Privacy Policy

Contents

Purpose and accountability
General information on data processing and legal basis
User rights
Right to object
Amendments to this Privacy Policy
Deletion of data
Security safeguards
Forwarding of data to third parties and third-party providers
Processing of data within the course of customer relations
Contact form, Enquiries and CRM
Profile pictures from Gravatar
Akismet Anti-Spam Check
Collection of access data (logfiles)
Cookies & reach measurement
Google Analytics
Jetpack
Newsletter and commercial communication
Integration of third-party services and content

Purpose and accountability
1. This Privacy Policy describes how we process personal data collected on our websites and online platforms and through our associated webpages, functions and content (hereinafter jointly referred to as “Services”, or more specifically as “Website”) and describes the scope and purpose of these activities. This Privacy Policy applies to all situations, regardless of which domain, system, platform or device (e.g. desktop or mobile) the Websites are accessed on.
2. The provider of the Websites, and the party responsible for data protection and privacy issues in regard to the Websites, is DMT Visions Ltd, Ross House, Victoria Place, Eyre Square, Galway, Ireland, e-mail: [email protected] (hereinafter referred to as “we”, “us” and “our”). For further information about us and contact details please refer to our legal information: https://www.wplab.com/contact/imprint/.
General information on data processing and legal basis
1. The personal data of the users processed in the context of our Service include inventory data (e. g., names and addresses of customers), contract data (e. g., services used, names of staff, payment information), usage data (e. g., the websites visited, interest in our products), Meta/communication data (device IDs, IP addresses) and content data (e. g., entries in the contact form, data processed within the scope of our contract fulfilment).
2. The term “user” covers all categories of data subjects concerned. They include our business partners, customers, prospective customers and other visitors to our website. The term “user” covers all categories of data subjects concerned. They include our business partners, customers, prospective customers and other visitors to our website. The terminology used within this Privacy Policy, such as “users”, is gender-neutral.
3. All the personal User data we collect is processed in accordance with the relevant data protection regulations. That means we only process User data where this is permitted by law. This applies, in particular, if data processing is required or prescribed by law in order to furnish our contractual services (e.g. to process orders) and provide online services, or if the User has provided their consent, or if it is for the purposes of our legitimate interests (i.e. our interest in analyzing, optimizing and running our Websites in a secure and commercially viable manner within the meaning of Art. 6 (1) f. of the General Data Protection Regulation (GDPR).
4. In regard to the processing of personal data on the basis of the General Data Protection Regulation (GDPR), please note that the legal basis for the data subject giving consent is Art. 6 (1) a. and Art. 7 GDPR, the legal basis for processing data in order to perform our contractual services and discharge our contractual obligations is Art. 6 (1) b. GDPR, the legal basis for processing data in order to comply with our legal obligations is Art. 6 (1) c. GDPR, and the legal basis for processing data for the purposes of our legitimate interests is Art. 6 (1) f. GDPR.
User rights
1. Users have the right to obtain information free of charge on the personal data we have collected about them. In addition, Users have the right to correct any inaccurate data, restrict the processing of their personal data or delete it, and, where applicable, assert their right to data portability. Users also have the right to submit a complaint to the relevant supervisory authorities if they suspect that data has been processed unlawfully.
2. Users can also withdraw any consent they may have given. Such a revocation of consent shall have future effect only.
Right to object
1. Users can choose to opt out of the future processing of their personal data at any time in accordance with statutory provisions. This right to object applies in particular to the processing of data for the purposes of direct advertising.
Amendments to this Privacy Policy
1. We reserve the right to amend this Privacy Policy at any time to reflect changes in the legal situation or changes relating to the service or data processing. This only applies to declarations concerning data processing, however. If Users’ consent is required or if the Privacy Policy contains provisions for the contractual relationship with the Users, the changes shall only be made with the consent of the Users.
