1. introduction

In the following, we provide information about the processing of personal data when using

our website https://varify.io
our profiles in social media.

Personal data is all data that can be related to a specific natural person, e.g. their name or IP address.

1.1 Contact details

The controller pursuant to Art. 4 (7) of the EU General Data Protection Regulation (GDPR) is Varify GmbH, Südliche Münchner Straße 55, 82031 Grünwald, Germany, e-mail: [email protected]. We are legally represented by Thomas Kraus.

Our data protection officer is Martin Bastius via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, e-mail: [email protected] reachable.

1.2 Scope of data processing, processing purposes and legal bases

The scope of data processing, processing purposes and legal bases are explained in detail below. The legal basis for data processing is generally as follows:

Art. 6 para. 1 sentence 1 lit. a GDPR serves as the legal basis for processing operations for which we obtain consent.
6 para. 1 sentence 1 lit. b GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. if a site visitor purchases a product from us or we perform a service for them. This legal basis also applies to processing that is necessary for pre-contractual measures, for example in the case of inquiries about our products or services.
Art. 6 para. 1 sentence 1 lit. c GDPR applies if we fulfill a legal obligation by processing personal data, as may be the case in tax law, for example.
Art. 6 para. 1 sentence 1 lit. f GDPR serves as the legal basis if we can rely on legitimate interests to process personal data, e.g. for cookies that are required for the technical operation of our website.

1.3 Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the EEA, adequacy decisions of the EU Commission pursuant to Art. 45 para. 3 GDPR guarantee the security of the data during transfer, insofar as these exist, as is the case, for example, for the UK, Canada and Israel.

In the case of data transfer to service providers in the USA, the legal basis for data transfer is an adequacy decision by the EU Commission if the service provider is also certified under the EU-US Data Privacy Framework.

In other cases (e.g. if there is no adequacy decision), the legal basis for data transfer is usually standard contractual clauses, i.e. unless we indicate otherwise. These are a set of rules adopted by the EU Commission and form part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they guarantee the security of data transfer. Many of the providers have provided contractual guarantees that go beyond the standard contractual clauses and protect the data beyond the standard contractual clauses. These are, for example, guarantees regarding the encryption of the data or regarding the obligation of the third party to inform the data subject if law enforcement agencies wish to access data.

1.4 Storage period

Unless expressly stated in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its 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 will be blocked and not processed for other purposes. This applies, for example, to data that we must retain for commercial or tax law reasons.

1.5 Rights of the data subjects

Data subjects have the following rights vis-à-vis us with regard to their personal data:

Right to information,
Right to rectification or erasure,
Right to restriction of processing,
Right to object to the processing,
Right to data portability,
Right to withdraw consent at any time.

Data subjects also have the right to complain to a data protection supervisory authority about the processing of their personal data. Contact details of the data protection supervisory authorities can be found at https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html.

1.6 Obligation to provide data

In the context of a business relationship or other relationship, customers, interested parties or third parties must only provide us with the personal data that is necessary for the establishment, execution and termination of the business relationship or for the other relationship or that we are legally obliged to collect. Without this data, we will generally have to refuse to conclude a contract or provide a service or will no longer be able to perform an existing contract or other relationship.

Mandatory information is marked as such.

1.7 No automated decision-making in individual cases

In principle, we do not use fully automated decision-making in accordance with Article 22 GDPR to establish and implement a business relationship or other relationship. If we use these procedures in individual cases, we will provide separate information about this if this is required by law.

1.8 Making contact

When you contact us, e.g. by email or telephone, the data you provide us with (e.g. names and email addresses) will be stored by us in order to answer your questions. The legal basis for the processing is our legitimate interest (Art. 6 para. 1 sentence 1 lit. f GDPR) in answering inquiries addressed to us. We delete the data collected in this context after storage is no longer necessary or restrict processing if there are statutory retention obligations.

