This privacy statement explains the nature, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online offer and its related websites, functions and content, as well as external online presence, such as our Social Media Profile (hereafter collectively referred to as "online offer"). With regard to the terms used, such as "processing" or "responsible", we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).
Publisher (legal entity):
Company "ooo Герой" (ooo Geroy), registered company
OGRN 1172375019959, reg. Krasnodar, Russian Federation
350088 Krasnodar, Russian Federation
✆ Germany: + 49-40-22861140
✆ Austria: + 43-1-3649234
✆ Russia: + 7-499-6094132
✆ USA: + 1-408-7695407
Types of processed data:
- Inventory data (eg, names, addresses).
- Contact details (eg, e-mail, telephone numbers).
- Content data (eg, text input, photographs, videos).
- Usage data (eg, visited websites, interest in content, access times).
- Meta / communication data (eg, device information, IP addresses).
Categories of affected persons
Visitors and users of the online offer (hereinafter we refer to the affected persons as "users").
Purpose of processing
- Provision of the online offer, its functions and contents.
- Answering contact requests and communicating with users.
- Safety measures.
- Reach Measurement / Marketing
"Personal data" means any information relating to an identified or identifiable natural person (hereinafter the "data subject"); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (eg cookie) or to one or more special features, that express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.
"Processing" means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term goes far and includes virtually every handling of data.
"Pseudonymisation" means the processing of personal data in such a way that the personal data can no longer be assigned to a specific data subject without additional information being provided, provided that such additional information is kept separate and subject to technical and organizational measures to ensure that the personal data not assigned to an identified or identifiable natural person.
"Profiling" means any kind of automated processing of personal data which involves the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular aspects relating to job performance, economic situation, health, personal To analyze or predict preferences, interests, reliability, behavior, whereabouts or relocation of that natural person.
"Responsible person" means the natural or legal person, public authority, body or body that decides, alone or in concert with others, on the purposes and means of processing personal data.
"Processor" means a natural or legal person, public authority, agency or other body that processes personal data on behalf of the controller.
Relevant legal bases
In accordance with Art. 13 DSGVO we inform you about the legal basis of our data processing. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 DSGVO, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 para. 1 lit. b DSGVO, the legal basis for processing in order to fulfill our legal obligations is Art. 6 para. 1 lit. c DSGVO, and the legal basis for processing for the protection of our legitimate interests is Art. 6 para. 1 lit. f DSGVO. In the event that vital interests of the data subject or any other natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO as legal basis.
We take appropriate technical measures in accordance with Art. 32 GDPR, taking into account the state of the art, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the different likelihood and severity of the risk to the rights and freedoms of individuals and organizational measures to ensure a level of protection appropriate to the risk.
Measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as their access, input, disclosure, availability and separation. We have also set up procedures to ensure the enjoyment of data subject rights, data deletion and data vulnerability. Furthermore, we consider the protection of personal data already in the development, or selection of hardware, software and procedures, according to the principle of data protection by technology design and by privacy-friendly default settings (Article 25 DSGVO).
Collaboration with processors and third parties
If, in the context of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit them to them or otherwise grant access to the data, this will only be done on the basis of a legal permission (eg if a transmission of the data to third parties, as to payment service providers, in accordance with Art. 6 para. 1 lit. b DSGVO is required to fulfill the contract), you have consented to a legal obligation or on the basis of our legitimate interests (eg the use of agents, webhosters, etc.).
If we commission third parties to process data on the basis of a so-called "order processing contract", this is done on the basis of Art. 28 DSGVO.
Transfers to third countries
If we process data in a third country (ie outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done if it is to fulfill our (pre) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or have the data processed in a third country only in the presence of the special conditions of Art. 44 et seq. DSGVO. This means, for example, that the processing takes place on the basis of special guarantees, such as the officially recognized level of data protection (eg for the USA through the "Privacy Shield") or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").
Rights of data subjects
You have the right to request a confirmation as to whether the data in question are being processed and to provide information about this data as well as further information and a copy of the data in accordance with Art. 15 DSGVO.
You have accordingly. Art. 16 DSGVO the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you.
In accordance with Art. 17 DSGVO, they have the right to demand that the relevant data be deleted immediately, or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 DSGVO.
You have the right to demand that the data relating to you provided to us be obtained in accordance with Art. 20 DSGVO and to be transmitted to other persons responsible.
You have gem. Art. 77 DSGVO the right to file a complaint with the competent supervisory authority.
Right of rescission
You have the right to grant consent in accordance with. Art. 7 para. 3 DSGVO with effect for the future
Right To Object
You may at any time object to the future processing of your data in accordance with Art. 21 GDPR. The objection may in particular be made against processing for direct marketing purposes.
Cookies and right to object in direct mail
"Cookies" are small files that are stored on users' computers. Different information can be stored within the cookies. A cookie is primarily used to store the information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, for example, the content of a shopping cart in an online shop or a login status can be saved. The term "permanent" or "persistent" refers to cookies that remain stored even after the browser has been closed. For example, the login status can be saved if users visit it after several days. Likewise, in such a cookie the interests of the users can be stored, which are used for range measurement or marketing purposes. A "third-party cookie" refers to cookies that are offered by providers other than the person who manages the online offer (otherwise, if it is only their cookies, this is called "first-party cookies").
