Privacy Policy

Last modified October 16, 2018

Privacy Statement

This privacy statement explains the nature, scope and purpose of the processing of personal data (hereinafter referred to as "data") within our online offer and its associated websites, features, and content, as well as our external online presence, such as our social media profile (hereafter collectively referred to as "online offer"). With regard to the terms used, such as "processing" or "data controller", we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR).

Controller

Brunton, Paige

Rambergstr. 5, Hannover 30161, Germany

hello@paigebrunton.com

https://paigebrunton.com/impressum

Types of processed data:

  • Inventory data (e.g. names, addresses)

  • Contact details (e.g. e-mail, telephone numbers)

  • Content data (e.g. text input, photographs, videos)

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

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

Categories of Data Subjects

Visitors and users of the online offer (data subjects will hereinafter also be referred to as  "users").

Purpose of processing

  • Provision of the online offer, its features and contents

  • Responding to contact enquiries and communicating with users

  • Security measures

  • Audience measurement / marketing

Used Terms

"Personal data" means any information relating to an identified or identifiable natural person (hereinafter the "data subject"); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by reference to identifiers such as names, to identification numbers, to location data, to online identifiers (e.g. cookies) or to one or more special features that express the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.

"Processing" means any operation or set of operations performed with or without the aid of automated procedures that involves personal data. The term is a broad one and covers virtually any handling of data.

"Pseudonymization" means the processing of personal data in such a way that the personal data can no longer be attributed to a specific data subject without the provision of additional information, provided that such additional information is kept separate and subject to technical and organizational measures ensuring that the personal data is not attributed to an identified or identifiable natural person.

"Profiling" means any automated processing of personal data consisting of the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects relating to their work performance, economic situation, health, personal preferences, interests, reliability, conduct, whereabouts or movements of that natural person.

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

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

Applicable Legal Bases

In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis is not mentioned in the privacy statement, the following applies: The legal basis for obtaining consent is article 6 (1) lit. a and Art. 7 GDPR, the legal basis for processing in order to fulfil our services, execute contractual, and respond to inquiries is art. 6 (1) lit. b GDPR, the legal basis for processing in order to fulfill our legal obligations is art. 6 (1) lit. c GDPR, and the legal basis for processing in order to safeguard our legitimate interests is article 6 (1) lit. f GDPR. In the event that vital interests of the data subject or another natural person require the processing of personal data, art. 6 para. 1 lit. d GDPR serves as the legal basis.

Security Measures

In accordance with art. 32 GDPR, we take appropriate technical and organizational measures to ensure an appropriate level of protection against risks to the rights and freedoms of natural persons, considering the current state of technology, the implementation costs and the nature, scope, circumstances and purposes of the processing as well as the probabilities of occurrence and severity of these risks.

Measures shall include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and virtual access to the data, as well as input, disclosure, availability and separation of data. We have also set up procedures against risks of data being compromised, and to ensure the deletion of data and that data subjects can exercise their rights. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software, and procedures, in accordance with the principle of data protection through technology design and privacy-friendly default settings (article 25 GDPR).

Collaboration with Contract Processors and Third Parties

If, in the context of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit data to them or otherwise grant access to it, this will only be done on the basis of legal permission (e.g. where transmission of data to third parties, such as payment service providers, is required to fulfill the contract pursuant to art. 6 (1) (b) GDPR), your consent, a legal obligation or on the basis of our legitimate interests (e.g. the use of agents, webhosts, etc.).

If we commission third parties to process data on the basis of a so-called "data processing agreement", this is done on the basis of art. 28 GDPR.

Transfers to Third Countries

If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or in the context of the use of third party services or disclosure or transmission of data to third parties, this will only be done to fulfill our (pre-) contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we process or allow the data to be processed in a third country only if the special requirements of art. 44 ff. GDPR are met. This means that the processing takes place, for example, on the basis of special guarantees, such as the officially recognized determination of a data protection level corresponding to EU data protection levels (e.g. for the USA through the "Privacy Shield") or the observance of officially recognized special contractual obligations (so-called "standard contractual clauses").

Rights of Data Subjects

You have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with art. 15 GDPR.

Pursuant to art. 16 GDPR, you have the right to request the completion of the data concerning you or the correction of any incorrect data concerning you.

Pursuant to art. 17 GDPR, you have the right to demand that the relevant data be deleted immediately or, alternatively, to demand a restriction on the processing of the data pursuant to art. 18 GDPR.

You have the right to demand to receive any personal data you have provided to us pursuant to art. 20 GDPR, and to request the transmission of this data to other controllers.

