Privacy Policy of this web page

We, as the operator of the website at https://book.nemovote.com/ (also the “website“), are the controller within the meaning of applicable data protection law, in particular the General Data Protection Regulation (“GDPR“), for the personal data of the user (“you“) of this website.

In the following, we inform you clearly within the scope of our information obligations (Art. 13 seqq. GDPR) about which data is processed when you visit our website and on which legal basis such processing is carried out. You will also receive information about the rights you have vis-à-vis us and the competent supervisory authority.

 

1. Information on the controller

 

NemoContra GmbH

Mörikestr. 25

71083 Herrenberg

Germany

info@nemovote.com

 

2.  Informational use of our website

 

When you call up our website merely to visit it, so-called log files are automatically recorded by our system.

The following log files are processed automatically:

• IP address of the requesting computer
• Date and time of the request
• Name and URL of the retrieved file
• Referrer URL
• Access Status/HTTP Status Code
• Type of Internet browser used
• Language of the Internet browser used
• Version of the Internet browser used
• Operating system

The log files contain your IP address and possibly other personal data. Therefore, an assignment to you is possible in principle. However, we only store your data temporarily and in particular not together with other personal data. The data is deleted as soon as you leave the website. The temporary processing and storage of the above-mentioned data is necessary to provide our website and to ensure the security of our information technology systems. These purposes also constitute our legitimate interest in processing the data on the legal basis of Art. 6 (1) sentence 1 lit. f GDPR.

Website hosting:

Our website is operated on the servers of the provider netcup GmbH, Daimlerstraße 25, 76185 Karlsruhe, Germany, with server location in Germany. This means that the data we collect when you visit this website is stored by our hoster.

The legal basis for the processing of your personal data is Art. 6 (1) sentence 1 lit. f GDPR, as it is in our legitimate interest to use the services of a professional provider for the secure and efficient provision of our website. We have entered into a data processing agreement pursuant to Art. 28 GDPR with netcup.

 

3.         WooCommerce

 

Our website is based on WooCommerce, a customisable open-source eCommerce platform that is embedded locally on our website via a plugin and is provided by WooCommerce Ireland Ltd, Grand Canal Dock, 25 Herbert Pl, Dublin, D02, AY86, Ireland.

WooCommerce does not store any information of our visitors. It is only stored if the website provider has activated so-called tracking. We have not activated this function.

 

4.         Orders

 

4.1      Ordering information

When you place an order on our website, we need the following data to fulfil the contract with you:

• First name, last name and billing address to send you your order and invoice.
• e-mail address to send you the order confirmation and to provide you with contract documents immediately after the order.
• Name of the company/organisation (optional)
• Tax ID number (optional)
• Telephone number (optional)
• Name of the event (to allow the NemoVote event link to be assigned)
• Date of the election
• Your payment information to process payment for your order

We also process the data required in each case in order to unwind our contract after a withdrawal or return for any other reason or to check claims. In addition, we store your aforementioned data in order to be able to display your order history on our website.

The legal basis for the processing of the data is Art. 6 para. 1 sentence 1 lit. b and f GDPR. The data is stored for as long as is necessary for order processing and within the scope of our obligations deriving from any website user contract entered into with you. It is in our legitimate interests to enable you to track your current and previous orders on our website. Furthermore, we only store your data in order to comply with our legal obligations (e.g. tax obligations) (Art. 6 para. 1 sentence 1 lit. c GDPR). In this case, we block your data to the extent that it is only processed for the necessary purposes.

In addition to the aforementioned data, we store the time (date and time) of the transmission of your data to us, as well as your IP address. The processing of this data corresponds to our legitimate interest (Art. 6 para. 1 sentence 1 lit. f GDPR) in order to ensure the security of our systems and to counteract misuse. This additional data is deleted as soon as it is no longer required, at the latest when the contract with you has been completed.

Please note: If you would like to subscribe to a subscription plan with us, an order is only possible as a registered customer (more on this under 5).