2. Users are requested to check the Privacy Policy on a regular basis to keep up-to-date with its content.
3. Last updated: April 2018
Deletion of data
1. The data stored by us is deleted once it is no longer required for the designated purpose and provided that we have no statutory obligation to retain said data. In the event User data is not deleted because it is required for other purposes permitted by law, then its processing shall be restricted accordingly, i.e. the data shall be blocked and no longer processed for other purposes. This applies, for example to User data that must be retained due to commercial or tax requirements.
Security safeguards
1. We apply state-of-the-art organizational, contractual and technical security measures to ensure compliance with the provisions of data protection legislation and thereby to protect the data we process against accidental or intentional manipulation, loss, destruction or access by unauthorized persons.
2. These security measures include, in particular, the encrypted transmission of data between your browser and our server.
Forwarding of data to third parties and third-party providers
1. Data is only forwarded to third parties to the extent permitted by law. We only forward User data to third parties if, for example, this is necessary in order to fulfil our contractual obligations towards the users or if we make use of third party services within the scope of our legitimate interests. Furthermore, data is transferred within the companies of our group of companies, in particular for the purpose of fulfilling administrative tasks, legal obligations or for reasons of business interests.
2. Insofar as we make use of third-party services to furnish our own services, we ensure appropriate legal safeguards are in place and take appropriate technical and organizational steps to ensure that personal data is protected in compliance with applicable statutory requirements.
3. Insofar as content, tools or any other resources from other providers (hereinafter referred to as “third-party providers”) are employed within the scope of this Privacy Policy and said third-party providers have their registered headquarters in a third country, it should be assumed that data will be transferred to the country of domicile of the third-party provider. The term third country refers to countries in which the GDPR does not constitute directly applicable legislation, i.e. essentially countries outside the EU or the European Economic Area. Data shall be transferred to third countries if an adequate level of data protection is in place, if the User has provided their consent, or if this transfer is permitted by law in any other way.
Processing of data within the course of customer relations
1. We process inventory data (e. g., names and addresses as well as contact data of users) and contract data (e. g., services used, names of contact persons, payment information) of our customers and interested parties for the purpose of fulfilling our contractual obligations and services in accordance with Art. 6 (1) b. GDPR.
2. Within the framework of an order, users must be able to create a user account, in particular by viewing their orders. During the registration process, the required information will be communicated to the users. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to its storage is necessary for commercial or tax reasons according to Art. 6 (1) lit. c DSGVO. It is up to the users to save their data before the end of the contract if they have given notice of termination; we are entitled to irretrievably delete all user data stored during the term of the contract.
3. Furthermore, we process the data of our customers (e. g., the visited websites of our online offer as well as concerning the use of our services) on the basis of our legitimate interests in advertising and market research purposes in accordance with Art. 6 (1) f. GDPR, in order to offer customers services based on their previous contractual interests or the events they have attended and to analyze the development of our business operations. Furthermore, we process the data insofar as we are legally required to do so, e. g. due to commercial and tax obligations, in accordance with Art. 6 (1) c. GDPR, are obligated.
Contact form, Enquiries and CRM
1. If a User gets in touch with us via the contact form or by email, we process the User’s details in order to respond to and deal with the query or request. The User’s details may be stored in our customer relationship management (CRM) system or a comparable enquiry system.
2. On the basis of our legitimate interests pursuant to Art. 6 (1) f. DSGVO (i.e. interest in the optimization and economic operation of our online offer as well as efficient and fast processing of service requests), we use the CRM system “HelpScout” of the provider Help Scout Inc., 131 Tremont St, Boston, MA 02111-1338, USA. To protect the privacy of our users, we have also entered into a Data Processing Agreement with Help Scout.
3. Help Scout is also certified under the Privacy Shield Agreement and thus offers an additional guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000KzX1AAK&status=Active). For further information please visit Help Scout’s Privacy Policy: https://www.helpscout.net/company/privacy/.
Profile pictures from Gravatar
1. We use the service Gravatar provided by Automattic, Inc. 132 Hawthorne Street San Francisco, CA 94107, USA, within our Website and especially in our blog.
