Privacy Policy
effective as of the 1st of July 2020 (version v1.1.0)
XIPPIOS UG (haftungsbeschränkt) ("Us", "We", or "Our") operates the Website "www.xippios.com" (hereinafter referred to as the "Service"). This page informs You of Our policies regarding the collection, use and disclosure of personal data when You use Our Service and the choices You have associated with that data. We use your data to provide and improve the Service.
By using Our Service, You agree to the collection and use of information in accordance with this policy.
Please read this Privacy Policy carefully before using Our Service.
Definitions
- Cookies are small files stored on your device (computer or mobile device).
- Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, We are a Data Controller of your Personal Data.
- Data Processors (or Service Providers) are any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
- Data Subject (or User) is any living individual who is using Our Service and is the subject of Personal Data.
- Personal Data means data about a living individual who can be identified from those data (or from those and other information either in Our possession or likely to come into Our possession).
- Service refers to and includes the Website.
- Usage Data is the data collected automatically either generated by the use of the Service or from the service infrastructure itself (for example, the duration of a page visit).
- We, Us or Our refers to XIPPIOS UG (haftungsbeschränkt), Ditmar-Koel-Straße 12, 20459 Hamburg.
- Website refers to Our internet presence provided under "www.xippios.com".
- You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve Our Service to You.
Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You ("Personal Data"). Personally identifiable information may include, but is not limited to:
- First and last name
- Email address
- Telephone number
- Instant Messenger handle
- Address (including street, city, postal code, province, state, country)
- Cookies and Usage Data
We may use your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
Usage Data
We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of Our Service that You visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking and Cookies Data
We may use cookies and similar tracking technologies to track the activity on Our Service and We hold certain information.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze Our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if You do not accept cookies, You may not be able to use some portions of Our Service.
Examples of Cookies We may use:
- Session Cookies may be used to operate Our Service.
- Preference Cookies may be used to remember your preferences and various settings.
- Security Cookies may be used for security purposes.
Use of Collected Data
We may use the collected data for various purposes:
- To provide and maintain Our Service
- To notify You about changes to Our Service
- To allow You to participate in interactive features of Our Service when You choose to do so
- To provide customer support
- To gather analysis or valuable information so that We can improve Our Service
- To monitor the usage of Our Service
- To detect, prevent and address technical issues
- To provide You with news, special offers and general information about other goods, services and events which We offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information
General Data Protection Regulation (GDPR)
If You are from the European Economic Area (EEA), Our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data We collect and the specific context in which We collect it.
We may process your Personal Data because:
- We need to perform a contract with You
- You have given Us permission to do so
- The processing is in Our legitimate interests and it is not overridden by your rights
- For payment processing purposes
- To comply with the law
Retention of Collected Data
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with Our legal obligations (for example, if We are required to retain your data to comply with applicable laws), resolve disputes and enforce Our legal agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer periods.
Transfer of Collected Data
Your information, including Personal Data, may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If You are located outside Germany and choose to provide information to Us, please note that We transfer the data, including Personal Data, to Germany and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.
Disclosure of Collected Data
Business Transaction
If We are involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
Legal Requirements
We may disclose your Personal Data in the good faith and belief that such action is necessary
- to comply with a legal obligation,
- to protect and defend Our rights or property,
- to prevent or investigate possible wrongdoing in connection with the Service,
- to protect the personal safety of users of the Service or the public, and
- to protect against legal liability.
Security of Collected Data
The security of your data is important to Us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect your Personal Data, We cannot guarantee its absolute security.
Data Protection Rights under the GDPR
If You are a resident of the European Economic Area (EEA), You have certain data protection rights. We aim to take reasonable steps to allow You to correct, amend, delete or limit the use of your Personal Data.
If You wish to be informed about what Personal Data We hold about You and if You want it to be removed from Our systems, please contact Us.
In certain circumstances, You have the following data protection rights:
- The right to access, update or delete the information We have on You. Whenever made possible, You can access, update or request deletion of your Personal Data directly within your account settings section. If You are unable to perform these actions yourself, please contact Us to assist You.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to Our processing of your Personal Data.
- The right of restriction. You have the right to request that We restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information We have on You in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where We relied on your consent to process your personal information.
Please note that We may ask You to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about Our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
Service Providers
We may employ third-party companies and individuals to facilitate Our Service ("Service Providers"), provide the Service on Our behalf, perform Service-related services or assist Us in analyzing how Our Service is used.
These third-parties have access to your Personal Data only to perform these tasks on Our behalf and are obligated not to disclose or use it for any other purpose.
Analytics
We may use third-party Service Providers to monitor and analyze the use of Our Service.
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Google Analytics
Google Analytics web analytics service is provided by Google, Inc.
The collected data is used to track and report website traffic and to monitor the use of Our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Behavioral Remarketing
We may use remarketing services to advertise on third-party websites to You after You visited Our Service. We and Our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to Our Service.
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Google Ads (AdWords)
Google Ads (AdWords) remarketing service is provided by Google, Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
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Twitter
Twitter remarketing service is provided by Twitter, Inc.
You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405
You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy
Email Delivery
We may use email delivery services to manage and send emails and newsletters and to organize and analyze their dispatch and distribution. We currently use MailGun as Our primary email delivery service.
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MailGun
MailGun email delivery service is provided by Mailgun Technologies, Inc.
While MailGun maintains Standard Contractual Clauses (SCCs) in their agreements, We specifically choose to use MailGun's EU server infrastructure. As such all applicable data shall be processed and stored within the European Economic Area (EEA) only.
Standard Contractual Clauses (SCCs) are and, as per the European Commission Court of Justice (CJEU) ruling, continue to be a valid legal mechanism to transfer data under the GDPR. MailGun uses these SCCs for all their data transfers, including transfers with sub-processors that processed customers’ personal data.
For details on the privacy practices and policies of MailGun, please visit their Privacy Policy page: https://www.mailgun.com/privacy-policy/
We have entered into a Data Processing Agreement with MailGun. As part of this agreement, MailGun is required to protect your data and is prohibited from disclosing your data to third-parties.
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SparkPost
SparkPost email delivery service is provided by Message Systems, Inc.
While SparkPost is certified under the EU-US Privacy Shield, We specifically choose to use SparkPost's EU server infrastructure. As such all applicable data shall only be processed and stored within the European Economic Area (EEA) only.
The Privacy Shield is an agreement between the European Union (EU) and the US to ensure compliance with European privacy standards in the United States.
For details on the privacy practices and policies of SparkPost, please visit their Privacy Policy page: https://www.sparkpost.com/policies/privacy
We have entered into a data processing agreement with SparkPost. As part of this agreement, SparkPost is required to protect your data and is prohibited from disclosing your data to third-parties.
Payments
We may provide paid services within the Service. In that case, We may use third-party services for payment processing ("Payment Processors").
We will not store or collect your payment card details. That information is provided directly to Our third-party Payment Processors whose use of your personal information is governed by their Privacy Policy. These Payment Processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American
Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
The payment processors We may work with are:
Links to Other Sites
Our Service may contain links to other sites that are not operated by Us. If You click a third-party link, You will be directed to that third-party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
Children's Privacy
Our Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that your Child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from children without verification of parental consent, We take steps to remove that information from Our servers.
Changes to This Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If You have any questions about this Privacy Policy, please contact Us via email at privacy@xippios.com.