Pursuant to art. 77 GDPR, you also have the right to file a complaint with the competent supervisory authority.

Withdrawal

You have the right to revoke consents granted pursuant to art. 7 (3) GDPR with effect for the future.

Right of objection

You can object to the future processing of your data in accordance with art. 21 GDPR at any time. The objection may in particular be made against processing for direct marketing purposes.

Cookies and Right of Objection against Direct Advertising

"Cookies" are small files that are stored on users' computers. Different information can be stored within these cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after their visit to an online offer. Temporary cookies, or "session cookies" or "transient cookies", are cookies that are deleted after a user leaves an online service and closes their browser. Such cookie are used, for example, to save the content of a shopping cart in an online shop or a login status. The term "permanent" or "persistent" refers to cookies that remain stored even after the browser has been closed. For example, the login status can be saved if users visit it after several days. Likewise, such cookies can be used to store information on the interests of users, which is in turn used for range measurement or marketing purposes. "Third-party Cookies" refers to cookies that are offered by providers other than the controller managing the online offer ("first-party cookies", on the other hand, are cookies used exclusively by the controller).

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

If users do not want cookies stored on their computer, they will be asked to disable the corresponding option in their browser's system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies may lead to functional restrictions of this online offer.

A general objection to the use of cookies used for online marketing purposes can be raised for a large number of services, particularly for tracking activities, via the US site http://www.aboutads.info/choices/ or the EU site http://www.youronlinechoices.com/. Furthermore, the storage of cookies can be prevented by switching them off in the browser settings. Please note that in this case not all features of this online offer can be used.

Deletion of Data

The data processed by us are deleted or limited in their processing in accordance with Articles 17 and 18 GDPR. Unless explicitly stated in this privacy policy, the data stored by us are deleted as soon as they are no longer required for their purpose and the deletion does not conflict with any statutory storage requirements. Unless the data is deleted because it is required for other and legally permissible purposes, its processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be kept for reasons relating to commercial or tax law.

Statutory storage periods in Germany are 10 years in particular according to section 147 para. 1 AO (Abgabenordnung – German Tax Code), section 257 para. 1 clauses 1 and 4, section 4 HGB (Handelsgesetzbuch – German Commercial code) (books, records, management reports, accounting documents, trading books, documents relevant for taxation, etc.), and 6 years in accordance with section 257 (1) no. 2 and 3, para. 4 HGB (commercial letters).

Statutory storage periods in Austria are 7 years according to section 132 paragraph 1 BAO (Bundesabgabenordnung – Austrian Tax Code) (accounting documents, receipts/invoices, accounts, receipts, business documents, statements of income and expenses, etc.), 22 years for real estate related documents and 10 years for documents relating to services that are rendered and delivered electronically, to telecommunications, broadcasting and television services provided to non-entrepreneurs in EU Member States and for which a Mini-One-Stop-Shop (MOSS) is used.

Business-related Processing

In addition we process

  • contract data (e.g. subject matter and term of the contract, customer category)

  • payment data (e.g. bank details, payment history)

of our customers, prospects and business partners for the provision of contractual services and activities relating to customer service and customer care, marketing, advertising and market research.

Order Processing in the Online Shop and Customer Account

We process our customers’ data as part of the ordering process in our online shop to allow them to select and order the selected products and services, and to facilitate their payment and delivery, or execution.

The processed data includes inventory data, communication data, contract data, payment data and data subjects include our customers, prospects and other business partners. Processing is carried out for the purpose of providing contractual services within the scope of online shop operations, billing, delivery and customer services. We use session cookies to store shopping cart contents and permanent cookies to store the login status.

Processing is based on art. 6 para. 1 lit. b (execution of order processes) and c (legally required archiving) GDPR. Any information marked as required for the establishment and fulfillment of the contract is mandatory. We only disclose data to third parties within the scope of delivery, payment or within the scope of the legal permissions and obligations towards legal advisors and authorities. The data will only be processed in third countries if this is necessary for the fulfilment of the contract (e.g. at the customer's request for delivery or payment).

Users can optionally create a user account, primarily to view their orders. As part of the registration, users will be informed which information is. User accounts are not public and cannot be indexed by search engines. If users terminate their user account, their data relating to the user account will be deleted, unless its retention is required for reasons relating to commercial or tax law pursuant to Art. 6 para. 1 lit. c GDPR. Information required for the customer account will be retained until the account is deleted and, where legally required, subsequently archived. In the event of termination, it is the responsibility of the users to secure their data before the end of the contract.

