Legal

Privacy policy

Information on the processing of personal data in accordance with the GDPR

This is a translation for your convenience. The legally binding version is the German original. View the German version.

1. Privacy at a glance

General information

The following notes provide a simple overview of what happens to your personal data when you visit this website. Personal data is any data with which you can be personally identified. For detailed information on data protection, please refer to our privacy policy listed below this text.

Data collection on this website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find their contact details in the section "Information about the responsible party" in this privacy policy.

How do we collect your data?

Your data is collected, on the one hand, by you providing it to us. This may be, for example, data that you enter in a contact form.

Other data is collected automatically or after your consent when you visit the website, by our IT systems. This is mainly technical data (e.g. internet browser, operating system or time of the page view). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Some of the data is collected to ensure error-free provision of the website. Other data can be used to analyze your user behavior. If contracts can be concluded or initiated via the website, the transmitted data is also processed for contract offers, orders or other order requests.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipient and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you can withdraw this consent at any time for the future. You also have the right, under certain circumstances, to request the restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time about this and other questions on data protection.

Analysis tools and third-party tools

When you visit this website, your surfing behavior can be statistically evaluated. This is done mainly with so-called analysis programs.

Detailed information about these analysis programs can be found in the following privacy policy.

2. Hosting and content delivery networks (CDN)

We host the content of our website with the following provider:

External hosting

This website is hosted externally. The personal data collected on this website is stored on the servers of the host(s). This may mainly be IP addresses, contact requests, meta and communication data, contract data, contact data, names, website accesses and other data generated via a website.

External hosting is carried out for the purpose of fulfilling the contract with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of secure, fast and efficient provision of our online offering by a professional provider (Art. 6(1)(f) GDPR). If corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as the consent covers the storage of cookies or access to information on the user's device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be withdrawn at any time.

Our host(s) will only process your data to the extent necessary to fulfill their performance obligations and will follow our instructions regarding this data.

We use the following host(s):

Vercel Inc.
c/o EDPO
Avenue Huart Hamoir 71
1030 Brussels
Belgium

Data processing agreement

We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract required by data protection law that ensures that this provider processes the personal data of our website visitors only according to our instructions and in compliance with the GDPR.

Cloudflare

We use the "Cloudflare" service. The provider is Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA (hereinafter "Cloudflare").

Cloudflare offers a globally distributed content delivery network with DNS. Technically, the transfer of information between your browser and our website is routed through Cloudflare's network. This enables Cloudflare to analyze the data traffic between your browser and our website and to act as a filter between our servers and potentially malicious traffic from the internet. In doing so, Cloudflare may also use cookies or other technologies to recognize internet users, which are used solely for the purpose described here.

The use of Cloudflare is based on our legitimate interest in providing our web offering as error-free and securely as possible (Art. 6(1)(f) GDPR).

The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details and further information on security and data protection at Cloudflare can be found here: https://www.cloudflare.com/privacypolicy/.

The company is certified under the "EU-US Data Privacy Framework" (DPF). The DPF is an agreement between the European Union and the USA intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF commits to complying with these data protection standards. Further information can be obtained from the provider at the following link: https://www.dataprivacyframework.gov/participant/5666.

Data processing agreement

3. General information and mandatory information

Data protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected. Personal data is data with which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this happens.

We point out that data transmission over the internet (e.g. when communicating by email) can have security gaps. Complete protection of data against access by third parties is not possible.

Information about the responsible party

The party responsible for data processing on this website is:

webtofly GmbH
Stefano Montuschi
Im Schloßgarten 1
77971 Kippenheim

Phone: +49 7825 864 748-0
Email: kontakt(at)webtofly.de

The responsible party is the natural or legal person who alone or jointly with others decides on the purposes and means of processing personal data (e.g. names, email addresses, etc.).

Storage duration

Unless a more specific storage period has been stated within this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a justified request for deletion or revoke 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 retention periods); in the latter case, deletion takes place after these reasons no longer apply.

