Privacy policy

Important note regarding the privacy policy

This data protection declaration informs you about the type, scope and purpose of the processing of personal data (hereinafter referred to as “data”) within the scope of the provision of our services as well as within our online offer and the websites, functions and contents connected with it as well as external online presences, such as our social media profiles (hereinafter jointly referred to as “online offer”). With regard to the terms used, such as “processing” or “controller”, we refer to the definitions in Art. 4 of the General Data Protection Regulation (GDPR).

Person responsible

Digital Content L.L.C
Business Center 1, M Floor
Dubai
United Arab Emirates

+49 170 367 5215
+971 58 538 4721
office@firmengruendung-dubai.net

Types of data processed

  • Inventory data (e.g., personal master data, names or addresses).
  • Contact data (e.g., email, telephone numbers).
  • Content data (e.g., text entries, photographs, videos).
  • Usage data (e.g., web pages visited, interest in content, access times).
  • Meta/communication data (e.g., device information, IP addresses).

Categories of persons concerned

Visitors and users of the online offer (hereinafter we also refer to the data subjects collectively as “users”).

Purpose of processing

  • Provision of the online offer, its functions and contents.
  • Answering contact requests and communicating with users.
  • Security measures.
  • Reach measurement/marketing

Terms used

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter “data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (e.g. cookie) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

“Pseudonymisation” means the processing of personal data in such a way that personal data can no longer be related to a specific data subject without additional information, provided that such additional information is kept separately and is subject to technical and organisational measures which ensure that the personal data are not attributed to an identified or identifiable natural person.

“Profiling” means any automated processing of personal data which consists in using such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or change of location.

“Controller” means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data.

“Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

Relevant legal bases

In accordance with Art. 13 DSGVO, we inform you about the legal basis of our data processing. For users from the area of application of the General Data Protection Regulation (GDPR), i.e. the EU and the EEC, the following applies if the legal basis is not mentioned in the data protection declaration:
The legal basis for obtaining consent is Art. 6 para. 1 lit. a and Art. 7 DSGVO;
The legal basis for processing for the fulfilment of our services and implementation of contractual measures as well as answering enquiries is Art. 6 (1) lit. b DSGVO;


The legal basis for processing for the fulfilment of our legal obligations is Art. 6 para. 1 lit. c DSGVO;
In the event that vital interests of the data subject or another natural person make it necessary to process personal data, Art. 6 (1) (d) DSGVO serves as the legal basis.

The legal basis for the processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller is Article 6(1)(e) of the GDPR.
The legal basis for processing to protect our legitimate interests is Art. 6 (1) lit. f DSGVO.
The processing of data for purposes other than those for which it was collected is determined by the requirements of Art. 6 (4) DSGVO.
The processing of special categories of data (in accordance with Art. 9 (1) of the Data Protection Regulation) is governed by the provisions of Art. 9 (2) of the Data Protection Regulation.

Security measures

We take appropriate technical and organisational measures to ensure a level of protection appropriate to the risk, in accordance with the law and taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of natural persons.

The measures include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical access to the data, as well as access to, input, disclosure, ensuring availability and segregation of the data. We also have procedures in place to ensure the exercise of data subjects’ rights, deletion of data and response to data compromise. Furthermore, we already take the protection of personal data into account in the development and selection of hardware, software and procedures, in accordance with the principle of data protection through technology design and through data protection-friendly default settings.

Cooperation with processors, joint controllers and third parties

If, in the course of our processing, we disclose data to other persons and companies (order processors, jointly responsible persons or third parties), transmit it to them or otherwise grant them access to the data, this is only done on the basis of a legal permission (e.g. if a transmission of the data to third parties, such as to payment service providers, is necessary for the fulfilment of the contract), users have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).

If we disclose or transfer data to other companies in our group of companies or otherwise grant them access, this is done in particular for administrative purposes as a legitimate interest and, in addition, on a basis that complies with the legal requirements.

Transmissions to third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA) or the Swiss Confederation) or do so in the context of using third-party services or disclosing or transferring data to other persons or companies, this will only be done if it is done to fulfil our (pre-)contractual obligations, on the basis of your consent, due to a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we will only process or allow data to be processed in a third country if the legal requirements are met. This means, for example, that the processing is carried out on the basis of special guarantees, such as the officially recognised determination of a level of data protection corresponding to the EU or compliance with officially recognised special contractual obligations.

Rights of data subjects

You have the right to obtain confirmation as to whether or not data relating to you is being processed and to obtain information about such data, as well as further information and a copy of the data in accordance with the law.

You have the right, in accordance with the law, to request that data concerning you be completed or that inaccurate data concerning you be corrected.

You have the right, in accordance with the law, to request that data concerning you be deleted immediately or, alternatively, to request restriction of the processing of the data in accordance with the law.

You have the right to demand that the data relating to you that you have provided to us be received in accordance with the statutory provisions and to demand that it be transferred to other persons responsible.

You also have the right to lodge a complaint with the competent supervisory authority in accordance with the law.

Right of withdrawal

You have the right to revoke any consent you have given with effect for the future.

Right of objection

You can object to the future processing of the data concerning you at any time in accordance with the legal requirements. The objection can be made in particular against the processing for purposes of direct advertising.