1.9 Customer surveys

From time to time, we conduct customer surveys to get to know our customers and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so that the legal basis for the associated data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We delete the data once the results of the surveys have been evaluated.

2nd Newsletter

Interested parties have the option of subscribing to a free newsletter. We process the data provided during registration exclusively for the purpose of sending the newsletter. Registration takes place by selecting the corresponding field on our website, by ticking the corresponding field in a paper document or by another clear action, whereby interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6 para. 1 sentence 1 lit. a GDPR. Consent can be withdrawn at any time, e.g. by clicking on the corresponding link in the newsletter or by sending a message to the email address provided above. The processing of the data until revocation remains lawful even in the event of revocation.

Based on the consent of the recipients (Art. 6 para. 1 sentence 1 lit. a GDPR), we also measure the opening and click rate of our newsletters in order to understand which content is relevant for our recipients.

We send newsletters using the HubSpot tool from the provider HubSpot, Inc., 25 1st Street Cambridge, MA 0214, USA (privacy policy: https://legal.hubspot.com/de/privacy-policy). The provider processes content, usage, meta/communication data and contact data in the EU.

3. data processing on our website

3.1 Note for website visitors from Germany

Our website stores information in the terminal equipment of website visitors (e.g. cookies) or accesses information that is already stored in the terminal equipment (e.g. IP addresses). Please refer to the following sections to find out what information this is in detail.

This storage and access takes place on the basis of the following provisions:

Insofar as this storage or access is absolutely necessary for us to provide the service expressly requested by website visitors on our website (e.g. to implement a chatbot used by the website visitor or to ensure the IT security of our website), it is carried out on the basis of Section 25 (2) No. 2 TTDSG.
Otherwise, this storage or access is based on the consent of the website visitor (Section 25 (1) TTDSG).

Downstream data processing is carried out in accordance with the following sections and on the basis of the provisions of the GDPR.

3.2 Informational use of the website

When using the website for informational purposes, i.e. when visitors to the site do not send us information separately, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This is our legitimate interest, so the legal basis is Art. 6 para. 1 sentence 1 lit. f GDPR.

These data are:

IP address
Date and time of the request
Time zone difference to Greenwich Mean Time (GMT)
Content of the request (specific page)
Access status/HTTP status code
Amount of data transferred in each case
Website from which the request comes
Browser
Operating system and its interface
Language and version of the browser software.

This data is also stored in log files. They are deleted when their storage is no longer required, at the latest after 14 days.

3.3 Web hosting and provision of the website

Our website is hosted by Amazon AWS. The provider is Amazon Web Services EMEA Sàrl, Avenue John F. Kennedy 38, 1855 Luxembourg, Luxembourg. The provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data, in the EU. Further information can be found in the provider's privacy policy at https://aws.amazon.com/privacy/.

It is our legitimate interest to provide a website, so that the legal basis for the data processing described is Art. 6 para. 1 sentence 1 lit. f GDPR.

We use the Cloudflare content delivery network for our website. The provider is Cloudflare, Inc, 101 Townsend St., San Francisco, CA 94107, USA. The provider processes the personal data transmitted via the website, e.g. content, usage, meta/communication or contact data, in the USA. Further information can be found in the provider's privacy policy at https://www.cloudflare.com/de-de/privacypolicy/.

We have a legitimate interest in using sufficient storage and delivery capacities in order to ensure optimal data throughput even during high load peaks. The legal basis for the data processing described is therefore Art. 6 para. 1 sentence 1 lit. f GDPR.

The legal basis for the transfer to a country outside the EEA is an adequacy decision. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed because the EU Commission has decided that the third country offers an adequate level of protection as part of an adequacy decision in accordance with Art. 45 (3) GDPR.

3.4 Contact form

When you contact us via the contact form on our website, we store the data requested there and the content of the message.
The legal basis for the processing is our legitimate interest in responding to inquiries addressed to us. The legal basis for the processing is therefore Art. 6 para. 1 sentence 1 lit. f GDPR.
We delete the data arising in this context after storage is no longer required, or restrict processing if there are statutory retention obligations.