2. Gravatar is a service where users can log in and store profile pictures and their e-mail addresses. If users leave contributions or comments with the respective e-mail address on other websites (especially in blogs), their profile pictures can be displayed next to the contributions or comments. For this purpose, the e-mail address provided by the users is transmitted to Gravatar in encrypted form for the purpose of checking whether a profile has been saved for it. This is the sole purpose of the transmission of the e-mail address and it will not be used for other purposes, but will be deleted thereafter.
3. The use of Gravatar is based on our legitimate interests within the meaning of Art. 6 (1) f. DSGVO, as we offer with the help of Gravatar the possibility to personalize the authors of contributions and comments with a profile picture.
4. Automattic is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000CbqcAAC&status=Active).
5. By displaying the images, Gravatar obtains the IP address of the user, as this is necessary for communication between a browser and an online service. For more information on Gravatar’s collection and use of the data, please refer to Automattic’s privacy policy: https://automattic.com/privacy/.
6. If users do not want a user image associated with their email address to appear in Gravatar’s comments, you should use a non-Gravatar email address for commenting. We would also like to point out that it is also possible to use an anonymous or no e-mail address if users do not wish their own e-mail address to be sent to Gravatar. Users can completely prevent the transfer of data by not using our comment system.
Akismet Anti-Spam Check
1. Our Website uses the “Akismet” service offered by Automattic, Inc. 132 Hawthorne Street San Francisco, CA 94107, USA. The use is based on our legitimate interests within the meaning of Art. 6 (1) lit. f. DSGVO. With the help of this service, comments of real people are distinguished from spam comments. All comment information is sent to a server in the USA, where it is analyzed and stored for four days for comparison purposes. If a comment has been classified as spam, the data will be stored after this time. This information includes the name entered, the e-mail address, the IP address, the comment content, the referrer, information on the browser used, the computer system and the time of entry.
2. Automattic is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt0000000CbqcAAC&status=Active).
3. Further information on Akismet’s collection and use of the data can be found in Automattic’s privacy policy: https://automattic.com/privacy/.
4. Users are welcome to use pseudonyms or refrain from entering their name or email address. You can completely prevent the transfer of data by not using our comment system.
Collection of access data (logfiles)
1. For the purposes of our legitimate interests, we collect data every time the server on which the service is located is accessed. This data is collected in the form of server log files. These access logs include the name of the webpage and/or file accessed by the User, the date and time of access, the amount of data transferred, notification of successful retrieval, details of the web browser used (including the version), the User’s operating system, the referrer URL (of the previous page linking to our website), the IP address and the requesting provider.
2. Log file information is retained for security reasons (e.g. to detect improper use or fraud) for a maximum of seven days before being deleted. Data that is to be retained as evidence shall be excluded from deletion until the relevant case has been finalized.
Cookies & reach measurement
1. Cookies are data packets that are transferred from our web server or third parties’ web servers to the User’s web browser and stored there for later retrieval. Cookies may comprise small files or any other kinds of information storage. When the user browses the same website in the future, the data stored in the cookie can be retrieved by the website to notify the website of the user’s previous activity. We use so-called “session cookies”, which information are only stored for the duration of the current visit to our Website (e. g. to enable your login status). A session cookie stores a randomly generated unique identification number, a so-called session-ID. A cookie also contains information about its origin and the storage period. These cookies cannot store any other data. Session cookies are deleted when users have finished using my online offer and, for example, log out or close the browser.
2. This Privacy Policy also explains to Users how I use cookies in a pseudonymized manner to measure reach.
3. If the User does not wish cookies to be stored on their computer, we hereby request that they disable the relevant option in their browser settings. Stored cookies can be deleted in the browser settings at any time. Disabling cookies may prevent the user from enjoying the full functionality of these Websites.
4. Users can block cookies that are used for tracking and online advertising by visiting the opt-out page of the network advertising initiative (https://optout.networkadvertising.org/) and also by managing their preferences on the U.S. website https://www.aboutads.info/choices or the European website https://www.youronlinechoices.com/uk/your-ad-choices/.
