Privacy Policy

Any collection, processing and use (hereinafter "use") of data is solely for the purpose of providing our services. The services of Vicodo - FreudeSchenken AG have been designed to use as little personal information as possible. For that matter, "personal data" is understood as all individual details about a person or factual circumstances of an identifiable natural person (so-called "affected person"). The following information on data protection describes what types of personal data are processed when accessing our website (https://www.vicodo.com/) and when using our app (http://app.vicodo.com/), what happens to this personal data and how you may object to data processing.

I. General information on data processing

1. Person Responsible (Controller)

Responsible within the meaning of the EU General Data Protection Regulation (GDPR) and the new Federal Data Protection Act (BDSG) is:

Vicodo - FreudeSchenken AG
Address: Kemperplatz 1, 10785 Berlin Germany
Phone: +49 (0) 30 120 644 630
Email: service@vicodo.com
Homepage: https://www.vicodo.com/

2. Name and address of the Data Security Officer

The data security officer is:

Kemal Webersohn of WS Datenschutz GmbH

If you have questions about data protection, you can contact us under the following email address: privacy@vicodo.com

WS Datenschutz GmbH
Dircksenstraße 51
D-10178 Berlin

3. Protection of your data

We have taken technical and organizational measures to ensure that the requirements of the EU General Data Protection Regulation (GDPR) are met by us, as well as, by external service providers working for us.

If we work with other companies to provide our services, such as email and server providers, this will only be done after an extensive selection process. In this selection process, each individual service provider is carefully selected for its suitability in terms of technical and organizational data protection skills. This selection procedure will be documented in writing and an agreement on the order processing of data (order processing contract) will only be concluded if the third party complies with the requirements of Art. 28 GDPR.

Your information will be stored on specially protected servers. Access to it is only possible for a few specially authorized persons.

4. Erasure of personal data

We process personal data only if necessary. As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.

II. Use of data on this website and in logfiles

1. Scope of processing personal data

When visiting our website, our web servers temporarily store every access in a log file. The following data is collected and stored until automated erasure:

· Date and time of access

· Name and URL of the retrieved file

· Message if the retrieval was successful

· Detection data of the browser and operating system used

· Name of your Internet access provider

We or our partners may process additional data occasionally. You will find information about this below.

2. Legal basis for processing personal data

The legal basis for the temporary storage of the data and log files is Art. 6 para. 1 s. 1 lit. f) of the GDPR. Our legitimate interest is to make our website accessible for you.

3. Purpose of data processing

The processing of this data serves: the purpose of enabling the use of the website (connection establishment), system security, the technical administration of the network infrastructure, as well as to optimize the website. The IP address is evaluated only in case of attacks on our network infrastructure or the network infrastructure of our internet provider.

Furthermore, no input of your personal data is required to use our website.

4. Duration of storage

As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out. This happens as soon as you close our website. Our hosting service might use data for statistical purposes. Any personal data will be anonymized for this. Our hosting service will delete this data after a period of 30 days.

5. Right of objection and erasure

The data processing is necessary in order to present the website and to ensure the website’s operation. Therefore, objecting is impossible.

III. Use of cookies

1. Description and scope of data processing

Our website is using cookies. Cookies are stored on your computer when you use our website. Cookies are small text files which are stored on your hard drive assigned to the browser you use. Through this information flows to us or the party who set the cookie. Cookies cannot run programs on or transmit viruses to your computer. Cookies are used to analyze the use of our website in anonymized or pseudonymized form and to enable personalized advertisements on this website. The following data may be transmitted:

· Frequency of website visits

· Which functions of the website are used by you

· Your cookie-settings

· Language settings

· Used search terms

Upon entering this website, a cookie banner informs you about the use of cookies on this website and asks for your consent to the use of cookies. Also, you are pointed to the data privacy statement of this website.

Note on data processing in the USA by Google and LinkedIn:

By clicking on "Agree to All", you agree in accordance with Art. 6 sec. 1 p. 1 lit. a) GDPR that your data will be processed in the USA. The ECJ considers that the data protection standard in the US is insufficient and that there is a risk that your data will be processed by the US authorities for control and monitoring purposes, possibly without any redress. If you only agree to set essential cookies, the transmission will not take place. Consent given may be revoked at any time.

2. Legal basis for data processing

The legal basis for the processing of data by cookies, which do not only serve the functionality of our website, is Art. 6 para. 1 s. 1 lit. a) GDPR.