 

4.2      Payment methods

If you select a payment provider on our site for payment, this provider will also receive your personal data, for example your name, address and bank account details. In addition, our house bank receives your bank connection data when an electronic payment is received. The legal basis for processing your personal data for payment purposes is Art. 6 para. 1 sentence 1 lit. b and f GDPR.

Credit card: When you pay with your credit card on our website, your credit card provider receives the information that you have placed an order with us. Your credit card provider may carry out a credit check. You can find more information about this on the respective website of your credit card provider.

Direct debit: If you pay on our website by bank transfer or direct debit, our house bank receives your bank details for payment processing.

SOFORT Überweisung.: If you select the payment method SOFORT Überweisung (Sofort GmbH, Theresienhöhe 12, 80339 München) on our website, Sofort GmbH will receive your personal data, for example your name, address and account details.

Giropay: If you pay on our website via Giropay (paydirekt GmbH, Stephanstr. 14-16, 60313 Frankfurt am Main (hereinafter “paydirekt”)), paydirekt forwards your payment and transaction data as well as information on the shopping basket to your bank. In addition, our house bank receives your bank connection data for payment processing. You can find information on this at: https://www.giropay.de/rechtliches/datenschutzerklaerung

Invoice: If you order on invoice, our house bank receives your bank details for payment processing when you make a bank transfer to us.

 

5.         Customer account/registration

 

You have the option of creating a customer account on our website with your personal data. If you decide to create a customer account, you must provide us with the following information:

• E-mail address

All other information is voluntary. We store the following voluntary information together with your e-mail address if you provide it to us:

• First and last name

Your data is used for the purpose of managing your customer account and providing the associated functions, such as displaying your orders. The legal basis for the storage of your customer account data is Art. 6 para. 1 sentence 1 lit. b and f GDPR.

We store your data that you have provided to us as part of your login/registration as long as you do not delete your customer account with us. If you make changes to your details, the old details will be deleted and only the updated data will be stored. Furthermore, we only store your data in order to comply with our legal obligations (e.g. tax obligations) (Art. 6 para. 1 sentence 1 lit. c GDPR). In this case, we block your data to the extent that it is only processed for the necessary purposes.

In addition to the data you provide to us, we may also store the time (date and time) of the transmission of your data to us, as well as your IP address. The processing of this data corresponds to our legitimate interest (Art. 6 para. 1 sentence 1 lit. f GDPR) in order to ensure the security of our systems and to counteract misuse. This additional data is deleted as soon as it is no longer required, at the latest when the contract with you has been completed.

You can delete or change your voluntary customer account with us at any time. You will find the functions for changing your details in your profile. To delete your customer account, please contact us (see point 1 above).

 

6.         Contact by e-mail

 

You have the option of contacting us by e-mail. Your personal data transmitted in this way will be stored by us. The data will be processed exclusively in order to properly handle your contact, whereby this corresponds to our legitimate interest. The legal basis for the processing of your personal data is Art. 6 para. 1 sentence 1 lit. f GDPR. The data is stored until it is no longer required to achieve the purpose of the conversation with you and the matter of your contact has been comprehensively clarified.

If your contact is aimed at concluding a contract with us, the additional legal basis for processing your personal data is Art. 6 (1) sentence 1 lit. b GDPR. This data is stored for as long as it is required for the execution of the contract or the pre-contractual measures. Beyond that, we only store your data in order to comply with legal obligations (e.g. tax obligations) (Art. 6 para. 1 sentence 1 lit. c GDPR).

You can inform us at any time (see point 1 above) that you would like us to delete the data provided during the conversation. In this case, all personal data of the conversation will be deleted, as far as permissible, and a continuation of the conversation is not possible.

 

7. After-sales e-mails

 

If you provide your e-mail address when using our services, for example when entering into a subscription agreement via our website, we may use the e-mail address to send you after-sales e-mails. This is done exclusively in the context of direct advertising for our own or similar goods or service

The legal basis for sending after-sales e-mails in connection with the sale of goods or services is Section 7 (3) of the German Act Against Unfair Competition (UWG). If we send you an after-sales e-mail following an order on our website, we will store your e-mail address for the purpose of advertising our own or similar goods or services until you have objected to the use of your e-mail address for this purpose (e.g. by unsubscribing from the newsletter).