Google Analytics
1. For the purposes of our legitimate interests (i.e. our interest in analyzing, optimizing and running our Websites in a commercially viable manner within the meaning of Art. 6 (1) f. of the GDPR, we use Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google uses cookies. The information generated by cookies concerning the use of the Websites by the User will generally be transmitted to and stored by Google on servers in the USA.
2. Google is certified under the Privacy Shield framework which offers a guarantee of compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
3. Google will use this information on our behalf for the purpose of evaluating use of our Websites by the User, compiling reports on activity on the Websites, and providing us with other services relating to the use of the Websites and use of the Internet. This process may involve creating pseudonymized usage profiles of Users from the processed data.
4. We only use Google Analytics with IP anonymization enabled. That means Google truncates the User’s IP address within Member States of the European Union and in other countries that are party to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and truncated there.
5. The IP address transmitted by the User’s browser is not associated with any other data held by Google. Users can prevent cookies from being installed on their computer by adjusting their browser settings accordingly. Users can also prevent Google from collecting data generated by cookies concerning their use of the Websites and can prevent Google from processing this data by downloading and installing a browser plug-in from the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
6. For more information on how Google uses data and how to opt out, please refer to Google’s websites: https://www.google.com/intl/en/policies/privacy/partners (“How Google uses data when you use our partners’ sites or apps”), http://www.google.com/policies/technologies/ads (“How Google uses data in advertising”), http://www.google.com/settings/ads (“Control the information Google uses to show you ads”).
Jetpack
1. On the basis of our legitimate interests (i.e. our interest in analyzing, optimizing and running our Websites in a commercially viable manner within the meaning of Art. 6 (1) f. of the GDPR, we use Jetpack, a service provided by Automattic Inc., 60 29th Street #343, San Francisco, CA 94110-4929 to obtain information regarding the activities that users engage in while visiting our website in order to analyze and improve the usage of our website and our service.
2. Automattic is certified under the Privacy Shield framework which offers a guarantee of compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt0000000CbqcAAC&status=Active).
3. The information includes browser information, operating system information, mobile device information, time of visit, and the referring site, application, or service. This process may involve creating pseudonymized usage profiles of Users from the processed data. Your IP-address will be anonymized. The information of the users is stored in a cookie. The information generated by the cookie about your use of this online offer is stored on a server in the USA. The processed data can be used to create user profiles, which are only used for analysis purposes. You can find further information in Automattic’s privacy policy: https://automattic.com/privacy/ and information on jetpack cookies: https://jetpack.com/support/cookies/.
Newsletter and commercial communication
1. With the following declarations we would like to inform our users about the contents of our newsletters as well as other types of business e-mails and electronic mail (short “newsletter”) as well as the registration, sending and statistical evaluation procedures and your rights of objection. By subscribing to our newsletter, you declare your agreement with the reception and the described procedures.
2. We send out newsletters, e-mails and other electronic notifications with advertising information (hereinafter referred to as “newsletters”) only with the consent of the recipients or a legal permission. Insofar as the contents of a newsletter registration are specifically described in detail, they are decisive for the user’s consent. In general, our newsletters contain information on our Services, Software and our business.
3. The registration for our newsletter is done in a so-called double opt-in procedure. This means that users will receive an e-mail after the registration, in which users will be asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The subscriptions to the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes saving the logon and confirmation time as well as the IP address.
4. The newsletters may contain a so-called “web-beacon”, i.e. a pixel-sized file, which is retrieved from our server when the newsletter is opened. In the course of this retrieval, technical information such as information about the browser and your system, as well as your IP address and time of retrieval are collected. This information is used for the technical improvement of the services based on the technical data or target groups and their reading behavior. Statistical surveys also include determining whether the newsletters are opened, when they are opened, and which links are clicked and when. For technical reasons, this information can be assigned to the individual newsletter recipients. However, it is not our intention to monitor individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our contents to them or to send different contents according to the interests of our users.
