Privacy statement

1. Introduction

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

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

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

1.1. Contact details

The controller within the meaning of Art. 4(7) of the EU General Data Protection Regulation (GDPR) is Varify GmbH, Südliche Münchner Straße 55, 82031 Grünwald, Germany, e-mail: info@varify.io. We are legally represented by Thomas Kraus.

Our data protection officer is Martin Bastius, who can be reached via heyData GmbH, Schützenstraße 5, 10117 Berlin, www.heydata.eu, e-mail: datenschutz@heydata.eu.

1.2. Scope of data processing, purposes of processing and legal bases

We set out the scope of the data processing, the purposes of processing and the legal bases in detail below. In principle, the following may serve as the legal basis for data processing:

6(1)(a) GDPR serves as our legal basis for processing operations for which we obtain consent.
6(1)(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.
6(1)(c) GDPR applies if, by processing personal data, we fulfill a legal obligation, as may be the case, e.g., under tax law.
6(1)(f) GDPR serves as the legal basis if we can rely on legitimate interests for the processing of personal data, e.g., for cookies that are necessary 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(3) GDPR guarantee the security of the data during the transfer, where such decisions exist, as is the case, e.g., for the United Kingdom, Canada and Israel.

When data is transferred to service providers in the USA, the legal basis for the data transfer is an adequacy decision of the EU Commission if the service provider has additionally been certified under the EU US Data Privacy Framework.

In other cases (e.g., if no adequacy decision exists), the legal basis for the data transfer is, as a rule, i.e., unless we indicate otherwise, standard contractual clauses. These are a set of rules adopted by the EU Commission and form part of the contract with the respective third party. Pursuant to Art. 46(2)(b) GDPR, they ensure the security of the data transfer. Many of the providers have given contractual guarantees that go beyond the standard contractual clauses and protect the data beyond the standard contractual clauses. These are, e.g., guarantees regarding the encryption of the data or regarding an obligation of the third party to notify data subjects if law enforcement authorities wish to access data.

1.4. Storage period

Unless expressly stated in this privacy statement, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and no statutory retention obligations prevent its deletion. 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, e.g., to data that we must retain for reasons of commercial or tax law.

1.5. Rights of data subjects

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

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

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

1.6. Obligation to provide data

Within the scope of a business relationship or other relationship, customers, prospective customers or third parties only need to provide us with the personal data that is necessary for the establishment, performance 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 to 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 individual decision-making

As a matter of principle, we do not use fully automated decision-making pursuant to Article 22 GDPR to establish and perform a business relationship or other relationship. Should we use such procedures in individual cases, we will inform you separately about this, insofar as this is required by law.

1.8. Contacting us

When you contact us, e.g., by e-mail or telephone, the data provided to us (e.g., names and e-mail addresses) will be stored by us in order to answer questions. The legal basis for the processing is our legitimate interest (Art. 6(1)(f) GDPR) in answering inquiries addressed to us. We delete the data arising in this context once storage is no longer necessary, or restrict the processing if statutory retention obligations exist.

1.9. Customer surveys

From time to time, we conduct customer surveys in order 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(1)(f) GDPR. We delete the data once the results of the surveys have been evaluated.

2. Newsletter

Interested parties have the option of subscribing to a free newsletter. We process the data provided during registration exclusively for sending the newsletter. Registration takes place by selecting the corresponding field on our website, by ticking the corresponding box in a paper document or by another unambiguous action by which interested parties declare their consent to the processing of their data, so that the legal basis is Art. 6(1)(a) GDPR. Consent may be withdrawn at any time, e.g., by clicking the corresponding link in the newsletter or by notifying us at our e-mail address stated above. The processing of the data until the withdrawal remains lawful even in the event of a withdrawal.

On the basis of the recipients' consent (Art. 6(1)(a) GDPR), we also measure the open and click rates of our newsletters in order to understand which content is relevant to our recipients.

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

3. Data processing on our website

3.1. Notice 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). The specific information concerned can be found in the following sections.

