Privacy Policy

We recognize and appreciate the responsible handling of personal data. The processing of personal data in connection with the online offer on the website https://traverise.com (hereinafter also referred to as “website”) is carried out in accordance with the General Data Protection Regulation (hereinafter “GDPR”) and the country-specific data protection regulations applicable to us.

The provision of your personal data on our website is generally not required by law or contract. Therefore, you are not obligated to provide personal data on this website unless we explicitly indicate this in the privacy policy below for the use of certain offers.

With the following privacy policy, we inform you about the type, scope, and purpose of the processing of personal data that we carry out when visiting our website. This privacy policy also informs you of the rights you have in connection with the processing of personal data.

I. Name and contact details of the person responsible for processing

The following information on data protection applies to data processing by:

Traverise GmbH
represented by its Managing Director Oliver Gerhardt
Sandweg 18
35745 Herborn

The data protection officer can be reached as follows:

Mark Alexander Kaldenbach
Address & contact options

II. General information on data processing

Scope of processing personal data

We process personal data of users of our website only to the extent necessary to provide a functional website and our content and services. The processing of personal data of our users regularly takes place only with their consent. An exception applies in cases where prior consent cannot be obtained for factual reasons and the processing of the data is permitted by legal regulations.

Legal basis for the processing of personal data

Insofar as we obtain the consent of the data subject for processing operations of personal data, Article 6(1)(a) of the GDPR serves as the legal basis.

When processing personal data necessary for the performance of a contract to which the data subject is a party, Article 6(1)(b) of the GDPR serves as the legal basis. This also applies to processing operations required for carrying out pre-contractual actions.

Insofar as processing of personal data is necessary for compliance with a legal obligation to which our company is subject, Article 6(1)(c) of the GDPR serves as the legal basis.

In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6(1)(d) of the GDPR serves as the legal basis.

If processing is necessary to safeguard a legitimate interest of our company or a third party, and the interests, fundamental rights, and freedoms of the data subject do not override the first interest, Article 6(1)(f) of the GDPR serves as the legal basis for processing.

Data deletion and duration of storage

The personal data of the data subject will be deleted or blocked as soon as the purpose of storage no longer applies. Storage may also take place if this is provided for by the European or national legislator in EU regulations, laws, or other provisions to which the controller is subject. Blocking or deletion of the data also takes place when a storage period prescribed by the mentioned norms expires, unless there is a need for further storage of the data for the conclusion or fulfillment of a contract.

Recipient of collected data

The recipient of the data collected via our website is the person responsible as mentioned under item I. In addition, the processors we may use (web hosts, technical support, etc.) have access to the data collected via our website. Compliance with the statutory regulations is ensured by order processing contracts that we conclude with our processors located in the EU.

Profiling

We note that we do not perform profiling via our website, nor is there any automated decision-making.

III. Provision of the website and collection of data for technical reasons

In connection with a purely informational visit to our website, we collect only the data that the browser you use automatically sends to the server of our website. This information is temporarily stored in a so-called logfile. The following information is collected without your intervention and stored until automated deletion:

IP address of the requesting computer,

Date and time of access,

Name and URL of the retrieved file,

Website from which access is made (referrer URL),

Browser used and, if applicable, the operating system of your computer and the name of your access provider

Message about successful retrieval,

and the amount of data transferred.

The mentioned data are processed by us for the following purposes:

Ensuring a smooth connection setup of the website,

Ensuring comfortable use of our website,

Evaluation of system security and stability, as well as

for further administrative purposes.

Our legitimate interest follows from the above purposes for data collection. In no case do we use the data for the purpose of drawing conclusions about you. The legal basis for the processing of the mentioned data is Article 6(1)(f) GDPR.

The server log files with the above-mentioned data are automatically deleted after XX days. We reserve the right to store the server log files for longer if there are facts that suggest an unauthorized access (such as an attempt at hacking or a so-called DDOS attack).