General information on the legal bases for data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, insofar as special categories of data pursuant to Art. 9(1) GDPR are processed. In the case of explicit consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49(1)(a) GDPR. If you have consented to the storage of cookies or to access to information on your device (e.g. via device fingerprinting), the data processing is additionally carried out on the basis of Section 25(1) TDDDG. Consent can be withdrawn at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, we process your data if it is required to fulfill a legal obligation on the basis of Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. Information on the legal bases relevant in each individual case is provided in the following paragraphs of this privacy policy.

Recipients of personal data

As part of our business activities, we work with various external parties. In some cases, the transfer of personal data to these external parties is also required. We only pass on personal data to external parties if this is required as part of the fulfillment of a contract, if we are legally obliged to do so (e.g. passing on data to tax authorities), if we have a legitimate interest pursuant to Art. 6(1)(f) GDPR in passing it on, or if another legal basis permits the passing on of data. When using processors, we only pass on personal data of our customers on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.

Withdrawal of your consent to data processing

Many data processing operations are only possible with your express consent. You can withdraw consent you have already given at any time. The lawfulness of the data processing carried out until the withdrawal remains unaffected by the withdrawal.

Right to object to data collection in special cases and to direct advertising (Art. 21 GDPR)

IF DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR AFFECTED PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OUTWEIGH YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES TO ASSERT, EXERCISE OR DEFEND LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT ADVERTISING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH ADVERTISING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS CONNECTED WITH SUCH DIRECT ADVERTISING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT ADVERTISING (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to lodge a complaint with the competent supervisory authority

In the event of violations of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the member state of their habitual residence, their place of work or the place of the alleged violation. The right to lodge a complaint exists without prejudice to other administrative or judicial remedies.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

Information, correction and deletion

Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipients and the purpose of the data processing and, if applicable, a right to correction or deletion of this data. You can contact us at any time about this and other questions on the subject of personal data.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restriction of processing exists in the following cases:

If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the verification, you have the right to request the restriction of the processing of your personal data.
If the processing of your personal data happened/is happening unlawfully, you can request the restriction of data processing instead of deletion.
If we no longer need your personal data but you need it to exercise, defend or assert legal claims, you have the right to request the restriction of the processing of your personal data instead of deletion.
If you have lodged an objection pursuant to Art. 21(1) GDPR, a balance must be struck between your interests and ours. As long as it has not been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data may, apart from its storage, only be processed with your consent or to assert, exercise or defend legal claims or to protect the rights of another natural or legal person or for reasons of important public interest of the European Union or a member state.

SSL/TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or inquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from "http://" to "https://" and by the lock symbol in your browser line.

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

4. Data collection on this website

Contact form

If you send us inquiries via the contact form, your details from the inquiry form, including the contact data you provide there, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We do not pass on this data without your consent.

The processing of this data is carried out on the basis of Art. 6(1)(b) GDPR, insofar as your inquiry is related to the fulfillment of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective handling of inquiries addressed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) if this was requested; consent can be withdrawn at any time.

The data you enter in the contact form will remain with us until you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after processing your inquiry has been completed). Mandatory statutory provisions, in particular retention periods, remain unaffected.

Inquiry by email, phone or fax

If you contact us by email, phone or fax, your inquiry, including all personal data resulting from it (name, inquiry), will be stored and processed by us for the purpose of handling your request. We do not pass on this data without your consent.

The data you send us via contact requests will remain with us until you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies (e.g. after processing your request has been completed). Mandatory statutory provisions, in particular statutory retention periods, remain unaffected.

5. Analysis tools and advertising

Plausible Analytics

We use Plausible Analytics on our website. The provider is Plausible Insights OÜ, Västriku tn 2, 50403, Tartu, Estonia.

With Plausible Analytics we can analyze the behavior of our website visitors. For this purpose, the following data in particular is collected: page URL, HTTP request, HTTP referrer, browser, operating system, device type and IP address. The HTTP request and IP address are stored in a hash for 24 hours; within this period a user can be recognized if they come to the website again. Identification of the person is not possible.