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

Insofar as this storage or access is strictly necessary for us to provide the service of our website expressly requested by website visitors (e.g., to operate a chatbot used by the website visitor or to ensure the IT security of our website), it takes place on the basis of § 25(2) No. 2 TTDSG.
Otherwise, this storage or access takes place on the basis of the website visitors' consent (§ 25(1) TTDSG).

The subsequent data processing takes place in accordance with the following sections and on the basis of the provisions of the GDPR.

3.2. Informational use of the website

In the case of informational use of the website, i.e., if site visitors do not otherwise transmit information to us, we collect the personal data that the browser transmits to our server in order to ensure the stability and security of our website. This constitutes our legitimate interest, so that the legal basis is Art. 6(1)(f) GDPR.

This data is:

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. It is deleted when its storage is no longer necessary, 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 Luxemburg, Luxemburg. In doing so, the provider processes the personal data transmitted via the website, e.g., content data, usage data, meta/communication data or contact data, in the EU. Further information can be found in the provider's privacy statement at https://aws.amazon.com/privacy/.

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

We use the content delivery network Cloudflare for our website. The provider is Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA. In doing so, the provider processes the personal data transmitted via the website, e.g., content data, usage data, meta/communication data or contact data, in the USA. Further information can be found in the provider's privacy statement 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 large peak loads. The legal basis for the described data processing is therefore Art. 6(1)(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, by means of an adequacy decision pursuant to Art. 45(3) GDPR, that the third country offers an adequate level of protection.

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 answering inquiries addressed to us. The legal basis for the processing is therefore Art. 6(1)(f) GDPR.
We delete the data arising in this context once storage is no longer necessary, or restrict the processing if statutory retention obligations exist.

3.5. Job advertisements

We publish vacancies in our company on our website, on pages linked to the website or on third-party websites.
The data provided in the course of the application is processed in order to carry out the application process. Insofar as this data is necessary for our decision to establish an employment relationship, the legal basis is Art. 88(1) GDPR in conjunction with § 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 cannot process the application.
Further data is voluntary and not required for an application. If applicants provide further information, the basis is their consent (Art. 6(1)(a) GDPR).

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

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

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

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

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

3.6. Booking appointments

Site visitors can book appointments with us on our website. For this purpose, in addition to the data entered, we process meta or communication data. We have a legitimate interest in offering interested parties a user-friendly way to arrange appointments. The legal basis for the data processing is therefore Art. 6(1)(f) GDPR. Insofar as we use a third-party tool for scheduling, the relevant information 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(1)(b) GDPR.

3.8. Offer of goods and services

We offer goods and services via our website. In doing so, we process the following data in the course of the order:

Company, first name, last name, street and house number, ZIP code, city, payment data

The data is processed in order to perform the contract concluded with the respective site visitor (Art. 6(1)(b) GDPR).

3.9. Payment service providers

To process payments, we use payment processors that are themselves controllers under data protection law within the meaning of Art. 4(7) GDPR. Insofar as they receive data entered by us in the ordering process and payment data, we thereby fulfill the contract concluded with our customers (Art. 6(1)(b) GDPR).

These payment service providers are:

Stripe Payments Europe, Ltd., Ireland

3.10. Technically necessary cookies

Our website sets cookies. Cookies are small text files that are stored in the web browser on a site visitor's device. Cookies help to make the offering more user-friendly, effective and secure. Insofar as these cookies are necessary for the operation of our website or its functions (hereinafter “technically necessary cookies”), the legal basis for the associated data processing is Art. 6(1)(f) GDPR. We have a legitimate interest in providing customers and other site visitors with a functioning 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 variations of the website to page visitors

3.11. Third-party providers

3.11.1. Leadinfo

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 the processing is Art. 6(1)(a) GDPR. The processing is based on consent. Data subjects may withdraw their consent at any time, for example by contacting us using the contact details provided in our privacy statement. The withdrawal does not affect the lawfulness of the processing carried out until the withdrawal.