As part of the registration and re-registration process and use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user's protection against misuse and other unauthorized use. This data is not passed on to third parties unless it is necessary for the prosecution of our claims or there is a legal obligation pursuant to Art. 6 para. 1 lit. c GDPR.

The deletion takes place after expiration of legal warranty and comparable obligations, the necessity of the retention of data is reviewed every three years; in the case of statutory archiving obligations, deletion takes place after expiration of the retention period (retention periods pursuant to commercial law (6 years) and tax law (10 years)).

Agency services

We process our clients' data as part of our contractual services, which include conceptual and strategic consulting, campaign planning, software and design development/consulting or maintenance, campaign/process/handling implementation, server administration, data analysis/consulting services, and training services.

Here we process inventory data (e.g., customer master data, such as names or addresses), contact data (e.g., e-mail, telephone numbers), content data (e.g. text inputs, photographs, videos), contract data (e.g. subject matter and term of the contract), payment data (eg, bank details, payment history), usage and meta data (e.g. in the context of the evaluation and performance measurement of marketing activities). In principle, we do not process specific categories of personal data, unless these are components of a commissioned processing activity. Data subjects include our customers and prospects as well as their customers, users, website visitors or employees as well as third parties. The purpose of the processing is the provision of contract services, billing, and our customer service activities. The legal basis for processing activities derives from art. 6 para. 1 lit. b GRPR (contractual services), art. 6 para. 1 lit. f GDPR (analysis, statistics, optimization, security measures). We process data that is required for the establishment and execution of contractual services and indicate its necessity. Data will only be disclosed to external parties if this is required within the scope of an order. When processing data provided to us within the context of an order, we act in accordance with the client’s instructions as well as with the statutory requirements for order processing pursuant to art. 28 GDPR and will not process the data for any purposes other purposes than those specified in the order.

We delete the data after expiry of statutory warranty and comparable obligations. The necessity of the retention of data is reviewed every three years; where we are legally required to archive data, deletion takes place after expiration of the statutory retention period (6 years pursuant to section 257 (1) HGB, or 10 years pursuant to section 147 (1) AO). Where clients disclose data to us in the context of an order, data deletion is performed in accordance with the order specifications, generally after the order has been completed.

External Payment Providers

We use external payment providers that facilitate payment transactions between users and us though their platforms (e.g. including a link to the respective privacy policies, Paypal (https://www.paypal.com/webapps/mpp/ua/privacy-full), Klarna (https://www.klarna.com/de/datenschutz/), Skrill (https://www.skrill.com/de/fusszeile/datenschutzrichtlinie/), Giropay (https://www.giropay.de/legal/dataprotection-agb/), Visa (https://www.visa.de/datenschutz), Mastercard (https://www.mastercard.de/de-de/datenschutz.html), American Express (https://www.americanexpress.com/de/content/privacy-policy-statement.html)

Within the context of the performance of contracts, we use these payment providers on the basis of art. 6 para. 1 lit. b. GDPR. We also use external payment providers on the basis of our legitimate interests pursuant to art. 6 para. 1 lit. f. GDPR in order to provide our users with effective and secure payment options.

The data processed by the payment providers include inventory data such as name and address, bank details such as bank account numbers or credit card numbers, passwords, TANs and checksums, as well as contract, summary and recipient-related information. These details are required to complete the transactions. However, the data entered will only be processed and stored by the payment service providers. This means that we do not receive any bank account- or credit card-related information, but only payment confirmations or information when a payment is rejected. Payment service providers may pass on data to credit reporting agencies for identity verification and credit check purposes. In this regard we refer to the general terms and conditions and privacy statements of the payment service providers.

Payment transactions are subject to the terms and conditions and privacy policies of the respective payment service providers, which can be accessed within the respective websites or transaction applications. We also refer to these documents for further information and assertion of rights of withdrawal, information and other rights of data subjects.

Administration, Financial Accounting, Office Organization, Contact Management

We process data in the context of administrative tasks as well as the organization of our business, financial accounting and compliance with legal obligations, such as archiving processes. In doing so, we process the same data that we process in order to render our contractual services. The bases for processing activities are art. 6 para. 1 lit. c. GDPR and art. 6 para. 1 lit. f. GDPR. The processing concerns customers, prospects, business partners, and website visitors. The purpose of and our interest in the processing are administration, financial accounting, office organization, archiving of data, i.e. tasks which serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of data with regard to contractual services and contractual communication corresponds to the details specified for these processing activities.

In doing so, we disclose or transmit data to fiscal authorities and consultants such as tax advisors or auditors, as well as other billing centers and payment service providers.