The legal basis for the processing of data for cookies, which serve only the functionality of this website, is Art. 6 para. 1 s. 1 lit. f) GDPR.

3. Purpose of data processing

Our legitimate interests are to provide you with a working website connection and to ensure a comfortable use of this website. Also, we need to process your personal data to solve occurring safety and security issues, as well as to ensure system stability.

The data processing takes place to make a statistical evaluation of our website possible.

4. Duration of storage

This website uses the following types of cookies. The extend and function of each are being explained below:

Transient cookies (see a)
Persistent cookies (see b)

a) Transient cookies are automatically deleted when you close the browser. This is especially true for session cookies which store your session ID, with which various requests from your browser can be assigned to your session. This will allow your computer to be recognized when you return to our website. Session cookies are deleted when you log out or close the browser.

b) Persistent cookies are automatically deleted after a specified period, which may differ depending on the cookie.

5. Right to objection and erasure

You have the possibility to revoke your consent to the data processing by means of cookies, which do not only serve the functionality of the website. In addition, we do not set cookies until you have agreed to set cookies when you visit the site. In this way, you can prevent data processing via cookies on our website. You can also delete the cookies in your browser's security settings at any time. Please note that you may not be able to use all the features of this website. The setting of cookies can also be prevented at any time by appropriate settings in your internet browser.

IV. Contact

1. Description and scope of data processing

Via our website it is possible to contact us via e-mail or via contact form. This will require different data to answer the request, which will be automatically saved for processing. The following data are required to process your request:

· Email address

· Name

· Checkbox data processing

Furthermore, you can enter the following data optionally:

· Company

· Message

Your data will not be passed on to third parties unless you have given your consent.

2. Legal basis for data processing

The legal basis depends on your consent, Art. 6 para. 1 s. 1 lit. a) GDPR.

3. Purpose of data processing

The processing of personal data from the input form is used solely handling the contact request.

4. Duration of storage

The data will be deleted as soon as we answer your request. There might occur rare cases when legal or contractual retention periods interfere with the erasure of your personal data. In this case your data will be deleted after these periods.

5. Right to objection and erasure

You can revoke your given consent any time. In such cases, the conversation cannot be continued. All personal data that has been stored in the course of the contact will be deleted.

6. Vicodo widget

a. Description and scope of data processing

We use our own chat widget on our website. With the chat you have the possibility to get in contact with us in an uncomplicated way directly on the website. After you have actively clicked on the widget and initiated a video call or chat, the following data can be processed by us:

· Content of the chat

· Uploaded files

· audio communication data

· Video communications data

Vicodo also collects the following technical data to enable communication via chat:

· Browser type

· Browser version

· Operating system

· Device type

· Display resolution

You also have the option of entering your name and email address if you contact us via chat but no employee can receive your request at this time.

b. Legal basis for data processing

The data processing serves to establish contact within the framework of a (pre-) contractual relationship in accordance with Art. 6 para. 1 s. 1 lit. b) GDPR.

c. Purpose of data processing

With the help of the widget, we offer you a direct option to contact us quickly and easily via our website. It is possible to contact us via chat or a video request.

d. Duration of storage

After the data has been collected, it is transferred to our Vicodo dashboard and saved there. The data will be deleted as soon as the purpose of the data processing has been fulfilled and there are no legal, contractual or official retention periods to prevent deletion. The chat history is stored on your device until we have marked it as complete. The history is then actively deleted from your device (browser) after 48 hours.

e. Right to objection and erasure

You have the option to object to data processing at any time. You can also delete the chat history at any time by selecting the deletion of the chat history in the chat menu and confirming the deletion again. This data is then deleted from the system and can no longer be assigned by us.

7. Appointment booking

a. Description and scope of data processing

To book an appointment with us, you can use our appointment booking page and make an appointment with us that suits you. In order to book an appointment with us, the following data is processed by us:

· Surname

· E-mail address

· Selected appointment slot

Optionally, you can also enter the following data:

· Company

· Telephone number

· Notes

After booking your appointment, you will receive a confirmation of the selected appointment by email or SMS. We will also receive an email with the data you have provided and the appointment will be created in our Vicodo dashboard. If our employee connects his external calendar with the appointment booking, your selected appointment will be transferred directly to his calendar.

