Privacy

Scope of Application
This data protection declaration informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online offer and the websites, functions and content associated with it, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer"). With regard to the terms used, such as "processing" or "controller", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
Responsible
Seven Whys Ltd.
Kinyra 28, Office 303
8011 Paphos, Cyprus
Types of data processed
- Inventory data (e.g., names, addresses).
- Contact data (e.g., email, phone numbers).
- Content data (e.g., text input, photographs, videos).
- Usage data (e.g., web pages visited, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).
Categories of data subjects
Visitors and users of the online offer (hereinafter we also refer to the data subjects collectively as "users").
Purpose of processing
- Provision of the online offer, its functions and contents.
- Answering contact requests and communication with users.
- Security measures.
- Reach measurement/marketing
Relevant legal bases
In accordance with Art. 13 GDPR, we inform you about the legal bases of our data processing activities. If the legal basis is not mentioned in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 GDPR, the legal basis for processing to fulfill our services and carry out contractual measures and respond to inquiries is Art. 6(1)(b) GDPR, the legal basis for processing to fulfill our legal obligations is Art. 6(1)(c) GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6(1)(f) GDPR. In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) lit. d GDPR serves as the legal basis.
Security measures
We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk in accordance with Article 32 of the GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, entry into, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, deletion of data, and response to data compromise. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings (Article 25 of the GDPR).
Cooperation with processors and third parties
If, in the course of our processing, we disclose data to other persons and companies (order processors or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is required for the performance of the contract pursuant to Art. 6 (1) lit. b GDPR), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we commission third parties with the processing of data on the basis of a so-called "order processing agreement", this is done on the basis of Art. 28 GDPR.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using third-party services or disclosing, or transferring data to third parties, this is only done if it is done to fulfill our (pre)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or allow the processing of data in a third country only if the special requirements of Art. 44 et seq. GDPR are met. This means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection that corresponds to the EU (e.g. for the USA by the "Privacy Shield") or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").
Right of the data subjects
You have the right to request confirmation as to whether or not data in question is being processed and to be informed of such data, as well as to receive further information and a copy of the data in accordance with Article 15 of the GDPR.

You have according to. Art. 16 GDPR the right to request the completion of the data concerning you or the correction of incorrect data concerning you.

You have the right, in accordance with Art. 17 GDPR, to request that data concerning you be deleted without delay, or alternatively, in accordance with Art. 18 GDPR, to request restriction of the processing of the data.

You have the right to request that the data concerning you that you have provided to us be received in accordance with Art. 20 GDPR and to request that it be transferred to other data controllers.

You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 GDPR.
Right of revocation
You have the right to revoke given consents according to Art. 7 para. 3 GDPR with effect for the future
Right of objection
You may object at any time to the future processing of data relating to you in accordance with Article 21 DSGVO. The objection can be made in particular against processing for direct marketing purposes.
Right of objection
The data processed by us will be deleted or restricted in its processing in accordance with Articles 17 and 18 GDPR. Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.
Business related processing
In addition we process

- Contract data (e.g., subject matter of contract, term, customer category).
- Payment data (e.g., bank details, payment history) of our customers, prospective customers and business partners for the purpose of providing contractual services, service and customer care.
Agency services
We process the data of our customers within the scope of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services and training services.

In this context, we process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of contract, term), payment data (e.g., bank details, payment history), usage data and metadata (e.g., in the context of evaluating and measuring the success of marketing measures). As a matter of principle, we do not process special categories of personal data, unless these are components of commissioned processing. Data subjects include our customers, prospective customers as well as their customers, users, website visitors or employees as well as third parties. The purpose of the processing is the provision of contractual services, billing and our customer service. The legal basis for the processing results from Art. 6 para. 1 lit. b GDPR (contractual services), Art. 6 para. 1 lit. f GDPR (analysis, statistics, optimization, security measures). We process data that are necessary for the justification and fulfillment of the contractual services and point out the necessity of their indication. Disclosure to external parties only takes place if it is necessary in the context of an order. When processing the data provided to us as part of an order, we act in accordance with the instructions of the client as well as the legal requirements of a contract processing pursuant to Art. 28 GDPR and do not process the data for any other purposes than those specified in the order.
Administration, Accounting, Contact management
We process data in the context of administrative tasks as well as organization of our operations, financial accounting and compliance with legal obligations, such as archiving. In this context, we process the same data that we process in the course of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information mentioned in these processing activities.

In this context, we disclose or transfer data to the tax authorities, consultants, such as tax advisors or auditors, as well as other fee offices and payment service providers.

Furthermore, based on our business interests, we store information on suppliers, event organizers and other business partners, e.g. for the purpose of contacting them at a later date. This data, most of which is company-related, is generally stored permanently.
Administration, Accounting, Contact management
We process data in the context of administrative tasks as well as organization of our operations, financial accounting and compliance with legal obligations, such as archiving. In this context, we process the same data that we process in the course of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information mentioned in these processing activities.

In this context, we disclose or transfer data to the tax authorities, consultants, such as tax advisors or auditors, as well as other fee offices and payment service providers.