Furthermore, we store information on suppliers, operators and other business partners on the basis of our business interests, e.g. for the purpose of contacting clients in the future. We generally store this mostly company-related data permanently.

Business Analysis and Market Research

In order to operate our business economically, to recognize market trends, requirements of contracting partners and users, we analyze the data available to us for business transactions, contracts, inquiries, etc. We process inventory data, communication data, contract data, payment data, usage data, metadata based on art. 6 para. 1 lit. f. GDPR, with the data subjects including contractual partners, prospects, customers, visitors and users of our online offer.

Evaluations are carried out for purposes related to business analysis, marketing and market research. We can take into account the profiles of registered users along with the information provided, e.g. on the services they have used. These analyses help us to increase user-friendliness, to optimise our range of products and services and to improve business efficiency. These analyses will be used solely by us and will not be disclosed to outside parties unless they are anonymous analyzes with consolidated results.

Where these analyses or profiles are person-related, they will be deleted or anonymized upon termination by the users, otherwise after two years following the conclusion of the contract. General business and trends analyses are prepared anonymously wherever possible.

Participation in Affiliate Programs

Within our online offer, we use industry-standard tracking tools on the basis of our legitimate interests (i.e. interest in the analysis, optimization and profitable operation of our online offer) pursuant to art. 6 para. 1 lit. f GDPR, insofar as these are necessary for the operation of the affiliate system. Below we inform users about the technical details.

The services offered by our contractual partners may also be advertised and linked to on other websites (referred to as affiliate links or after-buy systems, e.g. third-party links or services that are offered after the conclusion of a contract). The operators of the respective websites receive a commission if users follow the affiliate links and then use the respective offers.

In summary, our online offer requires us to be able to keep track of whether users who are interested in affiliate links and/or the offers available from us, and if they use the offers provided through these affiliate links or on our online platform. To this end, the affiliate links and our offers are supplemented by certain details, which can be part of the link or provided otherwise, e.g. stored in a cookie. These details include in particular the source website (referrer), time, an online identifier of the operator of the website on which the affiliate link was located, an online identifier of the respective offer, an online identifier of the user, as well as details specific to the tracking tool used, such as ad ID, affiliate ID and categorization.

The online user IDs used by us are pseudonymous values. This means that the online identifiers themselves contain no personal data such as names or e-mail addresses. They only help us to determine if the same user who clicked on an affiliate link or showed interest in an offer via our online offer has accepted the offer, i.e. has concluded a contract with the respective provider. However, the online identifier is personal in so far as we and the partner company have access to the online identifier together with other user data. This is the only way the partner company can tell us whether the user has taken up the offer and we can, for example, pay out the bonus.

Amazon Affiliate Program

On the basis of our legitimate interests (i.e. interest in the profitable operation of our online offer within the meaning of art. 6 (1) lit. GDPR), we participate in Amazon EU’s Affiliate Program, which was designed to provide a medium for websites which can be used to place advertisements and links to Amazon.de and earn commissions for each referral (referred to as affiliate system). This means that, as an Amazon partner, we earn a commission on qualified purchases.

Amazon uses cookies to track the origin of orders. Among other things, Amazon will be able to see that you have clicked the affiliate link on this site and subsequently purchased a product from Amazon.

For more information about Amazon's data usage and opt-out options, please read the company's privacy policy: https://www.amazon.com/gp/help/customer/display.html?nodeId=201909010.

Please note: Amazon and the Amazon logo are trademarks of Amazon.com, Inc. or one of its affiliates.

Privacy Policy and Application Processes

We process applicant data only for the purpose and in the context of application processes and in compliance with legal requirements. The processing of applicant data takes place in order to fulfill our (pre-) contractual obligations in the context of the application process within the meaning of art. 6 para. 1 lit. b. GDPR and art. 6 para. 1 lit. f. GDPR where the processing of data becomes necessary for us, e.g. in the context of legal proceedings [in Germany, section 26 BDSG (Bundesdatenschutzgesetz – Federal Data Protection Act) applies additionally).

The application process requires that applicants provide their details to us. Where we offer an online application form, the required applicant data is marked as mandatory, otherwise the required details will be indicated in the job descriptions and basically include the applicant’s personal details, postal and contact addresses and documents such as cover letter, CV, and certificates. In addition, applicants may provide us with additional information on an optional basis.

By submitting their application to us, applicants consent to the processing of their data for the purposes of the application process in accordance with the nature and scope set forth in this privacy policy.