If users do not want cookies stored on their computer, they will be asked to disable the option in their browser's system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.
A general contradiction against the use of the cookies used for the purpose of online marketing can in a variety of services, especially in the case of tracking, on the US side http://www.aboutads.info/choices/ or the EU side http://www.youronlinechoices.com/ be explained. Furthermore, the storage of cookies can be achieved by switching them off in the settings of the browser. Please note that not all features of this online offer may be used.
Deletion of data
According to legal requirements in Germany, the retention takes place in particular for 10 years according to §§ 147 para. 1 AO, 257 para. 1 no. 1 and 4, para. 4 HGB (books, records, management reports, accounting documents, trading books, for taxation relevant Documents, etc.) and 6 years according to § 257 para. 1 No. 2 and 3, para. 4 HGB (commercial letters).
According to legal regulations in Austria the storage takes place in particular for 7 J according to § 132 para. 1 BAO (accounting documents, receipts / invoices, accounts, receipts, business papers, statement of income and expenses, etc.), for 22 years in connection with real estate and for 10 years of documentation related to electronically provided services, telecommunications, broadcasting and television services provided to non-entrepreneurs in EU Member States for which the Mini-One-Stop-Shop (MOSS) is used.
Participation in Affiliate Affiliate Programs
Within our online offer, we rely on our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer) gem. Art. 6 para. 1 lit. f DSGVO industry-standard tracking measures as required for the operation of the affiliate system. Below we clarify the users about the technical background.
The services offered by our contractual partners can also be advertised and linked to other websites (so-called affiliate links or after-buy systems, eg if links or services of third parties are offered after conclusion of a contract). The operators of the respective websites receive a commission if users follow the affiliate links and then take advantage of the offers.
In summary, our online offering requires us to be able to keep track of whether users who are interested in affiliate links and / or the offers available to us are subsequently viewing the offers at the instigation of the affiliate links or our online platform. For this, the affiliate links and our offers are supplemented by certain values, which can be part of the link or otherwise, eg in a cookie. The values include in particular the source website (referrer), time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as tracking specific values such as ad ID, affiliate ID and categorization.
The online user IDs used by us are pseudonymous values. This means that the online identifiers themselves contain no personal data such as names or e-mail addresses. They only help us to determine if the same user who clicked on an affiliate link or was interested in an offer via our online offer has accepted the offer, ie has signed a contract with the provider. However, the online identification is personal in so far as the partner company and also us, the online identification together with other user data are available. Only then can the partner company tell us whether the user has taken advantage of the offer and, for example, we can pay the bonus.
Amazon Affiliate Program
When contacting us (eg via contact form, e-mail, telephone or via social media), the information provided by the user to process the contact request and its processing acc. Art. 6 para. 1 lit. b) DSGVO processed. User information can be stored in a Customer Relationship Management System ("CRM System") or comparable request organization.
We delete the requests, if they are no longer required. We check the necessity every two years; Furthermore, the legal archiving obligations apply.
Google Tag Manager
Google Tag Manager is a solution that allows us to manage so-called website tags through a single interface (including integrating Google Analytics and other Google marketing services into our online offering). The tag manager itself (which implements the tags) does not process users' personal data. With regard to the processing of users' personal data, reference is made to the following information about Google's services. Usage guidelines: https://www.google.com/intl/de/tagmanager/use-policy.html.
Google is certified under the Privacy Shield Agreement, which provides a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf to evaluate the use of our online offer by users, to compile reports on the activities within this online offer and to provide us with further services related to the use of this online offer and the internet usage. In this case, pseudonymous usage profiles of the users can be created from the processed data.
We only use Google Analytics with activated IP anonymization. This means that the IP address of the users will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.
The IP address submitted by the user's browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users may also prevent the collection by Google of the data generated by the cookie and related to their use of the online offer and the processing of such data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
The personal data of users will be deleted or anonymized after 14 months.
Google Universal Analytics
We use Google Analytics in the design as "Universal Analytics" on. "Universal Analytics" means a process of Google Analytics, in which the user analysis is based on a pseudonymous user ID and thus a pseudonymous profile of the user is created with information from the use of different devices (so-called "cross-device tracking") ,
Targeting with Google Analytics
We use Google Analytics to display advertisements displayed within Google and its affiliate advertising services, only those users who have shown an interest in our online offering or who have certain characteristics (eg interests in specific topics or products visited by them) Web pages) that we submit to Google (so-called "remarketing" or "Google Analytics audiences"). With Remarketing Audiences, we also want to make sure that our ads meet the potential interest of users.
Integration of services and content of third parties
Based on our legitimate interests (ie interest in the analysis, optimization and economic operation of our online offer within the meaning of Art. 6 para. 1 lit.f DSGVO), we make use of content or services offered by third-party providers in order to provide their content and services Integrate services such as videos or fonts (collectively referred to as "content").
This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user's device and may include, but is not limited to, technical information about the browser and operating system, referring web pages, visit time, and other information regarding the use of our online offer.
We embed the videos of the platform "YouTube" of the provider Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Data protection: https://www.google.com/policies/privacy/, Opt-out: https://adssettings.google.com/authenticated.