RIGHT TO OBJECT / Unsubscribing from after-sales e-mails

You can unsubscribe from our after-sales e-mails at any time. You will find the link to do so at the end of every after-sales e-mail. By doing so, you revoke your consent with effect for the future or object to any further use of your data for the purpose of sending the newsletter. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.

Newsletter service provider:

We use Mailjet (Mailjet SAS, 13-13 bis, rue de l’Aubrac, 75012 Paris, France, hereinafter “Mailjet”) to send our after-sales e-mails and to send emails to our customers in connection with our monitoring service.

Mailjet offers us various, easy-to-use options for creating newsletters and other e-mails, designing them attractively and sending them to larger groups of recipients. In order to send you your newsletter, we transmit your e-mail address to Mailjet.

The legal basis for the use of Mailjet for the purpose of sending e-mails in this context is Art. 6 para. 1 sentence 1 lit. f GDPR. It is in our legitimate interests to use a professional, specialised and high-performance email service provider for the extensive sending of emails.

We have concluded an data processing agreement with Mailjet.

 

8.         Google Marketing Platform (DoubleClick)

 

On our website, we integrate the online marketing solution Google Marketing Platform (formerly “DoubleClick”), which is offered for users from the European Economic Area, Switzerland and Liechtenstein by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland and for all other users by Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA (hereinafter “Google Marketing Platform”). This tool enables us to place personalised digital advertisements on our website and to analyse their success later. At the same time, this allows us to avoid showing you advertisements again that you have already been able to view on another page. Within the scope of the functions provided by the Google Marketing Platform, we use the functions “Google Analytics”, and “Google Ads” (for more information, see sections 9 and 10).

For this purpose, Google Marketing Platform sets cookies through which the respective page views can be recorded. Google Marketing Platform sets cookies that store the following information:

• Referrer (previously visited website)
• Your IP address
• How you use our website
• the number of page views
• Keywords you used for the searchers

You can find more information about cookies in our cookie policy. Before we set the cookies, we request your consent (§ 25 para. 1 TTDSG). The legal basis for subsequent further processing of your data is your consent (Art. 6 para. 1 sentence 1 lit. a DSGVO).

You can revoke your consent under the aforementioned legal bases at any time by changing the data protection settings on our website.

You can prevent the collection of the data generated by the cookie and related to your use of the website (including your (anonymised) IP address) by Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: https://support.google.com/ads/answer/7395996.

In addition, you can stop the processing of your data by clicking on the following link: https://adssettings.google.com/authenticated?hl=de

You can find Google’s privacy policy at the following link: https://policies.google.com/privacy?hl=de.

Note on data transfers to the USA:

Please note the following: Google Marketing Platform is used on the basis of a contract that we have concluded with Google Ireland Ltd. However, Google Ireland Ltd. is a subsidiary of the US company Google, so that it is possible that your personal data will be transferred to US companies of Google (in particular Google LLC) and Google servers located in the USA. The USA is a third country within the meaning of the GDPR for which an adequacy decision has been issued by the EU Commission (the so-called “EU-US Data Privacy Framework” or “EU-US DPF”). Google LLC is certified as a US company under the EU-US DPF, cf. https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt000000001L5AAI&status=Active.

 

9.         Google Analytics 4

 

Our website implements the Google Analytics 4 analysis service, which is offered by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland for users from the European Economic Area, Switzerland and Liechtenstein and by Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA (hereinafter: “Google Analytics“) for all other users.

We have concluded a data processing agreement with Google Ireland Limited in accordance with Art. 28 GDPR.

Google Analytics 4 can record the following information, among others:

• Type of Internet browser used
• Internet browser version
• the operating system you are using,
• selected language,
• Data on the requesting terminal,
• Referrer (previously visited website)
• Your IP address (according to Google, the IP address is only used temporarily to determine a rough location of the requesting end device (city level) and is then deleted).
• (rough) location data, i.e. city (including its longitude and latitude), continent, country, region and subcontinent of the requesting terminal,
• Date and time of the server request,
• The session duration,
• Clicking and scrolling behaviour including playing media, internal searches, sharing content,
• Web shop interactions, such as product views and orders

Google Analytics 4 only uses the IP address to derive location data. IP addresses are not otherwise logged or stored, according to Google.