Where special categories of personal data within the meaning of art. 9 (1) GDPR are voluntarily disclosed within the context of the application procedure, their processing is also carried out in accordance with art. 9 (2) lit. b GDPR (e.g. health data, such as severe disability status or ethnic origin). Where special categories of personal data within the meaning of art. 9 (1) GDPR are requested from applicants as part of the application process, their processing is also carried out in accordance with art. 9 para. 2 lit. a GDPR (e.g. health data where necessary to fulfil job-related tasks).

Where provided, applicants may submit their applications to us via an online form on our website. The data will be encrypted and transmitted to us in accordance with the current state of technology.

Applicants may also send us their applications by e-mail. However, please note that e-mails are not generally sent in encrypted form and that applicants themselves must ensure that their e-mails are encrypted. We therefore cannot assume any responsibility for the transmission path of the application between the sender and reception on our server and therefore recommend using an online form or postal dispatch. Instead of applying via the online form and e-mail, applicants still have the option of sending their application by mail.

In the event of a successful application, the data provided by applicants may be further processed by us for the purposes of the employment relationship. Otherwise, if the application for a job offer is not successful, the applicant's data will be deleted. Applicants' data will also be deleted in the event that a candidate withdraws their application, which they are entitled to at any time.

Subject to a justified revocation by the applicant, deletion will take place after a period of six months so that we can answer any follow-up questions regarding the application and meet our obligations to provide evidence under the Equal Treatment Act (Gleichbehandlungsgesetz). Invoices submitted for any reimbursement of travel expenses are archived in accordance with applicable tax regulations.

Talent Pool

As part of the application, we offer applicants the opportunity to work in our "Talent Pool" for a period of two years on the basis of consent as defined in art. 6 para. 1 lit. a. and art. 7 GDPR.

Application documents in the Talent Pool are processed solely within the context of future job openings and recruitment activities and will be destroyed following expiration of the deadline at the latest. Candidates are informed that their consent to be admitted to the talent pool is voluntary, has no influence on the current application process and that they can revoke this consent at any time in the future and declare an objection within the meaning of art. 21 GDPR.

Registration feature

Users can create a user account. Within the scope of registration, the required mandatory data will be communicated to the users and processed on the basis of art. 6 para. 1 lit. b GDPR for the purpose of providing the user account. The processed data includes in particular the login details (name, password and e-mail address). The data entered during registration will be used for the purposes of using the user account and its purpose.

Users may be informed by e-mail about information relevant to their user account, such as technical changes. If users have terminated their user account, their user account-related data will be deleted, unless this data is subject to statutory retention requirements. It is the responsibility of the users to secure their data before the end of the contract in the event of termination. We are entitled to irretrievably delete all user data that was stored during the term of the contract.

In the context of the use of our registration and registration features as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user's protection against misuse and other unauthorized use. This data is not passed on to third parties, unless this is necessary for the pursuit of our claims or where we are legally required to do so in accordance with. art. 6 para. 1 lit. c. GDPR. The IP addresses will be anonymized or deleted after a period of 7 days at the latest.

Comments and Contributions

If users leave comments or other contributions, their IP addresses may be stored for 7 days on the basis of our legitimate interests within the meaning of art. 6 para. 1 lit. f. GDPR. This serves our own security for instances where someone leaves comments or contributions containing illicit content (insults, prohibited political propaganda, etc.). In this case, we may be prosecuted for the comment or post and are therefore interested in knowing the identity of the author.

Furthermore, we reserve the right, in accordance with our legitimate interests pursuant to art. 6 para. 1 lit. f. GDPR, to process user information for the purpose of spam detection.

On the same legal basis, in the case of surveys, we reserve the right to store users’ IP addresses for the duration of their use and to use cookies to avoid multiple votes.

The data provided in the comments and contributions will permanently be stored by us until the user objects.

Contact

When contacting us (e.g. via contact form, e-mail, telephone or social media), we process information provided by the user to handle the contact inquiry pursuant to art. 6 para. 1 lit. b. (regarding contractual / pre-contractual relationships), art. 6 para. 1 lit. f. (regarding other requests) GDPR. User information may be stored in a Customer Relationship Management System ("CRM System") or similar tool for inquiry processing.

We delete inquiries once they are no longer required. We review the necessity every two years; furthermore, the statutory archiving provisions apply.

Newsletter

With the following information we inform you about the contents of our newsletter as well as the registration, dispatch and statistical evaluation procedures as well as your right of objection. By subscribing to our newsletter, you agree to the receipt and to the procedures described.

Content of the newsletter: We send newsletters, e-mails and other electronic notifications containing advertising information (hereinafter "newsletter") only based on the consent of the recipient or where we are legally allowed to do so. Where the contents of the newsletter are specifically described as part of the newsletter registration, they are authoritative for the consent of the users. In addition, our newsletters contain information about our services and us.

