactivate the use of your personal
data by Google: https://myadcenter.google.de/personalizationoff.
|
| Google Tag Manager |
| The Google Tag Manager, provided by Google Ireland Limited, Dublin,
Ireland (“Google”), is a tool that allows us to integrate tracking and
statistical tools as well as other technologies on our website. The tool
itself does not create user profiles, store cookies or carry out its own
analyses. It is used solely for the administration and display of the
integrated tools. In doing so, the Google Tag Manager records your IP
address, which may also be transmitted to Google in the United
States. |
| The information collected by Google Analytics is usually transferred
to a Google server in the USA and stored there. Recipients of the data
may be Google Ireland Limited (Gordon House, Barrow Street, Dublin 4,
Ireland), Google LLC (1600 Amphitheatre Parkway Mountain View, CA 94043,
USA), or Alphabet Inc. (1600 Amphitheatre Parkway Mountain View, CA
94043, USA). On July 10, 2023, the European Commission issued an
adequacy decision for data transfers to the United States. Google LLC is
certified under the EU-US Privacy Framework. In addition, we have
concluded the EU Standard Contractual Clauses (SCC) with Google. |
| The use of Google Tag Manager is based on Art. 6 (1) sentence 1 lit.
f GDPR. Our legitimate interest lies in the efficient administration of
various tools on the website. If consent has been obtained, the
processing is carried out on the basis of Art. 6 (1) sentence 1 lit. a
GDPR and Sec. 25 (1) German Telecommunications and Telemedia Data
Protection Act. You can withdraw your consent at any time. The
withdrawal applies from the time you notify us of it and affects future
processing. The lawfulness of the processing up to your withdrawal
remains unaffected. |
| For more information about Google Tag Manager and Google’s privacy
policy, please visit https://policies.google.com/privacy?hl=de
and https://marketingplatform.google.com/about/analytics/tag-manager/use-policy/.
|
| Google Ads / Google Conversion Tracking |
| We also use the online advertising program “Google Ads” and, within
the framework of Google Ads, conversion tracking, provided by Google
Ireland Limited, Dublin, Ireland (“Google”). |
| Google Ads allows us to display ads based on certain search terms or
user data such as location and interests. We can also analyze this data,
e.g. which search terms triggered ads and how many clicks they
received. |
| Google Conversion Tracking enables us to recognize whether users
have performed certain actions on our website, such as clicking on
buttons or purchasing products. This data helps us to generate
conversion statistics. We learn the number of users who clicked on our
ads and what actions they performed, but without personal
identification. Google uses cookies or similar technologies for this
purpose. |
| The data collected by Google Analytics is usually transferred to a
Google server in the USA and stored there. Recipients of the data may be
Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland),
Google LLC (1600 Amphitheatre Parkway Mountain View, CA 94043, USA), or
Alphabet Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA).
On July 10, 2023, the European Commission issued an adequacy decision
for data transfers to the United States. Google LLC is certified under
the EU-US Privacy Framework. In addition, we have concluded the EU
Standard Contractual Clauses (SCC) with Google. |
| The use of Google Ads and Google Conversion Tracking is based on
your consent in accordance with Art. 6 (1) sentence 1 lit. f GDPR. You
can withdraw your consent at any time. The withdrawal applies from the
time you notify us of it and affects future processing. The lawfulness
of the processing up to your withdrawal remains unaffected. |
| For more information about Google Tag Manager and Google’s privacy
policy, please visit https://policies.google.com/privacy?hl=de. |
|
| Conclusion of a Contractual Relationship |
| When concluding a contractual relationship on our website, by
subscribing to one of our paid plans, we ask you to provide the
following personal data: |
| Data that allows your personal identification, such as name and
email address; date of birth; contact data, such as address billing and
delivery address as well as telephone number; data that identifies your
company, such as company name, address, communication data (email
address, telephone, fax number), VAT ID or tax number (if applicable);
information about your means of payment. |
| Other personal data that we are required or authorized by law to
collect and process and that we need for your authentication,
identification or to verify the data we collect. |
| The aforementioned data is processed for the purpose of carrying out
the contractual relationship. The processing of the data is based on