3.5 Job advertisements

We publish jobs that are vacant in our company on our website, on pages linked to the website or on third-party websites.
The data provided as part of the application is processed in order to carry out the application process. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88 (1) GDPR in conjunction with Section 26 (1) BDSG. We have marked the data required to carry out the application process accordingly or refer to it. If applicants do not provide this data, we will not be able to process the application.
Further data is voluntary and not required for an application. If applicants provide further information, this is based on their consent (Art. 6 para. 1 sentence 1 lit. a GDPR).

We ask applicants to refrain from providing information on political opinions, religious beliefs and similar sensitive data in their CV and cover letter. They are not required for an application. If applicants nevertheless provide such information, we cannot prevent their processing as part of the processing of the CV or cover letter. Their processing is then also based on the consent of the applicants (Art. 9 para. 2 lit. a GDPR).

Finally, we process applicants' data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 sentence 1 lit. a GDPR.

We pass on the applicants' data to the responsible employees in the HR department, to our processors in the area of recruiting and to the other employees involved in the application process.

If we enter into an employment relationship with the applicant following the application process, we will only delete the data after the employment relationship has ended. Otherwise, we will delete the data no later than six months after rejecting an applicant.

If applicants have given us their consent to use their data for further application procedures, we will only delete their data one year after receipt of the application.

3.6 Booking appointments

Site visitors can book appointments with us on our website. For this purpose, we process meta or communication data in addition to the data entered. We have a legitimate interest in offering interested parties a user-friendly way to make appointments. The legal basis for data processing is therefore Art. 6 para. 1 sentence 1 lit. f GDPR. If we use a tool from a third-party provider for the agreement, the information on this can be found under "Third-party providers".

3.7 Customer account

Visitors to the website can open a customer account on our website. We process the data requested in this context on the basis of the contract concluded with the user. The legal basis for the processing is therefore Art. 6 para. 1 sentence 1 lit. b GDPR.

3.8 Offer of goods and services

We offer goods and services via our website. We process the following data as part of the order process:

Company, first name, surname, street and house number, zip code, city, payment details

The data is processed for the performance of the contract concluded with the respective site visitor (Art. 6 para. 1 sentence 1 lit. b GDPR).

3.9 Payment service provider

To process payments, we use payment processors who are themselves data controllers within the meaning of Art. 4 No. 7 GDPR. Insofar as they receive data and payment data entered by us in the ordering process, we thereby fulfill the contract concluded with our customers (Art. 6 para. 1 sentence 1 lit. b GDPR).

These payment service providers are:

Stripe Payments Europe, Ltd, Ireland

3.10. Technically necessary cookies

Our website uses cookies. Cookies are small text files that are stored in the web browser on the end device of a site visitor. Cookies help to make the website more user-friendly, effective and secure. Insofar as these cookies are necessary for the operation of our website or its functions (hereinafter referred to as "technically necessary cookies"), the legal basis for the associated data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We have a legitimate interest in providing customers and other site visitors with a functional website.
Specifically, we set technically necessary cookies for the following purpose or purposes:

Cookies that adopt language settings
Local storage objects, which are required for the purpose of A/B testing in order to be able to display different variants of the website to page visitors

3.11. Third-party providers

3.11.1 Lead info

We use Leadinfo to identify business opportunities. The provider is Leadinfo B.V., Rivium Quadrant 141, 2909 LC Capelle aan den IJssel, Netherlands. The provider processes meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for processing is Art. 6 para. 1 sentence 1 lit. a GDPR. Processing is carried out on the basis of consent. Data subjects can withdraw their consent at any time, e.g. by contacting us using the contact details provided in our privacy policy. The revocation does not affect the legality of the processing until the revocation.

We delete the data when the purpose for which it was collected no longer applies. Further information can be found in the provider's privacy policy at https://www.leadinfo.com/de/datenschutz/.