IV. Collection and storage of personal data and the nature and purpose of their use

When contacting us via email

When you contact us using an email address listed on the website, we store the data you provide (in particular your email address, your first and last name, possibly your phone number, etc.) to process and respond to your request.

The data processing in the aforementioned cases serves the purpose of processing the contact as a necessary legitimate interest. The legal basis for the processing of the data transmitted by you is Article 6(1)(f) GDPR.

The transmitted data will be deleted as soon as they are no longer necessary for the purpose of their collection, especially when the conversation with you has ended. The conversation is considered to have ended when it can be inferred from the circumstances that the relevant issue has been conclusively resolved.

V. Transfer of data to third parties

Except in the cases mentioned under section IV of this privacy policy, we only pass on your data to third parties if:

(1) You have given your express consent according to Article 6(1)(a) GDPR,

(2) The transfer according to Article 6(1)(f) GDPR is necessary for the assertion, exercise, and/or defense of legal claims and there is no reason to assume that you have an overriding interest in not transferring your data,

(3) In the event that there is a legal obligation for the transfer according to Article 6(1)(c) GDPR, and

(4) It is legally permissible and necessary according to Article 6(1)(b) GDPR for the processing of contractual relationships with you.

VI.

VII. Data subject rights

If your personal data is processed, you are a data subject within the meaning of the GDPR and you have the following rights against us as the controller:

Right of access

You can request confirmation from us as to whether personal data concerning you is being processed by us.

If such processing is taking place, you can request information from us about the following:

(a) the purposes for which the personal data is processed;

(b) the categories of personal data that are processed;

(c) the recipients or categories of recipients to whom the personal data concerning you has been or will be disclosed;

(d) the planned duration of storage of the personal data concerning you or, if specific information on this is not possible, criteria for determining the storage period;

(e) the existence of a right to rectification or deletion of the personal data concerning you, a right to restriction of processing by us as the controller, or a right to object to such processing;

(f) the existence of a right to lodge a complaint with a supervisory authority;

(g) all available information on the origin of the data if the personal data is not collected from the data subject;

(h) the existence of automated decision-making, including profiling, according to Article 22(1) and (4) GDPR and – at least in these cases – meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

You have the right to request information as to whether the personal data concerning you is transferred to a third country or an international organization. In this context, you can request to be informed about the appropriate safeguards according to Article 46 GDPR in connection with the transfer.

Right to rectification

You have a right to rectification and/or completion against us if the processed personal data concerning you is incorrect or incomplete. We must make the correction without undue delay.

Right to restriction of processing

You may request the restriction of the processing of your personal data under the following conditions:

(a) if you contest the accuracy of the personal data concerning you for a period enabling us to verify the accuracy of the personal data;

(b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;

(c) we no longer need the personal data for the purposes of processing, but you require them for the assertion, exercise, or defense of legal claims, or

(d) if you have objected to processing pursuant to Article 21(1) GDPR and it has not yet been determined whether our legitimate grounds override your reasons.

Where processing of personal data concerning you has been restricted, such data may – apart from being stored – only be processed with your consent or for the establishment, exercise, or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or a Member State.

If processing has been restricted under the above conditions, you will be informed by us before the restriction is lifted.

Right to erasure

Obligation to erase

You may request that we as the controller erase personal data concerning you without undue delay and we are obliged to erase this data without undue delay where one of the following reasons applies:

(1) The personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed.

(2) You withdraw your consent on which the processing was based according to Article 6(1)(a) or Article 9(2)(a) GDPR, and there is no other legal ground for the processing.

(3) You object to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) GDPR.

(4) The personal data concerning you have been unlawfully processed.

(5) The erasure of the personal data concerning you is necessary to fulfill a legal obligation under Union or Member State law to which we as the controller are subject.

(6) The personal data concerning you have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.