We are only shown statistics via Google Analytics 4, which we use to optimise our website and offers. We have also configured Google Analytics 4 so that Google may not use the data for its own analysis of online trends or to improve its own products and services.

Before we use Google Analytics 4 to analyse your website visit, we request your consent to the processing of your personal data (Art. 6 para. 1 sentence 1 lit. a GDPR) and the setting of the necessary cookies (§ 25 para. 1 TTDSG) that may be associated with Google Analytics 4.

For more information about the cookies we use, please see our cookie information.

The legal basis for the processing of your personal data and the setting of cookies within the scope of Google Analytics 4 is therefore your consent pursuant to § 25 (1) TTDSG and Article 6 (1) sentence 1 lit. a GDPR.

You can revoke your consent under the aforementioned legal bases at any time by changing the data protection settings on our website.

Note on data transfers to the USA:

Google Analytics is used on the basis of a contract that we have concluded with Google Ireland Ltd. However, Google Ireland Ltd. is a subsidiary of the US company Google, so that it is possible that your personal data will be transferred to US companies of Google (in particular Google LLC) and Google servers located in the USA. The USA is a third country within the meaning of the GDPR for which an adequacy decision of the EU Commission (the so-called “EU-US Data Privacy Framework” or “EU-US DPF”) exists. Google LLC is certified as a US company under the EU-US DPF, cf. https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt000000001L5AAI&status=Active.

You can also prevent the collection of your personal data by Google Analytics 4 and the processing of this data by Google by downloading and installing the browser add-on available under the following link (https://tools.google.com/dlpage/gaoptout?hl=de) to deactivate Google Analytics.

You can also prevent the processing of your data within the scope of Google Analytics 4 by clicking on the following link and bringing about an “opt-out”: Set “opt-out cookie”. In doing so, an “opt-out cookie” will be set, which will prevent the collection of your user data on this website in the future, unless the opt-out cookie is deleted.

Finally, you can also prevent Google cookies from being stored directly by making the appropriate settings in your browser settings.

 

10.         Google Ads (Google AdWords)

 

We use the online advertising programme Google Ads (formerly Google AdWords) on our website, which is offered by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland for users from the European Economic Area and Switzerland and by Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA for all other users.

With the help of Google Ads, we can create advertisements and use them to advertise on the internet (e.g. within the scope of Google Search). This allows us to reach potential customers who are searching the internet for products and services that are comparable to the services offered on our website.

We use Google’s “Conversion Tracking” as part of Google AdWords. By using the conversion tracking analysis service as part of our advertising measures, we receive information about the effectiveness of our advertising campaigns. This is done by evaluating visit actions. When you click on a Google Ad, a cookie is stored on your terminal device with your consent. This cookie is generated by Google specifically for our website. Each Google Ad customer receives a different cookie, so the cookies cannot be tracked across Google Ad customers’ websites. During the storage period of the cookie on your terminal device, both Google and we can assess whether you have interacted with an advertisement and thus reached our website when you visit our site. The information collected in this way is used to create conversion statistics for Google Ad customers who have opted in to Google conversion tracking. You can object to the use of conversion tracking by deactivating the conversion tracking cookie in your browser under the user settings. The cookie serves the purpose of measuring the interaction of visitors with advertisements and avoiding frequent repetition of the same advertisement. We only receive statistical evaluations from Google regarding the effectiveness of our advertising measures.

The Google Ads cookies are stored with your consent and thus on the basis of § 25 (1) TTDSG. The legal basis for the subsequent further processing is also your consent, Art. 6 para. 1 sentence 1 lit. a GDPR.

You can revoke your consent under the aforementioned legal bases at any time by changing the data protection settings on our website.

You can prevent the storage of cookies directly in your browser settings. However, we would like to point out that you may not be able to use the full functionality of our website. You can also prevent conversion tracking through browser settings that prevent the setting of cookies from the www.googleadservices.com domain.