3.11.2 Microsoft Clarity

We use Microsoft Clarity to identify business opportunities and for analysis. The provider is Microsoft Ireland Operations, Ltd, One Microsoft Place, South County Business Park, Leopardstown, Dublin 18, D18 P521, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.

The data will be deleted when the purpose of its collection no longer applies and there is no obligation to retain it. Further information can be found in the provider's privacy policy at https://privacy.microsoft.com/de-de/privacystatement.

3.11.3 HubSpot LiveChat

We use HubSpot LiveChat as a live chat. The provider is HubSpot, Inc, 25 1st Street Cambridge, MA 0214, USA. The provider processes usage data (e.g. websites visited, interest in content, access times), content data (e.g. entries in online forms) and meta/communication data (e.g. device information, IP addresses) in the EU.

The data will be deleted when the purpose for which it was collected no longer applies and there are no retention obligations to the contrary. Further information can be found in the provider's privacy policy at https://legal.hubspot.com/de/privacy-policy.

3.11.4 Google Conversion Tag

We use Google Conversion Tag for conversion tracking. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) in the USA.

The legal basis for the transfer to a country outside the EEA are standard contractual clauses. The security of the data transferred to the third country (i.e. a country outside the EEA) is guaranteed by standard data protection clauses issued in accordance with the review procedure pursuant to Art. 93 para. 2 GDPR (Art. 46 para. 2 lit. c GDPR), which we have agreed with the provider.

3.11.5 Google Analytics

We use Google Analytics for analysis. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

3.11.6 Google Maps

We use Google Maps for maps on our website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for transferring data to a country outside the EEA is consent.

We delete the data when the purpose for which it was collected no longer applies. Further information can be found in the provider's privacy policy at https://policies.google.com/privacy?hl=de.

3.11.7 YouTube videos

We use YouTube videos for videos on the website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for transferring data to a country outside the EEA is consent.

Further information can be found in the provider's privacy policy at https://policies.google.com/privacy.

3.11.8 Google Tag Manager

We use Google Tag Manager to display additional tools. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes meta/communication data (e.g. device information, IP addresses) in the USA.

We delete the data when the purpose for which it was collected no longer applies. Further information can be found in the provider's privacy policy at https://policies.google.com/privacy?hl=de.

3.11.9. heyData

We have integrated a data protection seal on our website. The provider is heyData GmbH, Schützenstraße 5, 10117 Berlin, Germany. The provider processes meta/communication data (e.g. IP addresses) in the EU.

The legal basis for processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We have a legitimate interest in providing website visitors with confirmation of our data protection compliance. At the same time, the provider has a legitimate interest in ensuring that only customers with existing contracts use its seals, which is why a mere image copy of the certificate is not a viable alternative to confirmation.

The data is masked after collection so that there is no longer any personal reference. Further information can be found in the provider's privacy policy at https://heydata.eu/datenschutzerklaerung.

3.11.10. CookieFirst

We use CookieFirst for consent management. The provider is Digital Data Solutions B.V., Plantage Middenlaan 42a, 1018 DH Amsterdam. The provider processes meta/communication data (e.g. device information, IP addresses) in the EU.

The legal basis for processing is Art. 6 para. 1 sentence 1 lit. c GDPR. Processing is necessary for compliance with a legal obligation to which we are subject.

The data will be deleted if the purpose of its collection no longer applies and there is no obligation to retain it. Further information can be found in the provider's privacy policy at https://cookiefirst.com/legal/privacy-policy/ available.

3.11.11. Varify.io

We use varify.io for A/B testing. The provider is Varify GmbH, Südliche Münchner Straße 55, 82031 Grünwald, Germany. The provider processes meta/communication data (e.g. device information, IP addresses) in the USA.

The legal basis for processing is our legitimate interest pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR. The processing of the data is technically necessary in order to display different versions of the website to website visitors.