Cookies and right to object to direct advertising

Cookies” are small files that are stored on users’ computers. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his or her visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online offer and closes his or her browser. In such a cookie, for example, the contents of a shopping basket in an online shop or a login status can be stored. Cookies that remain stored even after the browser is closed are referred to as “permanent” or “persistent”. For example, the login status can be stored if users visit them after several days. Likewise, the interests of users can be stored in such a cookie, which is used for range measurement or marketing purposes. Third-party cookies” are cookies that are offered by providers other than the responsible party that operates the online offer (otherwise, if they are only its cookies, they are referred to as “first-party cookies”).

We may use temporary and permanent cookies and explain this in our privacy policy.

If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general objection to the use of cookies used for online marketing purposes can be declared for a large number of services, especially in the case of tracking, via the US American site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be achieved by deactivating them in the browser settings. Please note that not all functions of this online offer can then be used.

Deletion of data

The data processed by us will be deleted or restricted in its processing in accordance with the legal requirements. Unless expressly stated within the scope of this data protection declaration, 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 is blocked and not processed for other purposes. This applies, for example, to data that must be retained for reasons of commercial or tax law.

Changes and updates to the privacy policy

We ask you to regularly inform yourself about the content of our data protection declaration. We adapt the data protection declaration as soon as the changes in the data processing carried out by us make this necessary. We will inform you as soon as the changes require an act of cooperation on your part (e.g. consent) or other individual notification.

Business processing

Additionally we process

  • Contract data (e.g., subject matter of the contract, term, customer category).
  • Payment data (e.g., bank details, payment history).
    of our customers, interested parties and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.

Order processing in the online shop and customer account

We process the data of our customers in the context of the ordering processes in our online shop in order to enable them to select and order the selected products and services, as well as their payment and delivery, or execution.

The data processed includes inventory data, communication data, contract data, payment data and the persons affected by the processing include our customers, interested parties and other business partners. The processing is carried out for the purpose of providing contractual services within the scope of operating an online shop, billing, delivery and customer services. We use session cookies to store the contents of the shopping cart and permanent cookies to store the login status.

The processing is carried out for the fulfilment of our services and the implementation of contractual measures (e.g. implementation of order processes) and insofar as it is required by law (e.g. legally required archiving of business transactions for commercial and tax purposes). In this context, the information marked as required is necessary for the justification and fulfilment of the contract. We only disclose the data to third parties within the scope of delivery, payment or within the scope of legal permits and obligations, as well as if this is based on our legitimate interests, which we inform you about within the scope of this data protection declaration (e.g., vis-à-vis legal and tax advisors, financial institutions, freight companies and authorities).

Users can optionally create a user account, in which they can view their orders in particular. During the registration process, users are provided with the required mandatory information. The user accounts are not public and cannot be indexed by search engines. If users have cancelled their user account, their data relating to the user account will be deleted, subject to their retention being necessary for reasons of commercial or tax law. Information in the customer account remains until its deletion with subsequent archiving in the event of a legal obligation or our legitimate interests (e.g., in the event of legal disputes). It is the responsibility of the users to save their data in the event of termination before the end of the contract.

Within the scope of registration and renewed logins as well as the use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests as well as those of the users in protection against misuse and other unauthorised use. As a matter of principle, this data is not passed on to third parties unless it is necessary for the pursuit of our legal claims as a legitimate interest or there is a legal obligation to do so.

Deletion takes place after expiry of legal warranty and other contractual rights or obligations (e.g. payment claims or performance obligations from contracts with customers), whereby the necessity of storing the data is reviewed every three years; in the case of storage due to legal archiving obligations, deletion takes place after their expiry.

Agency services

We process our clients’ data within the scope of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, implementation of campaigns and processes/handling, server administration, data analysis/consulting services and training services.

In doing so, we process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g., text entries, photographs, videos), contract data (e.g., subject matter of the contract, term), payment data (e.g., bank details, payment history), usage and metadata (e.g., in the context of evaluating and measuring the success of marketing measures). As a matter of principle, we do not process special categories of personal data, unless these are components of commissioned processing. The data subjects include our customers, interested parties as well as their customers, users, website visitors or employees as well as third parties. The purpose of the processing is the provision of contractual services, billing and our customer service. The legal basis for the processing results from Art. 6 para. 1 lit. b DSGVO (contractual services), Art. 6 para. 1 lit. f DSGVO (analysis, statistics, optimisation, security measures). We process data that is necessary for the justification and fulfilment of contractual services and point out the necessity of their disclosure. Disclosure to external parties only takes place if it is necessary in the context of an order. When processing the data provided to us within the scope of an order, we act in accordance with the instructions of the client as well as the legal requirements of a commissioned processing pursuant to Art. 28 DSGVO and do not process the data for any other purposes than those specified in the order.

We delete the data after the expiry of statutory warranty and comparable obligations. the necessity of retaining the data is reviewed every three years; in the case of statutory archiving obligations, deletion takes place after their expiry (6 years, in accordance with § 257 para. 1 HGB, 10 years, in accordance with § 147 para. 1 AO). In the case of data disclosed to us by the client within the scope of an order, we delete the data in accordance with the specifications of the order, in principle after the end of the order.