In addition, you can prevent the collection of the data generated by the cookie and related to your use of the website to Google as well as the processing of this data by Google by downloading and installing the browser plugin available under the following link: https://support.google.com/ads/answer/7395996. The use of cookies or device identifiers by Google can also be deactivated here: https://adssettings.google.com/anonymous?hl=de

Detailed information on Google Ads, remarketing and conversion tracking can also be found in Google’s privacy policy at: https://www.google.de/policies/privacy/

Note on data transfers to the USA:

Please note the following: Google Ads are used on the basis of a contract that we have concluded with Google Ireland Ltd. However, Google Ireland Ltd. is a subsidiary of the US company Google, so that it is possible that your personal data will be transferred to US companies of Google (in particular Google LLC) and Google servers located in the USA. The USA is a third country within the meaning of the GDPR for which an adequacy decision has been issued by the EU Commission (the so-called “EU-US Data Privacy Framework” or “EU-US DPF”). Google LLC is certified as a US company under the EU-US DPF, cf. https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt000000001L5AAI&status=Active

 

11.      Borlabs Cookie

 

In order to obtain and document our visitors’ consent to the cookies we use, we use the Cookie Consent Tool from Borlabs, Benjamin A. Bornschein, Rübenkamp 32, 22305 Hamburg, Germany (“Borlabs“).

In this context, Borlabs sets a technically necessary cookie to store your cookie consents. This cookie stores the consent you gave when you entered the website. If you wish to revoke these consents, simply delete the cookie in your browser. When you re-enter/reload the website, you will be asked again for your cookie consent. You can find more information about this in our cookie information. Borlabs does not process any personal data. You can find details about this at https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/ .

The legal basis for the use of Borlabs is Art. 6 (1) sentence 1 lit. f GDPR, as it is in our legitimate interest to use the services of a professional service provider to manage and document the cookie settings of our visitors.

 

12.      Use of service providers

 

We would like to point out that when processing your personal data, we may use service providers with whom we have concluded data processing contracts pursuant to Art. 28 GDPR (e.g. for website hosting). If processors in a third country (not within the EU) carry out the data processing, we ensure that the level of protection of your data guaranteed by the GDPR is not undermined (Art. 44 et seq. GDPR).  The legal basis for the use of service providers is Art. 6 para. 1 sentence 1 lit. f GDPR. The commissioning of service providers (specialists or other service providers in areas that we cannot serve ourselves) is in our legitimate interest. If you would like to receive a copy of the suitable or appropriate guarantees, please let us know (see point 1 above).

 

13.      Your rights

 

If we process your data, you are a “data subject” within the meaning of the GDPR. You have the following rights: right of access, right to rectification, right to restriction of processing, right to erasure, right to information and right to data portability. In addition, you have a right to object, a right to withdraw your consent and the right to lodge a complaint with a supervisory authority.

Below you will find some details on the individual rights:

13.1    Right of access

You have the right to request confirmation from us as to whether we are processing your personal data. If we process your personal data, you have the right to obtain information in particular about the processing purposes, categories of personal data, recipients or categories of recipients and, if applicable, the storage period.

13.2    Right of rectification

You have the right to correct and/or complete the data we have stored about you if this data is incorrect or incomplete. We will carry out the correction or completion without delay.

13.3    Right to restrict processing

Under certain circumstances, you have the right to request that we restrict the processing of your personal data. An example of this is if you dispute the accuracy of your personal data and we need to verify the accuracy for a certain period of time. For the duration of the verification, your data will only be processed in a restricted manner. Another example of restriction is if we no longer need your data, but you need it for a legal dispute.

13.4    Right to erasure

You have the right in certain situations to request that we delete your personal data immediately. This is the case, for example, if we no longer need your personal data for the purposes for which we collected the data or if we have processed your data unlawfully. Another example would be if we process your data on the basis of your consent, you withdraw your consent and we do not process the data on any other legal basis. However, your right to erasure does not always exist. For example, we may process your personal data to comply with a legal obligation or because we need it for litigation.