Insofar as consent has been obtained, the use of the above-mentioned service is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25 TDDDG. Consent can be withdrawn at any time. Insofar as no consent has been obtained, the use of this service is based on Art. 6(1)(f) GDPR; the website operator has a legitimate interest in the most meaningful possible analysis of the user behavior of our website visitors.

Data processing agreement

6. Plugins and tools

Cloudflare Turnstile

We use Cloudflare Turnstile (hereinafter "Turnstile") on this website. The provider is Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA (hereinafter "Cloudflare").

The purpose of Turnstile is to check whether data entry on this website (e.g. in a contact form) is carried out by a human or by an automated program. To do this, Turnstile analyzes the behavior of the website visitor based on various characteristics.

This analysis begins automatically as soon as the website visitor enters a website with Turnstile enabled. For the analysis, Turnstile evaluates various information (e.g. IP address, the website visitor's time on the website or mouse movements made by the user). The data collected during the analysis is forwarded to Cloudflare.

The storage and analysis of the data is carried out on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in protecting its web offerings against abusive automated spying and against spam. If corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and Section 25(1) TDDDG, insofar as the consent covers the storage of cookies or access to information on the user's device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent can be withdrawn at any time.

The data processing is based on standard contractual clauses, which you can find here: https://www.cloudflare.com/cloudflare-customer-scc/.

Further information on Cloudflare Turnstile can be found in the data protection provisions at https://www.cloudflare.com/cloudflare-customer-dpa/.

7. eCommerce and payment providers

Credit checks

In the case of a purchase on account or another payment method where we make advance payment, we may carry out a credit check procedure (scoring). For this purpose, we transmit the data you have entered (e.g. name, address, age or bank details) to a credit agency. On the basis of this data, the probability of a payment default is determined. In the event of an excessive payment default risk, we may refuse the payment method in question.

The credit check is carried out on the basis of contract fulfillment (Art. 6(1)(b) GDPR) and to avoid payment defaults (legitimate interest pursuant to Art. 6(1)(f) GDPR). If consent has been obtained, the credit check is carried out on the basis of this consent (Art. 6(1)(a) GDPR); consent can be withdrawn at any time.

8. Audio and video conferences

Data processing

For communication with our customers, we use, among other things, online conference tools. The tools we use in detail are listed below. If you communicate with us via video or audio conference over the internet, your personal data will be collected and processed by us and the provider of the respective conference tool.

The conference tools collect all data that you provide/use to use the tools (email address and/or your phone number). Furthermore, the conference tools process the duration of the conference, the start and end (time) of participation in the conference, the number of participants and other "context information" in connection with the communication process (metadata).

Furthermore, the provider of the tool processes all technical data required to handle 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 speaker as well as the type of connection.

If content is exchanged, uploaded or otherwise provided within the tool, this is also stored on the servers of the tool providers. Such content includes in particular cloud recordings, chat / instant messages, voicemails, uploaded photos and videos, files, whiteboards and other information shared during the use of the service.

Please note that we do not have full influence over the data processing operations of the tools used. Our options depend largely on the corporate policy of the respective provider. Further information on data processing by the conference tools can be found in the privacy policies of the respective tools used, 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(1)(b) GDPR). Furthermore, the use of the tools serves to generally simplify and accelerate communication with us or our company (legitimate interest within the meaning of Art. 6(1)(f) GDPR). Insofar as consent has been requested, the relevant tools are used on the basis of this consent; consent can be withdrawn at any time with effect for the future.

Storage duration

The data collected directly by us via the video and conference tools is deleted from our systems as soon as you ask us to delete it, revoke your consent to storage or the purpose for data storage no longer applies. Stored cookies remain on your device until you delete them. Mandatory statutory retention periods remain unaffected.

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

Conference tools used

We use the following conference tools:

Microsoft Teams

We use Microsoft Teams. The provider is Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, Ireland. Details on data processing can be found in the Microsoft Teams privacy policy: https://privacy.microsoft.com/en-us/privacystatement.