In addition, the following technical data is processed:

· Time of booking

· Browser type and browser version

· Operating system

· Device type

· Display resolution

b. Legal basis for data processing

The legal basis for data processing is Art. 6 para. 1 s. 1 lit. b) GDPR.

c. Purpose of data processing

The data is processed by us in order to enable you to book an appointment with us easily and without complications and to be able to contact you for the selected appointment. Vicodo processes the data to enable you to book an appointment, for diagnostic purposes and, if necessary, to prevent spam.

d. Duration of data storage

The data will be deleted as soon as the purpose of the data processing has been fulfilled. In this case, we actively delete the data from the dashboard or via API, provided that there are no legal, contractual or official retention requirements that prevent deletion.

e. Right to objection and erasure

You have the option to object to data processing at any time. Please contact us for this.

8. Audio and video conference

a. Description and scope of data processing

If we would like to arrange a video conference with you. To do this, one of our employees will enter your name, your email address and your telephone number into our dashboard. Vicodo will automatically send you a video call invitation. This invitation contains the link to the invitation page.

The following data will be processed by us as part of our conversation:

· Two-way chat messages

· Files (Word, Excel, PDF, photos, ...)

· Audio and video communication

· Possibly location information (GPS)

You also have the option of voluntarily saving a rating as a rating note after the interview.

The following data is processed to provide the services:

· Browser type and browser version

· Operating system

· Device type

· Display resolution

· Your email address / telephone number and your name for sending the invitation link

b. Legal basis for data processing

The data processing takes place on the basis of our (pre-) contractual relationship with which the conversation takes place in accordance with Art. 6 para. 1 s. 1 lit. b) GDPR.

c. Purpose of data processing

The data processing takes place in order to be able to conduct an audio or video conference with you and to be able to record important conversation contents. The technical data is processed to enable a conversation between us, for diagnostic purposes and, if necessary, to prevent spam. Your name and your email address or telephone number will also be processed by Vicodo in order to be able to send you the invitation link.

d. Duration of storage

e. Right to objection and erasure

You have the option to object to data processing at any time. Please contact us for this.

V. Data processing for applications

1. Description and scope of data processing

We offer the opportunity to apply for jobs by email. For this purpose, personal data is processed and stored for further processing during the respective application process.

2. Legal basis for data processing

Data processing will be based on Art. 88 GDPR and § 26 BDSG (2018).

3. Purpose of data processing

We process your data exclusively for the purpose of carrying out the application process.

4. Duration and storage

In case of successful application and employment, the personal data is stored in accordance with the legal requirements. In case of unsuccessful application, the data will be deleted in accordance with the rules of the local erasure concept. In doing so the provisions of the AGG (German Employment Law), especially the existing evidence pursuant to § 22 AGG, are taken into account.

This does not apply if we are obliged to any legal erasure periods or if you have given consent to store your data for further communication with us (e.g. we have another suitable job in the future). If you have given consent the legal basis for further storage of your data is Art. 6 para. 1 s. 1 lit. c) or lit. a) GDPR.

5. Right to objection and erasure

You can contact us at any time and object to further processing of your data. All personal data of the application process will be deleted in this case.

VI. Licenses

1. Description and scope of data processing

If you wish to purchase our software subscriptions, we will process:

· Name

· Address

· telephone number

· e-mail address.

2. Legal basis for data processing

The legal basis for this data processing is Art. 6 para. 1 s.1 lit. b) GDPR. We are processing your data for the fulfilment of purchase contracts.

3. Purpose of data processing

We process your data to close the contract, to handle the payment, for billing, to ensure on-time delivery and to inform you about that delivery.

We provide your data to our contracted processors and service providers, so that they can process the delivery and, if necessary, communicate with you to announce and coordinate the delivery of your ordered goods.

4. Duration of storage

We process personal data only as long as necessary. As soon as the purpose of the data processing is fulfilled, erasure of the data is carried out according to the standards of the erasure concept, unless legal or contractual regulations oppose this.

5. Right to objection and erasure

The data processing is necessary in order to be able to process your purchase contract, which is why it cannot be waived. There is therefore no option to object.

6. Stripe

a. Description and scope of data processing

We use stripe to process online payments. The data processing is carried out by: Stripe, Inc., 510 Townsend Street, San Francisco, CA 94103, USA.

The following data can be processed by Stripe:

· Information about the payment method (credit or derbit card number or bank account information)

· Purchase amount

· Date of Name of credit card owner and

· Credit card validity

· purchase

· Payment method

· Name

· E-mail address

· Billing or delivery address

· In some cases, the transaction history to authenticate you

Where fraud monitoring is carried out, data from publicly available sources (e.g. name, address, telephone number, country) will be processed to the extent necessary to confirm your identity and prevent fraud.

