Privacy policy
1. data protection at a glance
General notes
The following notices provide a simple overview of what happens to your personal data when you visit this website. Personal data is any data by which you can be personally identified. For detailed information on the subject of data protection, please refer to our privacy policy listed below this text.
Data collection on this website
Who is responsible for the data collection on this website?
Data processing on this website is carried out by the website operator. You can find their contact details in the section “Information on the controller” in this privacy policy.
How do we collect your data?
On the one hand, your data is collected by you providing it to us. This may be, for example, data that you enter in a contact form.
Other data is collected automatically or after your consent when you visit the website by our IT systems. This is mainly technical data (e.g. Internet browser, operating system or time of page view). This data is collected automatically as soon as you enter this website.
What do we use your data for?
Part of the data is collected to ensure error-free provision of the website. Other data may be used to analyze your user behavior.
What rights do you have regarding your data?
You have the right at any time to receive information free of charge about the origin, recipient and purpose of your stored personal data. You also have a right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. You also have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.
You can contact us at any time if you have further questions on the subject of data protection.
Third-party analytics and tools
When visiting this website, your surfing behavior can be statistically analyzed. This is done mainly with so-called analysis programs.
Detailed information about these analysis programs can be found in the following privacy policy.
2. hosting
We host the content of our website with the following provider:
RAIDBOXES
The provider is RAIDBOXES GmbH, Hafenstr. 32, 48151 Münster, Germany (hereinafter RAIDBOXES). When you visit our website, RAIDBOXES collects various log files including your IP addresses.
For details, please refer to the RAIDBOXES privacy policy: https://raidboxes.io/legal/privacy/.
The use of RAIDBOXES is based on Art. 6 para. 1 lit. f GDPR. We have a legitimate interest in ensuring that our website is displayed as reliably as possible. If a corresponding consent was requested, the processing is based exclusively on Art. 6 para. 1 lit. a GDPR and Section 25 (1) TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s end device (e.g. for device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.
Order processing
We have concluded a data processing agreement (DPA) for the use of the above-mentioned service. This is a contract prescribed by data protection law, which ensures that it processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.
3. general notes and mandatory information
Data protection
The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.
When you use this website, various personal data are collected. Personal data is data with which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how this is done and for what purpose.
We would like to point out that data transmission on the Internet (e.g. when communicating by e-mail) can have security gaps. Complete protection of the data against access by third parties is not possible.
Note on the responsible entity
The responsible party for data processing on this website is:
Sonja Osinfade
Innere Wiener Straße 10
81667 Munich
Phone: +49 (0) 174 704 0200
E-mail: info@palomas-webservices.com
The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, e-mail addresses, etc.).
Storage duration
Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for data processing no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the deletion will take place after these reasons no longer apply.
General information on the legal basis for data processing on this website
If you have consented to data processing, we process your personal data on the basis of Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR, insofar as special categories of data are processed in accordance with Art. 9 para. 1 GDPR. In the event of express consent to the transfer of personal data to third countries, data processing is also carried out on the basis of Art. 49 para. 1 lit. a GDPR. If you have consented to the storage of cookies or access to information in your end device (e.g. via device fingerprinting), the data processing is also carried out on the basis of Section 25 (1) TTDSG. Consent can be revoked at any time. If your data is required to fulfill a contract or to carry out pre-contractual measures, we process your data on the basis of Art. 6 para. 1 lit. b GDPR. Furthermore, we process your data if this is necessary to fulfill a legal obligation on the basis of Art. 6 para. 1 lit. c GDPR. Data processing may also be based on our legitimate interest in accordance with Art. 6 para. 1 lit. f GDPR. Information on the relevant legal bases in each individual case is provided in the following paragraphs of this privacy policy.
Note on data transfer to the USA and other third countries
Among other things, we use tools from companies based in the USA or other third countries that are not secure under data protection law. If these tools are active, your personal data may be transferred to these third countries and processed there. We would like to point out that a level of data protection comparable to that in the EU cannot be guaranteed in these countries. For example, US companies are obliged to hand over personal data to security authorities without you as the data subject being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g. secret services) may process, evaluate and permanently store your data on US servers for surveillance purposes. We have no influence on these processing activities.