Information to third parties

If we have made the personal data concerning you public and are obliged to erase it according to Article 17(1) GDPR, we will take appropriate measures, including technical measures, considering the available technology and the cost of implementation, to inform data controllers who process the personal data that you as the data subject have requested the erasure of any links to, or copy or replication of, that personal data.

Exceptions

(1) for exercising the right of freedom of expression and information;

(2) for compliance with a legal obligation that requires processing by Union or Member State law to which we as the controller are subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;

(3) for reasons of public interest in the area of public health according to Article 9(2)(h) and (i) and Article 9(3) GDPR;

(4) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes according to Article 89(1) GDPR, insofar as the right referred to in section a) is likely to render impossible or seriously impair the achievement of the objectives of that processing, or

(5) for the establishment, exercise, or defense of legal claims.

Right to be informed

You have the right against us as the controller to be informed about these recipients.

If you have asserted the right to rectification, erasure, or restriction of processing against us, we are obliged to communicate any rectification or erasure of personal data or restriction of processing to each recipient to whom the personal data concerning you have been disclosed, unless this proves impossible or involves a disproportionate effort.

Right to data portability

You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used, and machine-readable format. Furthermore, you have the right to transmit this data to another controller without hindrance from us, to whom the personal data have been provided, provided that

(a) the processing is based on consent according to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR or on a contract according to Article 6(1)(b) GDPR and

(b) the processing is carried out using automated methods.

In exercising this right, you also have the right to have the personal data concerning you transferred directly from us to another controller, where technically feasible. Freedoms and rights of other people must not be affected by this.

The right to data portability does not apply to processing personal data necessary for performing a task carried out in the public interest or in the exercise of official authority vested in us as the controller.

Right to object

You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you, which is based on Article 6(1)(e) or (f) GDPR; this also applies to profiling based on these provisions.

We as the controller will no longer process the personal data concerning you unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing is for the establishment, exercise, or defense of legal claims.

If the personal data concerning you is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling, to the extent that it is related to such direct marketing.

If you object to processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.

You have the option, in connection with the use of information society services – notwithstanding Directive 2002/58/EC – to exercise your right

to object by automated means using technical specifications.

Right to withdraw the data protection consent declaration

You have the right to withdraw your data protection consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Automated decision in individual cases including profiling

You have the right not to be subject to a decision based solely on automated processing – including profiling – which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision

(1) is necessary for entering into, or performance of, a contract between you and us,

(2) is authorized by Union or Member State law to which we as the controller are subject, and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or

(3) takes place with your express consent.

However, these decisions must not be based on special categories of personal data according to Article 9(1) GDPR, unless Article 9(2)(a) or (g) GDPR applies and suitable measures to safeguard the rights and freedoms, as well as your legitimate interests, are in place.

In the cases referred to in points (1) and (3), we as the controller take suitable measures to safeguard the rights and freedoms and your legitimate interests, which includes at least the right to obtain human intervention on our part as the controller, to express your own point of view and to contest the decision.

Right to complain to a supervisory authority

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you believe that the processing of personal data relating to you infringes the GDPR.

The supervisory authority with which the complaint has been lodged will inform the complainant about the progress and the outcomes of the complaint, including the possibility of a judicial remedy pursuant to Article 78 GDPR.

VIII. Data security

Within the visit of the website, we use the widespread SSL (Secure Socket Layer) method in conjunction with the highest level of encryption supported by your browser. This is usually a 256-bit encryption. If your browser does not support 256-bit encryption, we resort to 128-bit v3 technology instead. You can tell whether an individual page of our website is transmitted encrypted by the closed representation of the key or lock symbol in the bottom status bar of your browser.

We also take appropriate technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction, or unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.

IX. Currency and amendment of this privacy policy

You are advised that it may become necessary to amend this privacy policy due to changed legal or regulatory requirements. The current privacy policy can be retrieved and printed out at any time on the website at https://traverise.com/.

April 2024