We rely on data security at Stripe. All specified card numbers are encrypted with AES-256. The infrastructure for storing, decrypting, and transferring card numbers is completely separate and uses different credentials than Stripe's primary services. Stripe is also certified to the highest industry standards and has worldwide regulatory licenses. Stripe says it has taken steps to ensure a level of security that is commencing the risk associated with the processing of personal data and has taken organizational, technical and administrative measures to protect personal data within the company from unauthorized access, destruction, loss, alteration or misuse. For more information, see Stripe's privacy policy: https://stripe.com/de/privacy

b. Legal basis of data processing

The legal basis for the data processing associated with this is Art. 6 sec. 1 p. 1 b) GDPR.

c. Purpose of data processing

Stripe processes this data to complete payment transactions and provide payment-related services. They are also used to reflect the business relationship with us and to meet financial, regulatory and other obligations.

d. Duration of storage

Stripe stores the data until the purpose of the data processing has been fulfilled and no legal, contractual, or official regulations prevent deletion.

e. Right to objection and erasure

Data processing is mandatory to process your payment by credit card, so it cannot be waived if you wish to make a purchase. If you have any questions about Stripe's privacy policy or would like to exercise your rights, please contact our Data Protection Officer or use the following linked contact form to contact Stripe: https://stripe.com/contact or privacy@stripe.com.

VII. Social media on our website

We integrated social media platforms on our website via "plug-ins", which may result in social media providers receiving data from you if necessary. We will break this down for you in the following.

1. YouTube Video

a. Description and scope of data processing

We have integrated the services of YouTube on this website. We use for the integration of videos the provider YouTube. YouTube LLC, 901 Cherry Avenue, San Bruno, CA 94066, USA, Data processing for the European Economic Area and for Switzerland is carried out by: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

When you visit our website with embedded videos, your IP address will be sent to YouTube and cookies will be installed on your computer. We have included YouTube videos in enhanced privacy mode (in which case, YouTube still contacts the Google DoubleClick service, but personal data is not evaluated according to Google's privacy policy). As a result, YouTube does not store any information about visitors unless they watch the embedded video. If you click the video, your IP address will be sent to YouTube and YouTube will know that you've watched the video. If you are logged in to YouTube, this information is also assigned to your user account (you can prevent this by logging out of YouTube before clicking the video). We use no influence on any possible collection or use of your data by YouTube. For more information about privacy, please refer to the following data policy of YouTube: https://www.google.de/intl/de/policies/privacy/

b. Legal basis of data processing

The legal basis for this data processing is your consent, Art. 6 para. 1 s. 1 lit. a) GDPR.

c. Purpose of data processing

We use social media to promote our company. We also want to give you the opportunity to interact with social media through our website.

d. Duration of storage

Data collected by YouTube (Google) will be deleted by the controller after a fixed retention period of 9 to 18 months.

e. Right to objection and erasure

To prevent the processing of data by YouTube, you have the possibility to log out of YouTube and delete all cookies before visiting our website.

Additional settings and disagreements on the use of data for promotional purposes are available within the YouTube Profile settings.

VIII. Tracking and analytics

For the continuous improvement of our website, we use the following tracking and analytics tools. Below you can find information on which personal data is processed in each case and how you can reach the respective service providers:

1. Google Analytics

a. Description and scope of data processing

Our website uses Google Analytics. This is a service for analyzing access to websites of Google Inc. ("Google") and allows us to improve our website. Data processing for the European Economic Area and for Switzerland is carried out by: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

Cookies enable us to analyze your use of our website. The information collected by a cookie are:

· IP address

· Access time

· Access Duration

The information is transmitted to a Google server in the USA and stored there. The evaluation of your activities on our website is transmitted to us in the form of reports. Google may pass on the collected information to third parties, if required by law or if third parties process this data on behalf of Google. The Google tracking codes of our Internet offer use the function "_anonymizeIp ()", thus IP addresses are processed only shortened, in order to exclude a possible direct personal link to you. Under https://www.google.de/intl/de/policies/ as well as under http://www.google.com/analytics/terms/de.html you can find out more about the terms of use and privacy policy of Google Analytics.

b. Legal basis of data processing

Legal basis is the Art. 6 para 1 s. 1 lit. a) GDPR. Our interest is to provide a website which is tailored to its audience and to optimize our online services accordingly.

c. Purpose of data processing

By processing the data, we can analyze how our website is used, so we can improve it for our users. We protect your data by using only anonymized IP addresses.

d. Duration of storage

The data will be deleted after 26 months after your last website visit.

e. Right to objection and erasure

You can prevent the installation of cookies by Google Analytics in your browser settings. In this case, however, it may happen that you cannot fully use all features of our website. Also, trough browsers extensions e.g. http://tools.google.com/dlpage/gaoptout?hl=de Google Analytics can be disabled and controlled.