Furthermore, based on our business interests, we store information on suppliers, event organizers and other business partners, e.g. for the purpose of contacting them at a later date. This data, most of which is company-related, is generally stored permanently.
Contacting
When contacting the provider (for example, via contact form or e-mail), the user's details are stored for the purpose of processing the request and in the event that follow-up questions arise.

The use of published postal addresses, telephone or fax numbers and email addresses for marketing purposes is prohibited, offenders sending unwanted spam messages will be punished. We expressly reserve the right to take legal action against the senders of so-called spam mails in the event of violations of this prohibition.

When users leave comments or other contributions, their IP addresses may be stored for 7 days on the basis of our legitimate interests as defined in Art. 6 (1) lit. f. GDPR are stored for 7 days. This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.

Furthermore, we reserve the right, on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. GDPR, to process the information of the users for the purpose of spam detection.

On the same legal basis, we reserve the right, in the case of surveys, to store the IP addresses of users for their duration and to use Cookis to avoid multiple votes.

The data provided in the context of comments and contributions will be permanently stored by us until the user objects.
Hosting
uberspace is used for mail hosting. An order processing contract has been concluded with the hosting provider.

Framer is used for web hosting.

The hosting services used by us serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services, which we use for the purpose of operating this online offer.

In doing so, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer pursuant to Art. 6 (1) lit. f DSGVO in conjunction with Art. 28 DSGVO. Art. 28 DSGVO (conclusion of order processing contract).
Logfiles
We, or rather our hosting provider, collects on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR data about each access to the server on which this service is located (so-called server log files). The IP addresses for access are shortened by the hosting provider and no longer allow personal information.

Privacy

Scope of Application
This data protection declaration informs you about the nature, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online offer and the websites, functions and content associated with it, as well as external online presences, such as our social media profiles (hereinafter collectively referred to as "online offer"). With regard to the terms used, such as "processing" or "controller", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).
Responsible
Seven Whys Ltd.
Kinyra 28, Office 303
8011 Paphos, Cyprus
Types of data processed
- Inventory data (e.g., names, addresses).
- Contact data (e.g., email, phone numbers).
- Content data (e.g., text input, photographs, videos).
- Usage data (e.g., web pages visited, interest in content, access times).
- Meta/communication data (e.g., device information, IP addresses).
Categories of data subjects
Visitors and users of the online offer (hereinafter we also refer to the data subjects collectively as "users").
Purpose of processing
- Provision of the online offer, its functions and contents.
- Answering contact requests and communication with users.
- Security measures.
- Reach measurement/marketing
Relevant legal bases
In accordance with Art. 13 GDPR, we inform you about the legal bases of our data processing activities. If the legal basis is not mentioned in the privacy policy, the following applies: The legal basis for obtaining consent is Art. 6(1)(a) and Art. 7 GDPR, the legal basis for processing to fulfill our services and carry out contractual measures and respond to inquiries is Art. 6(1)(b) GDPR, the legal basis for processing to fulfill our legal obligations is Art. 6(1)(c) GDPR, and the legal basis for processing to protect our legitimate interests is Art. 6(1)(f) GDPR. In the event that vital interests of the data subject or another natural person make processing of personal data necessary, Art. 6 (1) lit. d GDPR serves as the legal basis.
Security measures
We take appropriate technical and organizational measures to ensure a level of protection appropriate to the risk in accordance with Article 32 of the GDPR, taking into account the state of the art, the costs of implementation and the nature, scope, circumstances and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons.

The measures include, in particular, safeguarding the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, entry into, disclosure of, assurance of availability of and segregation of the data. Furthermore, we have established procedures to ensure the exercise of data subjects' rights, deletion of data, and response to data compromise. Furthermore, we already take the protection of personal data into account during the development and selection of hardware, software and processes, in accordance with the principle of data protection through technology design and through data protection-friendly default settings (Article 25 of the GDPR).
Cooperation with processors and
third parties
If, in the course of our processing, we disclose data to other persons and companies (order processors or third parties), transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is required for the performance of the contract pursuant to Art. 6 (1) lit. b GDPR), you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we commission third parties with the processing of data on the basis of a so-called "order processing agreement", this is done on the basis of Art. 28 GDPR.
Cooperation with processors and
third parties
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using third-party services or disclosing, or transferring data to third parties, this is only done if it is done to fulfill our (pre)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or allow the processing of data in a third country only if the special requirements of Art. 44 et seq. GDPR are met. This means that the processing is carried out, for example, on the basis of special guarantees, such as the officially recognized determination of a level of data protection that corresponds to the EU (e.g. for the USA by the "Privacy Shield") or compliance with officially recognized special contractual obligations (so-called "standard contractual clauses").
Cooperation with processors and
third parties
You have the right to request confirmation as to whether or not data in question is being processed and to be informed of such data, as well as to receive further information and a copy of the data in accordance with Article 15 of the GDPR.

You have according to. Art. 16 GDPR the right to request the completion of the data concerning you or the correction of incorrect data concerning you.