5. The newsletter is sent on the basis of the consent of the recipients in accordance with Art. 6 (1) lit. a, Art. 7 GDPR as well as § 7 (3) No. 2 and (3) of the German fair competition law (UWG). The statistical surveys and analyses are conducted on the basis of our legitimate interests in accordance with Art. 6 (1) lit. f of the GDPR. We are interested in using a user-friendly and secure newsletter system that serves our business interests and meets the expectations of our users. The registration procedure is recorded in accordance with Art. 6 (1)(c). GDPR on the basis of a legal obligation to prove the consent of the newsletter recipients (e.g. in accordance with Art. 7 (1) GDPR).
6. Newsletter recipients can cancel the receipt of our newsletter at any time, i.e. revoke their consent. Newsletter recipients will find a link to unsubscribe from the newsletter at the end of each newsletter. By unsubscribing from the newsletter, the personal data will be insofar deleted, unless their storage is legally required or justified, and their processing in this case is limited to these exceptional purposes only.
Integration of third-party services and content
1. For the purposes of our legitimate interests (i.e. our interest in analyzing, optimizing and running our Websites in a commercially viable manner within the meaning of Art. 6 (1) f. of the GDPR), we use third-party content and service delivery services on our Websites in order to incorporate content and services such as videos and fonts, for example (hereinafter jointly referred to as “content”). The third-party provider of this content always requires the User’s IP address in order to send the content to the browser of the respective User. In other words, the IP address is required to display this content. We endeavor only to use such content where the respective provider uses the IP address exclusively to deliver said content. Third-party providers may additionally use “pixel tags” (invisible image files, also known as web beacons) for statistical or marketing purposes. Pixel tags can be used to analyze information such as the number of visitors accessing the pages of this website. The pseudonymized information may additionally be stored on User devices in the form of cookies. This information includes technical information on the browser and operating system, referring websites, time spent on the website, and further details on how Users make use of our Websites, plus it can also be combined with comparable information from other sources.
2. The list below provides an overview of third-party providers and their content as well as links to their privacy policies, which contain further information on data processing and opt-out mechanisms, some of which have already been discussed here:
  1. The links/buttons to social networks and platforms (“social media”) used within our online offer do not establish direct contact between social networks and users. Their function corresponds to that of a regular online link.
  2. If our customers use the payment services of third parties (e.g. PayPal or Stripe), the terms and conditions and the privacy policy of the respective third party payment providers, which can be accessed within the respective websites or transaction applications, apply.
  3. Videos on the “YouTube” platform provided by the third-party company Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland. Privacy policy: https://www.google.com/policies/privacy/; opt-out: https://www.google.com/settings/ads/. Notes on Google, Inc.: Google is certified under the Privacy Shield framework which offers a guarantee of compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
  4. Maps from the “Google Maps” service provided by the third-party company Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland. Privacy policy: https://www.google.com/policies/privacy/; opt-out: https://www.google.com/settings/ads/.
  5. External fonts provided by the third-party provider Google, Inc., https://www.google.com/fonts („Google Fonts“). The integration of the Google fonts is performed by a request on Google’s server (usually in the USA). Privacy policy: https://www.google.com/policies/privacy/, opt-out: https://www.google.com/settings/ads/.
  6. Notes on Google, Inc.: Google is certified under the Privacy Shield framework which offers a guarantee of compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
  7. We use the services of SendGrid, Inc. 1801 California Street, Suite 500 Denver, Colorado 80202, USA for the purpose of sending e-mails. To protect the privacy of our users, we have also entered into a Data Processing Agreement with Sendgrid. SendGrid is also certified under the Privacy Shield framework which offers a guarantee of compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt0000000TRktAAG&status=Active). Privacy policy: https://sendgrid.com/policies/privacy/services-privacy-policy/.
  8. We use the services of Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA, https://www.cloudflare.com, a Content Delivery Network (CDN), which helps us to deliver contents of our Services faster, especially big media files like images or scripts using a world-wide distributed server network. To protect the privacy of our users, we have also entered into a Data Processing Agreement with Cloudflare. Cloudflare is also certified under the Privacy Shield framework which offers a guarantee of compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnZKAA0&status=Active). Privacy Policy: https://www.cloudflare.com/security-policy/.