IX. Tools for advertisement and marketing

Tools are also included on our website to ensure that our website is displayed to you during an internet search, as a relevant search result or as an advertisement. Below, the programs used in connection with our website have been broken down for you:

1. Google Ads and Google Conversion Tracking

a. Description and scope of data processing

We have integrated the services of Google Ads (formerly Google AdWords) on our website. Google Ads is an internet advertising service. We use Google Ads to gain relevance in the results of Google's search engine. Data processing for the European Economic Area and for Switzerland is carried out by: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

If the user accesses our website through a Google ad, Google will set a so-called conversion cookie on the user's system. For the explanation of the cookies, please refer to the pass to the cookies. The conversion cookie is used to create and analyze web-use statistics. The conversion cookie stores the IP address when visiting the website. This data is stored in the USA. It is possible that Google will share this information with third parties. For further privacy notices of Google refer to: https://policies.google.com/privacy?hl=en&gl=de

b. Legal basis of data processing

The legal basis is your consent, Art. 6 para. 1 s. 1 lit. a) GDPR.

c. Purpose of data processing

We use Google Ads to gain relevance in the results of Google's search engine. These advertisements are carried out to reach a greater audience.

d. Duration of storage

30 days after setting the conversion cookie the cookie loses its validity. This means that the user can no longer be identified. Within these 30 days both- us and Google can track which subpages have been accessed.

e. Right to objection and erasure

You have the possibility to revoke your consent to the data processing at any time. Please contact our data protection officer. The setting of cookies can be prevented by appropriate settings in the user's Internet browser at any time. The already set cookies can also be deleted in the settings of the Internet browser. We express our concern that preventing cookies from being set may mean that not all features are fully available. The user may separately object to interest-based personalized advertising by Google. Please refer to the following link: www.google.de/settings/ads

2. Google Remarketing

a. Description and scope of data processing

Our website uses Google Remarketing. By using and using Google Remarketing, we are able to display advertisements to you. This is also possible when visiting other websites, if a registration has been made on our website beforehand. Google Remarketing ultimately enables user-related advertising. The data processing for the European Economic Area and for Switzerland is carried out by: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

The functionality of Google Remarketing is designed to set a cookie. With this use of cookies, Google has the option of recognizing you if you visit a website that also uses Google Remarketing. As a result, Google can track your IP address and browsing behaviour. For more information on Google's applicable privacy policy, please refer to: https://www.google.de/intl/de/policies/privacy/

b. Legal basis of data processing

The legal basis is your consent, Art. 6 para 1 s. 1 lit. a) GDPR.

c. Purpose of data processing

By using Google Remarketing, we may display advertisements to users that have previously logged into our website. Google Remarketing ultimately enables user-directed personalized advertising.

d. Duration of storage

The data will be deleted, which has been achieved for the purpose of data processing and that does not prevent deletion from legal, contractual or official regulations.

e. Right to objection and erasure

You have the possibility to revoke your consent to the data processing at any time. Please contact our data protection officer. The setting of cookies can be prevented at any time by appropriate settings in your internet browser. The cookies already set can also be deleted in the settings of the internet browser. We keep in mind that preventing the setting of cookies may result in not all features being fully available. You can object to user-related advertising by Google at any time. To this end, we refer to: www.google.de/settings/ads

3. LinkedIn Ads and Conversion Tracking

a. Description and scope of data processing

We place advertisements on LinkedIn. We also use the analytics and conversion tracking technology of the LinkedIn platform to test the effectiveness of this advertising. The data processing is carried out by: LinkedIn Ireland, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

