Privacy Policy

Last Updated 09/2023

Introduction

This Privacy Policy (the “policy”) explains how 44.moles GmbH (“we”, “us”, “our”) collects, uses and protects your personal data in accordance with applicable EU data protection laws, in particular the General Data Protection Regulation (GDPR). We are committed to protecting your privacy and ensuring that your personal data is processed fairly and lawfully. The policy relates to our processing of your personal data when you visit our website, contact us or use our services.

The policy inter alia describes your data subjects rights, including a right to object to some of the processing activities. More information about your rights, and how to exercise them, is set out in section 8 below.

Contents:

  • Who will be processing your personal data?

  • Collection of your personal data

  • How we collect your personal data

  • Purposes of processing your personal data and applicable legal basis

  • With whom do we share your personal data

  • International transfer of your personal data

  • Storage duration of your personal data

  • Automated decision making

  • Your data subjects rights

  • Explanation of cookies we use on our website

  • Types of cookies we use

  • Lifespan of the cookies in use

  • Managing cookies

  • Updates to this policy

  • Contact us

1. Who will be processing your personal data?

With respect to the processing activities subject to the policy the data controller is 44.moles GmbH.

Please find the contact details of our data protection officers and further information how to reach us in section 14 below.

2. Collection of your personal data

We collect the following categories of personal data about you when you visit our website, contact us, or use our services:

Usage data:

  • Your geolocation

  • Information which web browser you are using when viewing our website

  • Device and operating system of the device you are using when viewing our website

  • From which visitor channel (e.g., direct entry, search engine etc.) you reached our website

  • Links you clicked on our website

  • Time you spent on our website

General Data

  • Your contact details (e.g. name, email address) in case you shared them

  • Platform profile details (username, email address, password) in case you registered for such account

  • Your personal data that you share in a message with us

3. How we collect your personal data

We collect your personal data directly from you when you:

  • Visit our website

  • Register to create a profile on our platform

  • Use or view our website via your browser’s cookies

4. Purposes of processing your personal data and applicable legal basis

We use your personal data for the following purposes:

  • To provide you with our products or services;

  • To respond to your inquiries or requests;

  • To communicate with you about our products or services;

  • To improve our products or services (including our website);

  • To ensure the safety of our systems and networks

  • To advertise our products or services

For the processing of your personal data for each of the mentioned purposes we rely on one of the following legal bases:

  • To fulfil a contract we might have concluded with you (Art. 6(1)(b) GDPR)

  • Your consent should you have provided it (Art. 6(1)(a) GDPR)

  • Our legitimate interests (Art. 6(1)(f) GDPR) in ensuring the safety of our IT infrastructure,

  • Processing your personal data is necessary to comply with a legal obligation we are subject to (Art. 6(1)(c) GDPR)

We do not sell or rent your personal data to third parties.

5. With whom do we share your personal data?

Payment service provider, IT Service Providers, analytic service provider

6. International transfer of your personal data

If you are located in the EU, we may transfer personal data collected from you in connection with the purposes set out above to recipients located in countries outside the European Economic Area ("EEA") (including in the US). Please note that countries outside the EEA may not provide the same level of data protection as the EEA, although the collection, storage and use of your personal data will still be subject to this policy.

When transferring personal data outside the EEA, we will:

- incorporate the standard data protection clauses (“SCC”) adopted by the European Commission for transfers of personal data outside the EEA (where applicable) into our contracts with the recipients (these are the clauses adopted under Article 46(2) GDPR - you can obtain a copy of such standard data protection clauses by sending a request to [email protected]; or

- ensure that the country in which your personal data is to be processed has been found to be "adequate" by the European Commission under Article 45 of the GDPR (where applicable).

For more information on the SCC please see here and on the Third Countries for which the European Commission issued and adequacy decision please see here.

7. Storage duration of your personal data

Generally, we store your personal data for as long as is necessary to fulfil the purposes for which we collected it. Against this background we store your General Data as long as you have a profile with us any and your Usage Data not longer than for three months. Longer storage periods might apply , however, if we have to adhere to statutory retention periods or if this is necessary to defend us against or raise legal claims.

8. Automated decision making

We do not use your personal data for automated decision making.

9. Your data subjects rights

We would like to ensure that you are fully aware of all your data protection rights. In accordance with applicable laws, you have the right to in particular object to the processing of your personal data by us in certain circumstances, if we process your data on the basis of Art.6 (1) (e) or (f) GDPR (including profiling) (Art. 21 (1) GDPR), or if we process your data for direct marketing purposes (Art. 21 (2) GDPR).

generally to:

Access personal data about you, including: (i) confirming whether we are processing your personal data; (ii) obtaining access to or a copy of your personal data (Art. 15 GDPR);

Request correction of your personal data where it is inaccurate, incomplete or outdated. In some cases, we may provide self-service tools that enable you to update your personal data (Art. 16 GDPR);

Request deletion of your personal data when processing is based on your consent or when processing is unnecessary, excessive or noncompliant (Art. 17 GDPR);

Request restriction our processing of your personal data under certain circumstances (Art. 18 GDPR);

Request data portability and receive an electronic copy of personal data that you have provided to us (Art. 20 GDPR);

Request the review of decisions taken exclusively based on automated processing if that could affect data subject rights.