Art. 6 (1) sentence 1 lit. b GDPR. The storage period is limited to the
purpose of the contract and, if applicable, legal and contractual
retention obligations. |
| Use of Payment Providers |
| For processing the payment of contracts concluded with us, we
collaborate with the payment service provider ‘Stripe Payments
Europe, Limited (SPEL), 1 Grand Canal Street Lower, Grand Canal Dock,
Dublin, D02 H210, Ireland (“Stripe”)’. When processing the payment,
we pass on your payment data to the payment service provider – only for
the purpose of facilitating the payment – insofar as this is necessary
for the payment processing. The legal basis for the transfer of data is,
in each case, Art. 6 (1) sentence 1 lit. b GDPR. |
| Signing Up for our Newsletter |
| If you have expressly consented in accordance with Art. 6 (1)
sentence 1 lit. a GDPR, we will use your email address to send you our
newsletter on a regular basis. |
| The email address will be deleted as soon as it is no longer
necessary to achieve the purpose for which it was collected. Your email
address will therefore be stored as long as the newsletter subscription
is active. |
| Unsubscribing is possible at any time, for example via a link at the
end of a newsletter. |
| Contact via Email |
| When you contact us via email or via a contact form, the data you
provide (your email address, name and telephone number, if applicable)
will be stored by us in order to answer your questions or handle your
complaint. The data processing for the purpose of contacting us is
carried out in accordance with Art. 6 (1) sentence 1 lit. a GDPR on the
basis of your voluntarily given consent. We delete the data accruing in
this context, (i) if the inquiry is assigned to a contract, after the
term of the contract has elapsed, and (ii) otherwise after the storage
is no longer necessary, or (iii) restrict the processing if there are
legal obligations to retain data. |
| Use of the Login Area |
| If you wish to use our soofia.co platform, you must register by
entering your email address, a password of your choice and your user
name. There is no obligation to use a clear name; pseudonymous use is
possible. The provision of the aforementioned data is mandatory, whereas
all other information can be provided voluntarily when using the
platform. For this service we use the so-called double-opt-in procedure,
i.e. you will receive an email in which you must confirm that you are
the owner of the respective email address and wish to receive
notifications. You can unsubscribe from the notifications at any time,
e.g. by clicking on the link in the email or by contacting us using the
contact details provided. Your provided data as well as the dates of
your registration for the service and your IP address will be stored by
us until you unsubscribe from the notice service. |
| If you use our platform, we store your data required for the
fulfillment of the contract, as well as information on the method of
payment, until you ultimately delete your account. Furthermore, we store
the voluntary data provided by you for the time of your use of the
platform, unless you delete them beforehand. You can manage and change
all details in the protected customer area. Legal basis is Art. 6 (1)
sentence 1 lit. b GDPR. |
| User Accounts |
| If you interact with our services and products you are given the
opportunity to create an account with us. The creation of an account is
based on your consent. You can withdraw your consent and/or delete your
account by contacting us via the contact details provided above. The
withdrawal or deletion of your account may have negative consequences on
your user experience. The following personal data is processed in
connection with your account: Name, address data, contact data. Legal
basis for the processing of this data is Art. 6 (1) sentence 1 lit. a
GDPR. |
| Automated Decision-Making and Profiling |
| In the performance of the contract with you and to the extent
necessary to fulfill our obligations to you or where necessary for
purposes of the legitimate interest such as to improve our products or
our services, we use automated decision-making and profiling. When such
automated decision-making and/or profiling leads to a negative decision
about you, and you do not agree with it, or if you would like to object
to this type of processing of your personal data you can contact us via
the contact details provided above. We will then proceed to reassess the
situation and/or to provide you with more information about why such an
automated decision was made. |
|
| Up-To-Dateness and Amendments of this Privacy
Policy |
| Due to the further development of our website and offers on it or
due to changed legal or regulatory requirements, we may be required to
amend this privacy policy. |
| This policy was last modified on 26.09.2024 |