LinkedIn places a cookie on your computer from which information is obtained to play advertising. The cookie text files contain information about your visits to our website, in particular the pages you have viewed in order to be able to make specific product recommendations on subsequent visits to our website or third-party websites. The cookie contains an alias assigned by random generator. If you revisit our or LinkedIn's website within a certain period of time, LinkedIn recognizes you by this alias. However, this information cannot be linked to you. Neither we nor LinkedIn combine this information with your personal data and do not share personal data with third parties.

b. Legal basis for data processing

The data processing is based on your consent in accordance with Art. 6 sec. 1 p.1 lit. a) GDPR.

c. Purpose of data processing

It is in our interest to inform you about our offer and to make it clear and user-friendly for you. This is also the purpose of data processing.

d. Duration of storage

The data will be deleted as soon as it is no longer needed for our recording purposes and no legal, contractual or official regulations prevent deletion.

e. Right to objection and erasure

You have the possibility to revoke your consent to the data processing at any time. Please contact our data protection officer. You can prevent the storage and use of data in a LinkedIn cookie by accessing the link https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out and selecting "Reject". If you select this option, a new cookie (opt-out cookie) will be set in your browser, informing LinkedIn that no data about your browsing behavior may be stored. Please note that the setting must be made for all browsers you use. If all your cookies are deleted in a browser, linkedIn's opt-out cookie will also be affected.

X. Other tools of third-party providers

We also use third-party providers to help us with the site's appearance and functionality. These are listed below:

1. Google Web Fonts

a. Description and scope of data processing

We use web fonts provided by Google. for uniform representation of fonts on the website. Data processing for the European Economic Area and for Switzerland is carried out by: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

When you call up a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly. To do this, the browser you use must connect to Google's servers. As a result, Google learns that our website has been accessed via your IP address. For more information about Google Web Fonts, see https://developers.google.com/fonts/faq and Google's privacy policy: https://www.google.com/policies/privacy/.

b. Legal basis of data processing

The legal basis is based on Article 6 s.1 p. 1 lit. f) GDPR. It is our legitimate interest to be able to offer you a visually interesting and at the same time user-friendly website.

c. Purpose of data processing

We use web fonts provided by Google for uniform representation of fonts on the website. The reason for us using Google web fonts is our interest to make our website vivid and user-friendly.

d. Duration of storage

e. Right to objection and erasure

In the settings of your browser, you can select to not download the fonts from servers of third parties. In this case, a default font which is already installed on your computer will be used.

2. Amazon Web Services (AWS)

a. Beschreibung und Umfang der Datenverarbeitung

We use the services of Amazon Web Services. The data processing is carried out by:

Amazon.com Inc., 410 Terry Avenue North, Seattle WA 98109.

The service provides the technical infrastructure to provide its services, especially web servers and databases. For more details and information about Amazon Web Services' specific privacy policies, see https://aws.amazon.com/de/privacy/ and https://www.amazon.com/gp/help/customer/display.html?nodeId=468496.

b. Legal basis for data processing

The legal basis for data processing is Art. 6 para.1 s.1 lit. f) GDPR, Art. 28 GDPR.

c. Purpose of data processing

Our legitimate interest is based on the safe and user-friendly provision of our website.

d. Duration of storage

The data will be deleted as soon as the intended purpose has been fulfilled and there are no contractual, official or statutory retention regulations.

e. Right to objection and erasure

The collection of data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility of objection on the part of the user.

3. Webflow

a. Description and scope of data processing

We use Webflow's services as a hosting provider. The data processing is carried out by: Webflow, Inc., 398 11th Street, 2nd Floor, San Francisco, CA 94103, USA.

Webflow logs the following technical information when you visit our website:

· IP address

· Date and time of website visit

· User agent string

· Browser type and operating system

· Installed fonts

· Mime types

· Browser language and time zone

· Silverlight data

· Installed plugins

· http-header

· Screen resolution

Additional information on Webflow's data protection can be found here: https://webflow.com/legal/eu-privacy-policy

b. Legal basis of data processing

The processing of this data is carried out based on Art. 6 para. 1 s. 1 lit. f) GDPR. Our legitimate interest is based on making our website accessible to you.

c. Purpose of data processing

Webflow uses this information to monitor the volume of website visits, for example, to facilitate customer billing with the website operator when a tiered pricing plan is based on the number of unique visitors to a customer's website. In addition, Webflow can also use this technical information for its own analysis purposes, such as to measure how many Web page operators have published active Web sites through the Webflow Services.

d. Duration of storage

The data will be deleted as soon as the purpose of the data processing has been fulfilled and no legal, official or contractual retention periods prevent deletion.

e. Right to objection and erasure

The collection of data for the provision of the website and the storage of the data in log files is absolutely necessary for the operation of the website. If you have any questions about data protection or would like to exercise your rights, please contact our Data Protection Officer or Webflow at the following e-mail address: privacy@webflow.com.