We delete the data when the purpose for which it was collected no longer applies. Further information is available in the provider's privacy statement 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 is deleted when the purpose for which it was collected no longer applies and there is no obligation to retain it. Further information is available in the provider's privacy statement 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 is deleted when the purpose for which it was collected no longer applies and there are no retention obligations to the contrary. Further information is available in the provider's privacy statement 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 is 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 adopted in accordance with the examination procedure under Art. 93(2) GDPR (Art. 46(2)(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 the transfer 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 is available in the provider's privacy statement 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 the transfer to a country outside the EEA is consent.

Further information is available in the provider's privacy statement at https://policies.google.com/privacy.

3.11.8. Google Tag Manager

We use Google Tag Manager to deploy further 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 is available in the provider's privacy statement 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 the processing is Art. 6(1)(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 for confirmation.

The data is masked after collection so that it can no longer be related to a person. Further information is available in the provider's privacy statement at https://heydata.eu/datenschutzerklaerung.

3.11.10. Cookiebot

We use Cookiebot to manage consents. The provider is Usercentrics A/S, Havnegade 39, DK-1058, Kopenhagen. The provider processes meta/communication data (e.g., device information, IP addresses) in the EU.

The legal basis for the processing is Art. 6(1)(f) GDPR. We have a legitimate interest in managing website visitors' consents to cookies in a simple manner.

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 EU.

The legal basis for the processing is our legitimate interest pursuant to Art. 6(1)(f) GDPR. The processing of the data is technically necessary in order to display different variations 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 e-mails. The provider is Mailgun Technologies, Inc., 112 E Pecan St Ste 1135, San Antonio, TX, 78205-1509, USA. The provider processes e-mail addresses in the USA.

The legal basis for the processing is Art. 6(1)(b) GDPR. The processing is necessary for the performance of the contract concluded with the user in connection with the customer account.

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

3.11.13. Mapbox

We use Mapbox for location services. 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 there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles from users' online behavior, which are used, for example, to show advertising on the networks' pages and elsewhere on the internet that corresponds to the users' interests. For this purpose, the operators of the networks store information on usage behavior in cookies on the users' computers. Furthermore, it cannot be ruled out that the operators combine this information with other data. Users can obtain further information as well as notes on how users can object to the processing by the site operators in the privacy statements of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so 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 authorities access the data.

If users of the networks contact us via our profiles, we process the data provided to us in order to answer the inquiries. This constitutes our legitimate interest, so that the legal basis is Art. 6(1)(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 statement 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 statement is available here: https://twitter.com/de/privacy. One way to object to the data processing is 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 statement is available here: https://www.linkedin.com/legal/privacy-policy?_l=de_DE. One way to object to the data processing is via the settings for advertisements: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.

5. Changes to this privacy statement

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

6. Questions and comments

If you have any questions or comments regarding this privacy statement, please feel free to contact us using the contact details provided above.

7. Google API Compliance

We operate the application Varify.io®, which accesses certain Google user data in order to provide our customers with more precise and meaningful analyses in the context of A/B tests. Our goal is to enable companies to make well-founded decisions about their optimization measures.

For this purpose, we use data reports from Google Analytics 4 (GA4) to enable detailed comparisons between different A/B test groups. The imported data is further processed in Varify.io® to calculate essential key figures such as uplift, significance and other statistical measures. These metrics are crucial for evaluating the effectiveness of different test variations and enable data-driven decision-making.

In order to capture the test results precisely, Varify.io® creates specific audiences within GA4 for each A/B test started. This process requires access to certain Google API permissions to ensure that the data can be correctly captured, analyzed and interpreted. 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 transparent use of the data, which is aimed exclusively at presenting the results of A/B tests and improving the analytical capabilities. The data is used exclusively to perform the commissioned analysis functions, and access takes place only for the duration of the active connection between the GA4 account and Varify.io® or until the connection is disconnected. Should there be any changes regarding the access to or use of the data, these will be updated in our privacy statement. In this case, renewed consent to these changes via the API will be required.