You have the right, in accordance with Art. 17 GDPR, to request that data concerning you be deleted without delay, or alternatively, in accordance with Art. 18 GDPR, to request restriction of the processing of the data.

You have the right to request that the data concerning you that you have provided to us be received in accordance with Art. 20 GDPR and to request that it be transferred to other data controllers.

You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 GDPR.
Cooperation with processors and
third parties
You have the right to revoke given consents according to Art. 7 para. 3 GDPR with effect for the future
Cooperation with processors and
third parties
You may object at any time to the future processing of data relating to you in accordance with Article 21 DSGVO. The objection can be made in particular against processing for direct marketing purposes.
Cooperation with processors and
third parties
The data processed by us will be deleted or restricted in its processing in accordance with Articles 17 and 18 GDPR. Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted. I.e. the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.
Cooperation with processors and
third parties
In addition we process

- Contract data (e.g., subject matter of contract, term, customer category).
- Payment data (e.g., bank details, payment history) of our customers, prospective customers and business partners for the purpose of providing contractual services, service and customer care.
Cooperation with processors and
third parties
We process the data of our customers within the scope of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services and training services.

In this context, we process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of contract, term), payment data (e.g., bank details, payment history), usage data and metadata (e.g., in the context of evaluating and measuring the success of marketing measures). As a matter of principle, we do not process special categories of personal data, unless these are components of commissioned processing. Data subjects include our customers, prospective customers as well as their customers, users, website visitors or employees as well as third parties. The purpose of the processing is the provision of contractual services, billing and our customer service. The legal basis for the processing results from Art. 6 para. 1 lit. b GDPR (contractual services), Art. 6 para. 1 lit. f GDPR (analysis, statistics, optimization, security measures). We process data that are necessary for the justification and fulfillment of the contractual services and point out the necessity of their indication. Disclosure to external parties only takes place if it is necessary in the context of an order. When processing the data provided to us as part of an order, we act in accordance with the instructions of the client as well as the legal requirements of a contract processing pursuant to Art. 28 GDPR and do not process the data for any other purposes than those specified in the order.
Cooperation with processors and
third parties
We process data in the context of administrative tasks as well as organization of our operations, financial accounting and compliance with legal obligations, such as archiving. In this context, we process the same data that we process in the course of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information mentioned in these processing activities.

In this context, we disclose or transfer data to the tax authorities, consultants, such as tax advisors or auditors, as well as other fee offices and payment service providers.

Furthermore, based on our business interests, we store information on suppliers, event organizers and other business partners, e.g. for the purpose of contacting them at a later date. This data, most of which is company-related, is generally stored permanently.
Cooperation with processors and
third parties
We process data in the context of administrative tasks as well as organization of our operations, financial accounting and compliance with legal obligations, such as archiving. In this context, we process the same data that we process in the course of providing our contractual services. The processing bases are Art. 6 para. 1 lit. c. GDPR, Art. 6 para. 1 lit. f. GDPR. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organization, archiving of data, i.e. tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information mentioned in these processing activities.

In this context, we disclose or transfer data to the tax authorities, consultants, such as tax advisors or auditors, as well as other fee offices and payment service providers.

Furthermore, based on our business interests, we store information on suppliers, event organizers and other business partners, e.g. for the purpose of contacting them at a later date. This data, most of which is company-related, is generally stored permanently.
Cooperation with processors and
third parties
When contacting the provider (for example, via contact form or e-mail), the user's details are stored for the purpose of processing the request and in the event that follow-up questions arise.

The use of published postal addresses, telephone or fax numbers and email addresses for marketing purposes is prohibited, offenders sending unwanted spam messages will be punished. We expressly reserve the right to take legal action against the senders of so-called spam mails in the event of violations of this prohibition.

When users leave comments or other contributions, their IP addresses may be stored for 7 days on the basis of our legitimate interests as defined in Art. 6 (1) lit. f. GDPR are stored for 7 days. This is done for our security in case someone leaves unlawful content in comments and posts (insults, prohibited political propaganda, etc.). In this case, we ourselves can be prosecuted for the comment or post and are therefore interested in the identity of the author.

Furthermore, we reserve the right, on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f. GDPR, to process the information of the users for the purpose of spam detection.

On the same legal basis, we reserve the right, in the case of surveys, to store the IP addresses of users for their duration and to use Cookis to avoid multiple votes.

The data provided in the context of comments and contributions will be permanently stored by us until the user objects.
Cooperation with processors and
third parties
uberspace is used for mail hosting. An order processing contract has been concluded with the hosting provider.

Framer is used for web hosting.

The hosting services used by us serve to provide the following services: Infrastructure and platform services, computing capacity, storage space and database services, e-mail dispatch, security services and technical maintenance services, which we use for the purpose of operating this online offer.

In doing so, we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors of this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer pursuant to Art. 6 (1) lit. f DSGVO in conjunction with Art. 28 DSGVO. Art. 28 DSGVO (conclusion of order processing contract).
Cooperation with processors and
third parties
We, or rather our hosting provider, collects on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. GDPR data about each access to the server on which this service is located (so-called server log files). The IP addresses for access are shortened by the hosting provider and no longer allow personal information.