4. OHV

a. Description and scope of data processing

As a hosting provider, we also use the services of OVH. The data processing is carried out by: OVH GmbH, St. Johanner Str. 41-43, 66111 Saarbrücken, Germany.

The server locations used are in the EU and Canada. OHV stores the following data for us:

· Content data (e.g. entries in online forms)

· Usage data (e.g. websites visited, interest in content, access times)

· Meta / communication data (e.g. device information, IP addresses).

You can find the data protection declaration under the following link: https://www.ovh.de/unternehmen/datenschutz.xml

b. Legal basis for data processing

The data processing is based on our legitimate interest in being able to provide you with our online services, in accordance with Art. 6 para. 1 s. 1 lit. f) GDPR.

c. Purpose of data processing

The data processing takes place to provide the online services and to ensure a secure and effective connection establishment.

d. Duration of data storage

The data will be deleted as soon as the purpose of data storage has been achieved and there are no legal, contractual or official retention requirements to prevent deletion.

e. Right to objection and erasure

The data processing is necessary in order to make our online services accessible to you. If you do not want your data to be used any longer, you can object to this at any time with future effect. For questions about data protection at OHV or to exercise your rights, you can contact the OVH data protection officer at OVH GmbH, Datenschutz, Dr. Sebastian Kraska, St. Johanner Str. 41-43. 66111 Saarbrücken, Germany, email: datenschutz@ovh.de

XII. App-registration

1. Description and scope of data processing

You can register on our app. This requires that the data subject enters personal data in the registration form. The following data will be collected for this purpose at least:

· Email address

· Name

· password

The information provided by the data subject in the registration mask will be used exclusively for processing and will not be disclosed to third parties.

2. Legal basis for data processing

If the data subject enters mandatory personal data in the registration form, the legal basis of the data processing is based on Art. 6 para. 1 s. 1 lit. b) GDPR. However, if the user also enters personal data in the optional input field, the data processing is based on Art. 6 para. 1 s. 1 lit. a) GDPR.

3. Purpose of data processing

The processing of personal data is used solely for us to finish your registration and organize your website-account.

4. Duration of storage

The data are deleted as soon as the purpose of storage is no longer required. This is the case if you delete your account and no statutory or regulatory retention periods of erasure contradict.

5. Right to objection and erasure

During and after the registration, the data subject is free to change, correct or delete their personal data.

XII. Service providers from third countries

In order to be able to provide our services, we use the support of service providers from third party countries (non-EU countries). In order to ensure the protection of your personal data in this case, we conclude processing contracts with each - carefully selected - service provider. All of our processors provide sufficient guarantees to implement appropriate technical and organizational measures. Our third country data processors are either located in a country with an adequate level of data protection (Art. 45 GDPR) or provide appropriate safeguards (Art 46 GDPR).

Adequate level of protection: The provider comes from a country whose level of data protection has been recognized by the EU Commission. For more information, see: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

EU standard contract clauses: Our provider has submitted to the EU standard contractual clauses to ensure secure data transfer. For more information, see: https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:039:0005:0018:DE:PDF

Binding Corporate Rules: Article 47 of the GDPR provides the possibility of ensuring data protection when transferring data to a third country via Binding Corporate Rules. These are examined and approved by the data security authorities within the framework of the consistency mechanism pursuant to Art. 63 GDPR.

Consent: In addition, a data transfer to a third country without an adequate level of protection will only take place if you have given us your consent in accordance with Art. 49 sec. 1 lit. a) GDPR for this purpose.

XIII. Your rights

You have the following rights with respect to the personal data concerning you:

1. Right to withdraw a given consent (Art. 7 GDPR)

If you have given your consent to the processing of your data, you can withdraw it at any time. This will affect the admissibility of processing your personal data by us for the time after you have withdrawn your consent. To withdraw your consent, contact us personally or in written form.