Revocation of your consent to data processing
Many data processing operations are only possible with your express consent. You can revoke an already given consent at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.
Right to object to data collection in special cases and to direct marketing (Art. 21 DSGVO)
IF THE DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6 ABS. 1 LIT. E OR F DSGVO, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS DATA PROTECTION DECLARATION. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING IS FOR THE ESTABLISHMENT, EXERCISE OR DEFENSE OF LEGAL CLAIMS (OBJECTION UNDER ARTICLE 21(1) DSGVO).
IF YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS ASSOCIATED WITH SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21 PARA. 2 DSGVO).
Right of complaint to the competent supervisory authority
In the event of breaches of the GDPR, data subjects shall have a right of appeal to a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged breach. The right of appeal is without prejudice to other administrative or judicial remedies.
Right to data portability
You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.
Information, deletion and correction
Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipient and the purpose of data processing and, if applicable, a right to correction or deletion of this data. You can contact us at any time if you have further questions on the subject of personal data.
Right to restriction of processing
You have the right to request the restriction of the processing of your personal data. You can contact us at any time for this purpose. The right to restrict processing exists in the following cases:
- If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the review, you have the right to request the restriction of the processing of your personal data.
- If the processing of your personal data happened/is happening unlawfully, you may request the restriction of data processing instead of erasure.
- If we no longer need your personal data, but you need it to exercise, defend or enforce legal claims, you have the right to request restriction of the processing of your personal data instead of deletion.
- If you file an objection pursuant to Art. 21 para. 1 DSGVO, a balance must be struck between your interests and ours. As long as it has not yet been determined whose interests prevail, you have the right to demand the restriction of the processing of your personal data.
If you have restricted the processing of your personal data, this data may – apart from being stored – only be processed with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest of the European Union or a Member State.
SSL or TLS encryption
This site uses SSL or TLS encryption for security reasons and to protect the transmission of confidential content, such as orders or requests that you send to us as the site operator. You can recognize an encrypted connection by the fact that the browser address bar changes from “http://” to “https://” and by the lock symbol in your browser bar.
If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
4. data collection on this website
Cookies
Our Internet pages use so-called “cookies”. Cookies are small data packets and do not cause any damage to your end device. They are stored either temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your terminal device. Session cookies are automatically deleted after the end of your visit. Permanent cookies remain stored on your terminal device until you delete them yourself or until they are automatically deleted by your web browser.
Cookies may originate from us (first-party cookies) or from third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services from third-party companies within websites (e.g. cookies for processing payment services).
Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies can be used to evaluate user behavior or for advertising purposes.
Cookies that are required to carry out the electronic communication process, to provide certain functions that you have requested (e.g. for the shopping cart function) or to optimize the website (e.g. cookies to measure the web audience) (necessary cookies) are stored on the basis of Art. 6 para. 1 lit. a GDPR. 1 lit. f DSGVO, unless another legal basis is specified. The website operator has a legitimate interest in the storage of necessary cookies for the technically error-free and optimized provision of its services. If consent to the storage of cookies and comparable recognition technologies has been requested, the processing is carried out exclusively on the basis of this consent (Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG); the consent can be revoked at any time.
You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. When cookies are disabled, the functionality of this website may be limited.
You can find out which cookies and services are used on this website in this privacy policy.
Consent with Borlabs Cookie
Our website uses Borlabs Cookie consent technology to obtain your consent to the storage of certain cookies in your browser or to the use of certain technologies and to document these in compliance with data protection regulations. The provider of this technology is Borlabs GmbH, Rübenkamp 32, 22305 Hamburg, Germany (hereinafter referred to as Borlabs).
When you enter our website, a Borlabs cookie is stored in your browser, in which the consents you have given or the revocation of these consents are stored. This data is not passed on to the provider of Borlabs Cookie.
The data collected will be stored until you ask us to delete it or delete the Borlabs cookie yourself or until the purpose for storing the data no longer applies. Mandatory statutory retention periods remain unaffected. Details on data processing by Borlabs Cookie can be found at https://de.borlabs.io/kb/welche-daten-speichert-borlabs-cookie/.