13.5    Right to information

If you have exercised your right to rectify, erase or restrict the processing of your data, we are obliged to notify all recipients to whom we have disclosed your personal data of the rectification, erasure or restriction of the processing of your data, unless this proves impossible or involves a disproportionate effort.

13.6    Right to data portability

You have the right, under certain conditions, to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and the right to have this data transferred to another controller. This is the case if we process the data either on the basis of your consent or on the basis of a contract with you and that we process the data using automated procedures.

You have the right to request that we transfer your personal data directly to another controller, insofar as this is technically feasible and does not affect the freedoms and rights of other persons.

13.7    Right to object

You have the right to object at any time to the processing of your personal data based on Art. 6 (1) sentence 1 lit. e or lit. f GDPR for reasons arising from your particular situation. This also applies to profiling based on these provisions.

We will no longer process your personal data after an objection, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the assertion, exercise or defence of legal claims.

If we process your personal data for the purpose of direct marketing, you have the right to object at any time to the processing of your personal data for the purpose of such marketing. This also applies to profiling insofar as it is related to direct advertising. If you object to the processing of your personal data for direct marketing purposes, we will no longer process it for these purposes.

13.8    Right to withdraw your consent

You have the right to withdraw your consent at any time in accordance with Art. 7 (3) GDPR.  The withdrawal of consent does not retroactively invalidate the lawfulness of the processing.

13.9    Right of lodge a compaint with a supervisory authority

You have the right to lodge a complaint with a supervisory authority, without prejudice to any other administrative or judicial remedy. In particular, you may exercise your right to lodge a complaint in the Member State of your residence, place of work or place of the alleged infringement if you consider that the processing of your personal data infringes the GDPR.

An overview of the respective data protection commissioners of the German Bundesländer as well as their contact details can be found under the following link:

https://www.bfdi.bund.de/DE/Service/Anschriften/Laender/Laender-node.html

 

14.      Last update of this privacy policy

 

November 2023

 

Cookie Policy

 

Please note the following: You can ensure yourself that no cookies are stored on your computer at all, or that the storage of only certain cookies is permitted. You can select this in your internet browser settings. You can also view and delete the stored cookies there.

If you block all cookies, you may not be able to use all the features of our website.

We use cookies on our website. Cookies are text files that are sent to your browser by our web server when you visit our website and are stored on your computer for later retrieval. A cookie therefore enables your internet browser to be identified when you call up the website again.

There are session cookies, which are those that delete themselves when the browser is closed, and there are persistent cookies, which are stored on the hard disk until their preset expiry date is reached or until they are actively removed by you.

Some of the cookies we use on our website come from third parties that help us analyse the impact of our website content and the interests of our visitors, measure the performance of our website or serve ads and other content to our website or other websites. As part of our website, we use both first party cookies (only visible from the domain you are visiting) and third party cookies (visible across domains and set regularly by third parties).

In this context, we set the following types of cookies:

Technically necessary cookies: These are mandatory in order to navigate the website, use basic functions and ensure the security of the website; they do not collect information about you for marketing purposes nor do they store which web pages you have visited. The legal basis for setting technically necessary cookies is § 25 (2) TTDSG.

Optional cookies: We also use so-called analysis and marketing cookies on our website. Analysis cookies collect information about how you use our website, which pages you visit and, for example, whether errors occur during website use. Marketing cookies are used to show you tailored advertising on the website or offers from third parties and to measure the effectiveness of these offers. These are cookies that are not technically necessary. The legal basis for the setting of these cookies is therefore your consent in accordance with § 25 para. 1 TTDSG.

Possibility of revocation and removal

As communicated in the introduction to this section, you can enable or restrict the transmission of cookies by changing the settings in your Internet browser. Cookies that have already been stored by your internet browser can be deleted there at any time. If cookies are restricted or disabled for our website, it may not be possible to use all functionalities.

 

Information on the cookies set:

Information on the cookies set can be found in the individual cookie settings . There you can manage and withdraw the consent you have given at any time.

 

Last update of this cookie policy:

 

November 2023