Logging: The registration for the newsletter will be logged in order to prove the registration process according to the legal requirements. This includes the storage of the login and the confirmation time, as well as the IP address. Likewise, changes to your data stored with the newsletter dispatch provider will be logged.

Credentials: It is sufficient to provide your e-mail address to subscribe to the newsletter. We ask you to also provide a name, so we can address you personally in the newsletter.

The dispatch of the newsletter and the associated performance measurement are based on the recipient’s consent pursuant to art. 6 para. 1 lit. a, art. 7 GDPR in conjunction with section 7 para. 2 no. 3 UWG (Gesetz gegen den unlauteren Wettbewerb - German Fair Trade Practices Act) or if, based on our legitimate interests in direct marketing pursuant to art. 6 para. 1 lt. F. GDPR in conjunction with section 7 para. 3 UWG, consent is not required.

The logging of the registration process is based on our legitimate interests pursuant to art. 6 para. 1 lit. f GDPR. We are interested in using a user-friendly and secure newsletter system that serves our business interests, meets users' expectations, and allows us to provide evidence of consent.

Termination / Revocation - you can unsubscribe from our newsletter, i.e. revoke your consent, at any time. A link to unsubscribe from the newsletter can be found at the end of each newsletter. Based on our legitimate interests and to be able to provide evidence of prior consent, we may store the unsubscribed email addresses for up to three years before deleting them. The processing of these data is limited to the purpose of a possible defense against claims. Individual deletion requests may be submitted at any time, provided that the person requesting deletion confirms the former existence of a consent at the same time.

Newsletter – Dispatch Provider

The newsletter is sent using the dispatch service provider Seva, 113 Cherry St # 92768, Seattle, WA, 98104-2205, United States of America. The privacy policy of the dispatch service provider can be viewed here: https://convertkit.com/privacy/. The use of the dispatch service provider is based on our legitimate interests according to art. 6 para. 1 lit. f. GDPR and a contract processing agreement as defined by art. 28 (3) clause 1 GDPR.

The dispatch service provider may use the recipient’s data in a pseudonymous form, i.e. without attribution to a user, to optimize or improve their own services, e.g. for the technical optimization of newsletter dispatch and of the presentation of newsletters or for statistical purposes. However, the dispatch service provider will not use the data of our newsletter recipients to contact them on its own behalf or to pass the data on to third parties.

Hosting and E-mailing

The hosting services we use are designed to provide the following services: infrastructure and platform services, computing capacity, storage and database services, e-mailing, security and technical maintenance services we use to operate this online service.

In this regard we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, prospects and visitors to this online offer on the basis of our legitimate interests in the efficient and secure provision of these online services according to art. 6 para. 1 lit. f GDPR in conjunction with art. 28 GDPR (conclusion of a contract processing contract).

Collection of Access Data and Log Files

Based on our legitimate interests within the meaning of art. 6 para. 1 lit. f GDPR, we and/or our hosting provider collect access data each time the server on which this service is located (referred to server log files) is accessed. The access data includes the name of the retrieved web page, file, date and time of retrieval, amount of data transferred, report of successful retrieval, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the provider submitting the request.

Logfile information is stored for security reasons (e.g. to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data which must be stored longer for evidential purposes shall be exempt from deletion until the respective incident has been fully clarified.

Google Analytics

Based on our legitimate interests (i.e. interest in the analysis, optimization and profitable operation of our online services within the meaning of art. 6 (1) lit. f GDPR), we use Google Analytics, a web analytics service provided by Google LLC ("Google"). Google uses cookies. The information generated by the cookie about users’ use of the online services will usually be transmitted to a Google server in the USA and stored there.

Google is certified under the Privacy Shield Agreement, thereby guaranteeing compliance with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active ).

Google will use this information on our behalf to evaluate users’ use of our online services, to compile reports on the activities within this online offer and to provide us with further services associated with the use of these online services and the Internet. In this case, pseudonymous usage profiles of users can be created from the processed data.

We only use Google Analytics with IP anonymization enabled. This means that users’ IP addresses will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server in the US and shortened there.

The IP address submitted by the user's browser will not be merged with other data provided by Google. Users can prevent the storage of cookies by setting their browser software accordingly; Users may also prevent the collection by Google of the data generated by the cookie and related to its use of the online offer and the processing of such data by Google by downloading and installing the browser plug-in available at the following link: http: // tools .google.com / dlpage / gaoptout? hl = DE .