Borlabs cookie consent technology is used to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6 para. 1 lit. c GDPR.
Contact form
If you send us inquiries via the contact form, the information you provide in the inquiry form, including the contact data you enter there, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We do not share this data without your consent.
The processing of this data is based on Art. 6 para. 1 lit. b DSGVO, provided that your request is related to the performance of a contract or is necessary for the performance of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested; the consent can be revoked at any time.
The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies (e.g. after we have completed processing your request). Mandatory legal provisions – in particular retention periods – remain unaffected.
Request by e-mail, phone or fax
If you contact us by e-mail, telephone or fax, your inquiry including all resulting personal data (name, inquiry) will be stored and processed by us for the purpose of processing your request. We do not share this data without your consent.
The processing of this data is based on Art. 6 para. 1 lit. b DSGVO, provided that your request is related to the performance of a contract or is necessary for the performance of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6 para. 1 lit. f GDPR) or on your consent (Art. 6 para. 1 lit. a GDPR) if this has been requested; the consent can be revoked at any time.
The data you send to us via contact requests will remain with us until you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies (e.g. after we have completed processing your request). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected.
5. analysis tools and advertising
Google Tag Manager
We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
Google Tag Manager is a tool that enables us to integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store any cookies and does not carry out any independent analyses. It is only used to manage and display the tools integrated via it. However, Google Tag Manager records your IP address, which may also be transmitted to Google’s parent company in the United States.
The use of Google Tag Manager is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the fast and uncomplicated integration and management of various tools on its website. If a corresponding consent was requested, the processing is based exclusively on Art. 6 para. 1 lit. a GDPR and Section 25 (1) TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s end device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.
Google Analytics
This website uses functions of the web analysis service Google Analytics. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics enables the website operator to analyze the behavior of website visitors. The website operator receives various usage data, such as page views, length of visit, operating systems used and origin of the user. This data is assigned to the user’s end device. It is not assigned to a user ID.
We can also use Google Analytics to record your mouse and scroll movements and clicks, among other things. Google Analytics also uses various modeling approaches to supplement the collected data records and uses machine learning technologies for data analysis.
Google Analytics uses technologies that enable the recognition of the user for the purpose of analyzing user behavior (e.g. cookies or device fingerprinting). The information collected by Google about the use of this website is generally transmitted to a Google server in the USA and stored there.
The use of this service is based on your consent in accordance with Art. 6 para. 1 lit. a GDPR and Section 25 (1) TTDSG. Consent can be revoked at any time.
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. You can find details here: https://privacy.google.com/businesses/controllerterms/mccs/.
Browser plugin
You can prevent the collection and processing of your data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
You can find more information on how Google Analytics handles user data in Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=de.
Order processing
We have concluded an order processing contract with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.
Google Ads
The website operator uses Google Ads. Google Ads is an online advertising program of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
Google Ads enables us to display advertisements in the Google search engine or on third-party websites when the user enters certain search terms on Google (keyword targeting). Furthermore, targeted advertisements can be displayed based on the user data available at Google (e.g. location data and interests) (target group targeting). As the website operator, we can evaluate this data quantitatively by analyzing, for example, which search terms led to the display of our advertisements and how many advertisements led to corresponding clicks.
The use of this service is based on your consent in accordance with Art. 6 para. 1 lit. a GDPR and Section 25 (1) TTDSG. Consent can be revoked at any time.
Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://policies.google.com/privacy/frameworks and https://privacy.google.com/businesses/controllerterms/mccs/.
6. plugins and tools
Font Awesome
This site uses Font Awesome for the uniform display of fonts and symbols. The provider is Fonticons, Inc, 6 Porter Road Apartment 3R, Cambridge, Massachusetts, USA.
When you call up a page, your browser loads the required fonts into your browser cache in order to display texts, fonts and symbols correctly. For this purpose, the browser you are using must connect to Font Awesome’s servers. This gives Font Awesome knowledge that this website has been accessed via your IP address. The use of Font Awesome is based on Art. 6 para. 1 lit. f GDPR. We have a legitimate interest in the uniform presentation of the typeface on our website. If a corresponding consent was requested, the processing is based exclusively on Art. 6 para. 1 lit. a GDPR and Section 25 (1) TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s end device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.