We delete the data when the purpose for which it was collected no longer applies.

3.11.12. Mailgun

We use Mailgun to send transactional emails. The provider is Mailgun Technologies, Inc, 112 E Pecan St Ste 1135, San Antonio, TX, 78205-1509, USA. The provider processes email addresses in the USA.

The legal basis for processing is Art. 6 para. 1 sentence 1 lit. b GDPR. The processing is necessary to fulfill the contract concluded with the user in the context of the customer account.

The legal basis for the transfer to a country outside the EEA is an adequacy decision by the EU Commission and the certification of the provider under the EU-US Privacy Framework. In the event that the decision should be declared invalid, we have concluded standard data protection contractual clauses with the provider (Art. 46 para. 2 lit. c GDPR).

3.11.13. Mapbox

We use Mapbox for localization. The provider is Mapbox, Inc, 50 Beale St floor 9, San Francisco, CA, USA. The provider processes usage data (e.g. websites visited, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.

4. data processing on social media platforms

We are represented on social media networks in order to present our organization and our services. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from their online behavior, which are used, for example, to display advertising on the pages of the networks and elsewhere on the Internet that corresponds to the interests of the users. For this purpose, the network operators store information on user behavior in cookies on the user's computer. It is also possible that the operators may combine this information with other data. Users can find further information and information on how users can object to processing by the site operators in the privacy policies of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, meaning that they process data there. This may result in risks for users, e.g. because the enforcement of their rights is made more difficult or government agencies gain access to the data.

When users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This is our legitimate interest, so the legal basis is Art. 6 para. 1 sentence 1 lit. f GDPR.

4.1 Instagram

We maintain a profile on Instagram. The operator is Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy is available here: https://help.instagram.com/519522125107875.

4.2 Twitter

We maintain a profile on Twitter. The operator is Twitter Inc, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The privacy policy is available here: https://twitter.com/de/privacy. You can object to data processing via the settings for advertisements: https://twitter.com/personalization.

4.3 LinkedIn

We maintain a profile on LinkedIn. The operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy is available here: https://https://www.linkedin.com/legal/privacy-policy?_l=de_DE. You can object to data processing via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

5. changes to this privacy policy

We reserve the right to amend this privacy policy with effect for the future. A current version is always available here.

6. questions and comments

If you have any questions or comments regarding this privacy policy, please do not hesitate to contact us using the contact details above.

7 Google API Compliance

Varify GmbH operates the Varify.io® application and requests access to certain Google user data, primarily to improve our A/B testing analytics capabilities. We utilize data reports from Google Analytics 4 to provide users with detailed comparisons of A/B test groups across various metrics that you can import from GA4. Varify.io® further processes this data to calculate metrics such as uplift and significance, which are crucial for evaluating the effectiveness of different test variants.

In order to accurately measure the results of A/B tests, Varify.io® creates specific audiences in GA4 for each test launched. This process requires access to the following Google API permissions:

https://www.googleapis.com/auth/analytics.readonly
https://www.googleapis.com/auth/analytics.edit
https://www.googleapis.com/auth/analytics

We guarantee a transparent use of your data, which is exclusively aimed at presenting the results of A/B tests and improving your analytical capabilities. Varify GmbH will not use the data for any other purpose than stated and will only retain it for the duration of your active session or until you decide to disconnect. Changes to data access or use that go beyond the original disclosure in our Privacy Policy will result in an update to the policy and will require your renewed consent to those changes.

Varify GmbH is committed to data minimization by only accessing information that is necessary for the services provided and ensuring that permissions are only requested in justified contexts. We do not request access to information that is not required for the functionality of our application.

Your privacy and trust are extremely important to us and we are committed to keeping your Google user data secure and treating it with the highest standards of confidentiality and integrity.

Our use and transfer of information we receive through Google APIs complies with the Google API Services Privacy Policy, including the limited use requirements. For more information, please see the policy here.

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