For more information about Google's data usage, configuration options and possibilities to appeal, please read Google's privacy policy ( https://policies.google.com/technologies/ads ) as well as the settings for the display of advertisements by Google (https: // adssettings.google.com/authenticated).

The personal data of users will be deleted or anonymized after 14 months.

Google Universal Analytics

We use Google Analytics as "Universal Analytics". "Universal Analytics" means a Google Analytics process where the user analysis is based on a pseudonymous user ID and thus a pseudonymous profile of the user is created with information from different devices (referred to as "cross-device tracking").

Targeting with Google Analytics

We use Google Analytics to show advertisements displayed within Google and its affiliate advertising services only to those users who have shown an interest in our online services or who meet certain characteristics (e.g. being interested in specific topics or products visited by them) Web pages) that we submit to Google (referred to as "remarketing" or "Google Analytics audiences"). By using remarketing audiences, we also want to make sure that our ads meet the potential interest of users.

Facebook Pixels, Custom Audiences and Facebook Conversion

Based on our economic interests in analyzing, optimizing and operating our online services profitably, and for these purposes, we use the so-called "Facebook pixel" provided by social network Facebook, which is operated by Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025 , USA, or, if you are located in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland ("Facebook").

Facebook is certified under the Privacy Shield Agreement, thereby guaranteeing compliance with European privacy legislation https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

With the help of the Facebook pixel, it is on the one hand possible for Facebook to determine the visitors to our online offer as a target group for the display of advertisements (referred to as "Facebook ads"). Accordingly, we use the Facebook Pixel to display the Facebook Ads we have been sent only to those Facebook users who have shown an interest in our online offer or who meet certain criteria (e.g. interest in certain topics or products determined on the basis of the websites visited), which we transmit to Facebook (referred to as "Custom Audiences"). With the help of the Facebook pixel, we also want to ensure that our Facebook ads are in line with the potential interests of users and to ensure that they do not cause any nuisance. With the help of the Facebook pixel we can also understand the effectiveness of the Facebook ads for statistical and market research purposes as it allows us to see whether users were redirected to our website after clicking on a Facebook ad (so-called "conversion").

The processing of the data by Facebook is performed within the scope of Facebook's data usage policy. General information on the presentation of Facebook Ads is contained in Facebook’s data usage policy: https://www.facebook.com/policy. For specific information and details about the Facebook pixel and how it works, visit the Facebook help section: https://www.facebook.com/business/help/651294705016616 .

You may opt out of Facebook pixel collection and the use of your information to display Facebook ads. To configure what types of ads you see within Facebook, you can go to the page set up by Facebook and follow the instructions about the settings for usage-based ads: https://www.facebook.com/settings?tab=ads. The settings are platform-independent, meaning that they are adopted for all devices, such as desktop computers or mobile devices.

You may refuse the use of cookies for range measurement and advertising purposes by selecting the appropriate settings on the Network Advertising Initiative deactivation page ( http://optout.networkadvertising.org/ ) and in addition the US ( http://www.aboutads.info/ choices ) or European website ( http://www.youronlinechoices.com/uk/your-ad-choices/ ).

Visual Website Optimizer

Within our online offer, based on our legitimate interests (i.e. interest in the analysis, optimization and profitable operation of our online offer within the meaning of art. 6 (1) f. GDPR), we use the Visual Website Optimizer service (an offer of Wingify Software Private Limited , 404, Gopal Heights, Netaji Subhash Place, Pitam Pura, Delhi 110034, India).

Visual Website Optimizer allows website owners to understand the effects of changes made to a website (such as changes to the input fields, the design, etc.) as part of so-called "A/B-tests", "click tracking" and "heatmaps". A/B helps improve the usability and performance of online offerings. For example, users are presented with different versions of a website or its elements, such as input forms, on which the placement of the contents or labels of the navigation elements can differ. The behaviour of users, e.g. length of time spent on the website or more frequent interaction with the elements, can then be used to determine which of these websites or elements are more suited to users' needs. "Clicktracking" allows website owners to keep track of the movements of users within an entire online offering. As the results of these tests are more accurate if users’ interactions can be observed over a certain period of time (e.g. if a user likes to return), cookies are usually stored on the computers of the users for these test purposes. "Heatmaps" are mouse movements of the users, which are then combined to provide an overall picture that allows the website owner to see which web page elements are preferred and which web page elements users prefer less.

Cookies will only be stored on users' devices for these test purposes. Only pseudonymous user data will be processed. For more information, please refer to the Visual Website Optimizer privacy policy: https://vwo.com/privacy-policy/ .

Online Presence in Social Media

We maintain online presences within social networks and platforms in order to communicate with customers, prospects and users active there and to inform them about our services.