If your browser does not support Font Awesome, a standard font will be used by your computer.
Further information about Font Awesome can be found in Font Awesome’s privacy policy at: https://fontawesome.com/privacy.
Google reCAPTCHA
We use “Google reCAPTCHA” (hereinafter “reCAPTCHA”) on this website. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.
The purpose of reCAPTCHA is to verify whether the data entry on this website (e.g. in a contact form) is made by a human or by an automated program. For this purpose, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis starts automatically as soon as the website visitor enters the website. For analysis, reCAPTCHA evaluates various information (e.g. IP address, time spent by the website visitor on the website or mouse movements made by the user). The data collected during the analysis is forwarded to Google.
The reCAPTCHA analyses run completely in the background. Website visitors are not made aware that an analysis is taking place.
The storage and analysis of the data is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in protecting its web offers from abusive automated spying and from SPAM. If a corresponding consent was requested, the processing is based exclusively on Art. 6 para. 1 lit. a GDPR and Section 25 (1) TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s end device (e.g. device fingerprinting) within the meaning of the TTDSG. Consent can be revoked at any time.
For more information about Google reCAPTCHA, please refer to the Google Privacy Policy and the Google Terms of Use at the following links: https://policies.google.com/privacy?hl=de and https://policies.google.com/terms?hl=de.
7. eCommerce and payment providers
Processing of customer and contract data
We collect, process and use personal customer and contract data to establish, structure the content of and amend our contractual relationships. We collect, process and use personal data about the use of this website (usage data) only insofar as this is necessary to enable or charge the user for the use of the service. The legal basis for this is Art. 6 para. 1 lit. b GDPR.
The customer data collected will be deleted after completion of the order or termination of the business relationship and expiry of any existing statutory retention periods. Statutory retention periods remain unaffected.
8. own services
Handling applicant data
We offer you the opportunity to apply to us (e.g. by e-mail, post or via the online application form). Below we inform you about the scope, purpose and use of your personal data collected as part of the application process. We assure you that your data will be collected, processed and used in accordance with applicable data protection law and all other statutory provisions and that your data will be treated in strict confidence.
Scope and purpose of data collection
If you send us an application, we will process your associated personal data (e.g. contact and communication data, application documents, notes taken during job interviews, etc.) insofar as this is necessary to decide on the establishment of an employment relationship. The legal basis for this is Section 26 BDSG under German law (initiation of an employment relationship), Art. 6 para. 1 lit. b GDPR (general contract initiation) and – if you have given your consent – Art. 6 para. 1 lit. a GDPR. Consent can be revoked at any time. Your personal data will only be passed on within our company to persons who are involved in processing your application.
If the application is successful, the data submitted by you will be processed on the basis of § 26 BDSG and Art. 6 para. 1 lit. b GDPR for the purpose of implementing the employment relationship in our data processing systems.
Data retention period
If we are unable to make you a job offer, you reject a job offer or withdraw your application, we reserve the right to retain the data you have submitted on the basis of our legitimate interests (Art. 6 para. 1 lit. f GDPR) for up to 6 months from the end of the application process (rejection or withdrawal of the application). The data will then be deleted and the physical application documents destroyed. The retention serves in particular as evidence in the event of a legal dispute. If it is evident that the data will be required after the expiry of the 6-month period (e.g. due to an impending or pending legal dispute), deletion will only take place when the purpose for further storage no longer applies.
Data may also be stored for longer if you have given your consent (Art. 6 para. 1 lit. a GDPR) or if statutory retention obligations prevent deletion.
Inclusion in the applicant pool
If we do not make you a job offer, you may have the opportunity to be included in our applicant pool. If you are accepted, all documents and details from your application will be transferred to the applicant pool so that you can be contacted in the event of suitable vacancies.
Inclusion in the applicant pool is based exclusively on your express consent (Art. 6 para. 1 lit. a GDPR). Giving your consent is voluntary and is not related to the current application process. The data subject can withdraw their consent at any time. In this case, the data will be irrevocably deleted from the applicant pool, provided there are no legal grounds for retention.
The data from the applicant pool will be irrevocably deleted no later than two years after consent has been granted.