Withdraw consent, which you may have provided for certain processing activities at any time (Art. 7 (3) GDPR). If you ask to withdraw your consent to us processing your personal data, this will not affect any processing which has already taken place at that time. If you want to withdraw your consent please contact us (see section 14 below).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. If you have unresolved concerns, you have the right to complain to a competent data protection authority. Please note the competence for complaints is divided among different data protection authorities in Germany. Please find a list of the DPAs of the German Federal States here.

If you would like to exercise any of these rights, please contact us at our email noted in section 14 below.

10. Explanation of the cookies we use on our website

Cookies are small data files that are stored on your computer or mobile device by a website’s server when it is used to visit our website. Cookies generally contain information that is associated with your web browser, information such as website preferences, login information, or a user ID. This information enables online services to recognize you as you interact with or revisit the service. They are widely used to make websites work more efficiently, as well as to provide information to the owners of the site. Cookies can be “session” or “persistent”. Session cookies are automatically deleted from your computer or device when you close your browser. While persistent cookies remain stored on your computer or device until they expire (which may be the case after weeks or in certain cases even years) or are deleted by you. “First party cookies” are cookies that are set by us.

11. Types of cookies we use

We use essential cookies when you interact with our website as described below:

Essential cookies: These cookies are essential for the operation of our website and cannot be disabled in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms. Essential cookies are also used to monitor service technical performance to ensure our services are functioning properly. We also use essential cookies to maintain the security and stability of our services. Because these cookies are necessary to the security and functionality of our services, they cannot be switched off.

Performance cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. Regarding this category we use Google Analytics which a is a web analytics tool we use to track and analyse the performance of our website. We do not use this tool to identify you directly, but only to understand which segments, age groups or residents of which country are most likely to visit our site. You can find more information about Google and their tools at this link: https://support.google.com/analytics/answer/4597324?hl=en

Functional cookies: These cookies enable the website to provide enhanced functionality and personalization. For example, remembering which pages you visited and personalise your experience based on this.

Advertising cookies: These cookies enable us to find out your preferences and better tailor advertising for you. Tracking mechanisms we and our partners are able to show you offerings based on your interests, resulting from an analysis of your user behaviour. Regarding this category we use LinkedIn Insight Tag, which helps us to improve our advertising and content management. For more information, please see this link: https://www.linkedin.com/help/lms/answer/a427660.

The table below lists detailed information on the cookies we use:

COOKIE KEYDOMAINPATHCOOKIE TYPEEXPIRATIONDESCRIPTIONPHPSESSID44moles.com/First-PartySessionCookie generated by applications based on the PHP language. This is a general purpose identifier used to maintain user session variables.
It is normally a random generated number, how it is used can be specific to the site, but a good example is maintaining a logged-in status for a user between pages.__stripe_mid44moles.com/First-Party1 yearFor fraud detection, Stripe.js uses cookies, including `__stripe_mid`, `__stripe_sid`, and `m`, to collect signals differentiating legitimate behavior from fraudulent behavior. For example, fraudsters and bots often spend less time on Business Users’ pages than legitimate End Customers. We are able to detect this behavior and use it in evaluating the risk that a transaction is fraudulent.__stripe_sid44moles.com/First-Party30 minutesFor fraud detection, Stripe.js uses cookies, including `__stripe_mid`, `__stripe_sid`, and `m`, to collect signals differentiating legitimate behavior from fraudulent behavior. For example, fraudsters and bots often spend less time on Business Users’ pages than legitimate End Customers. We are able to detect this behavior and use it in evaluating the risk that a transaction is fraudulent.mm.stripe.com/Third-Party1 year 1 monthFor fraud detection, Stripe.js uses cookies, including `__stripe_mid`, `__stripe_sid`, and `m`, to collect signals differentiating legitimate behavior from fraudulent behavior. For example, fraudsters and bots often spend less time on Business Users’ pages than legitimate End Customers. We are able to detect this behavior and use it in evaluating the risk that a transaction is fraudulent.__cf_bm.44moles.com/First-party30 minutesThis cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website._ga.44moles.com/Third-party1 year 1 monthThis cookie name is associated with Google Universal Analytics - which is a significant update to Google's more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports._ga_KVJ39WD7EP.44moles.com/Third-party1 year 1 monthThis cookie is used by Google Analytics to persist session state.isShowAboutUsHeroPopUp.44moles.com/First-partySessionThis cookie is used if the about us pop up is already shown or not.

12. Lifespan of the cookie in use

We store cookies in your browser for the length of your browsing session or as indicated in table above.

13. Managing cookies

You can manage cookies by changing your browser settings to block or delete cookies. However, if you do so, some or all of our website may not function properly. For more information about how to manage cookies, please refer to your browser's help section.

14. Updates to this policy

We may update this Policy from time to time to reflect changes to our practices or for other operational, legal or regulatory reasons. We encourage you to periodically review this page for the latest information on our privacy practices.

15. Contact us

44.moles GmbH:

Reinhard-Rube-Straße 4, 37077 Göttingen, Germany

Email: [email protected]

Telephone: +49 1520 4106040

You can reach our data protection officer here:

Name: Kivanc Semen

E-mail: [email protected]

Mobile: +49 897 400 458 40