2. Right of access (Art. 15 GDPR)

You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to your personal data and the following information:

· the purpose of processing;

· the categories of personal data concerned;

· the recipients or the categories of recipient to whom your personal data have been or will be disclosed, in particular recipients in countries outside of the EU or international organisations;

· where possible, the envisaged period for which your personal data will be stored, or, if not possible, the criteria used to determine that period;

· all available information on the source of your personal data;

· the existence of automated decision-making, including profiling, referred to Art. 22 para. 1 and 4 GDPR and, in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

In the case of such a request, you must provide enough information about your identity to proof that the request concerns your own personal data.

3. Right to rectification and erasure (Art. 16, 17 GDPR)

You have the right to obtain from us without undue delay the rectification and completion of inaccurate personal data concerning yourself.

You may also request the erasure of your personal data if any of the following applies to you:

· the personal data concerning you are no longer necessary for the purposes for which they were collected or otherwise processed;

· you withdraw consent on which the processing is based according to Art. 6 para. 1 s.1 lit. a) or Art. 9 para. 2 lit. a) GDPR, and where there is no other legal ground of processing;

· you object to the processing pursuant to Art. 21 para. 1 GDPR and there are no overriding legitimate grounds for the processing, or the you object to the processing pursuant to Art. 21 para. 2 GDPR;

· the personal data have been unlawfully processed;

· the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which we are subject;

· the personal data have been collected in relation to the offer of information society services referred to in Art. 8 para. 1.

Where we made the personal data public and are obliged to erase the personal data pursuant to Art. 17 para. 1 GDPR, we, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

These rights shall not apply to the extent that processing is necessary:

· for exercising the right of freedom of expression and information;

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

· for reasons of public interest in the area of public health in accordance of Art. 9 para. 2 lit. h) and i) as well as Art. 9 para. 3 GDPR;

· for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Art. 89 para. 1 GDPR, in so far as the right referred to above is likely to render impossible or seriously impair the achievement of the objectives of that processing, or

· for the establishment, exercise or defence of legal claims.

4. Right to restriction of processing (Art. 18 GDPR)

You shall have the right to obtain from us restriction of processing where one of the following applies:

· the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;

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

· we no longer need the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims;

· you have objected to processing pursuant to Art. 21 para. 1 GDPR pending the verification whether our legitimate grounds override yours.

Where processing has been restricted under the aforementioned conditions, such personal data shall, except for storage, only be processed with your consent or for the establishment, exercise or defence 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 of a Member State.

If the limitation of the processing is restricted, you will be informed by us before the restriction is lifted.

5. Right to information (Art. 19 GDPR)

If you have asserted us your right to rectification, erasure or restriction of data processing, we will inform all recipients of your personal data to correct, delete or restrict the processing of data, unless this proves impossible or involves disproportionate effort.

You also have the right to know which recipients have received your personal data.

6. Right to data portability (Art. 20 GDPR)

You have the right to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format. Also, you have the right to transmit those data to another controller, where

· the processing is based on consent pursuant of Art. 6 para. 1 s.1 lit. a) GDPR or of Art. 9 para. 2 lit. a) GDPR or is based on a contract pursuant of Art. 6 para. 1 s. 1 lit. b) DS-GVO; and

· the processing is carried out by automated means.

In exercising your right to data portability, you have the right to obtain that personal data transmitted directly from us to another controller, as far as technically feasible. The right to data portability does not apply to processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority that has been delegated to us.

7. Right to object (Art. 21 GDPR)

Where we based the processing of your personal data on a legitimate interest (Art. 6 para. 1 s. 1 lit. f) GDPR), you may object to the processing. The same applies if the data processing is based on Art. 6 para. 1 s. 1 lit. e).

In this case, we ask you to explain the reasons why we should not process your personal data. Based on this we will terminate or adapt the data processing or show you our legitimate reasons why we continue the data processing.

8. Right to lodge a complaint with supervisory authority (Art. 77 GDPR)

Without prejudice to any other administrative or judicial remedy, you shall have the right to complain to a supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement, if you believe that the processing of the personal data concerning you is against the infringes of the GDPR.

The supervisory authority to which the complaint has been submitted shall inform you of the status and results of the complaint, including the possibility of a judicial remedy according to Article 78 GDPR.

XIV. How you perceive these rights

To exercise these rights, please contact our data security officer:

Kemal Webersohn from Webersohn & Scholtz GmbH

privacy@vicodo.com

or by mail:
‍
WS Datenschutz GmbH
Dircksenstraße 51
D-10178 Berlin

XV. Subject to change

We reserve the right to change this privacy policy in compliance with legal requirements.

June 2021

‍