We would like to point out that user data collected in this context may be processed outside the European Union. This may entail risks for users, e.g. by making it more difficult to enforce users' rights. We would like to point out that US providers certified under the Privacy Shield undertake to comply with EU privacy standards.

Furthermore, user data is usually processed for market research and advertising purposes. For example, user behavior and information about user interests derived from users’ behavior can be used to create user profiles. These can in turn be used, for example, to place advertisements inside and outside the platforms which are presumed to correspond to the interests of the users. For these purposes, cookies in which the user's usage behavior and interests are stored will usually be stored on the user's computer. Furthermore, data can be stored in the user profiles irrelevant of the device type used by the users (especially if the users are members of the respective platforms and are logged in to them).

The processing of users' personal data is carried out on the basis of our legitimate interests in effective information for users and communication with users pursuant to art. 6 para. 1 lit. f GDPR. If the users are asked by the respective providers to consent to the data processing (i.e. by ticking a check box or pressing a button), the legal basis of the processing is art. 6 para. 1 lit. a and art. 7 GDPR.

For a detailed description of the respective processing and the possibilities of objection (opt-out), we refer to the information by the providers at the links below

Also in the case of requests for information and the assertion of user rights, we would like to point out that these can be claimed most effectively from the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. If you still need help, please do not hesitate to contact us.

- Facebook (Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland) - Privacy Policy: https://www.facebook.com/about/privacy/ , opt-out: https: // www. facebook.com/settings?tab=ads and http://www.youronlinechoices.com , Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active .

- Google / YouTube (Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA) - Privacy Policy: https://policies.google.com/privacy , opt-out: https://adssettings.google.com/authenticated , Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active .

- Instagram (Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA) - Privacy Policy / Opt-Out: http://instagram.com/about/legal/privacy/ .

- Twitter (Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA) - Privacy Policy: https://twitter.com/privacy , opt-out: https://twitter.com/personalization , Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000TORzAAO&status=Active .

- Pinterest (Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA) - Privacy Policy / Opt-Out: https://about.pinterest.com/en/privacy-policy .

- LinkedIn (LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland) - Privacy Policy https://www.linkedin.com/legal/privacy-policy , opt-out: https://www.linkedin.com/psettings/guest -controls / retargeting-opt-out , Privacy Shield: https://www.privacyshield.gov/participant?id=a2zt0000000L0UZAA0&status=Active .

- Xing (XING AG, Dammtorstrasse 29-32, 20354 Hamburg, Germany) - Privacy Policy / Opt-Out: https://privacy.xing.com/de/datenschutzerklaerung .

- Wakalet (Wakelet Limited, 76 Quay Street, Manchester, M3 4PR, United Kingdom) - Privacy Policy / Opt-Out: https://wakelet.com/privacy.html .

- Soundcloud (SoundCloud Limited, Rheinsberger Str. 76/77, 10115 Berlin, Germany) - Privacy Policy / Opt-Out: https://soundcloud.com/pages/privacy .

Integration of third-party services and content

Based on our legitimate interests (i.e. interest in the analysis, optimization and profitable operation of our online offer within the meaning of art. 6 (1) lit. GDPR), we use third-party content and/or services in order to integrate these providers’ content and services, such as videos or fonts (collectively referred to as "content").

This always presupposes that the third-party providers of this content perceive the IP address of the users, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of this content. We endeavor to use only content whose respective providers use the IP address solely for the delivery of the content. Third parties may also use so-called pixel tags (invisible graphics, also referred to as "web beacons") for statistical or marketing purposes. The "pixel tags" can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on users’ devices and may include technical information about the browser and operating system, referring web pages, time of access, and other information regarding the use of our online offer.

Youtube

We embed videos shown on Google’s YouTube platform: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/ , opt-out: https://adssettings.google.com/authenticated .

Google Fonts

We incorporate the fonts ("Google Fonts") provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/ , opt-out: https://adssettings.google.com/authenticated .

Google ReCaptcha

We use the Bots Detection feature, for example for entries in online forms ("ReCaptcha") provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Privacy Policy: https://www.google.com/policies/privacy/ , opt-out: https://adssettings.google.com/authenticated .

Use of Facebook Social Plugins

Based on our legitimate interests (i.e. interest in the analysis, optimization and profitable operation of our online offer within the meaning of art. 6 para. 1 lit. f GDPR), we use social plugins ("plugins") of the social network facebook.com, which is operated by Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbor, Dublin 2, Ireland ("Facebook").

This may include, for example, content such as images, videos or text and buttons, which users can use to share content from this online offer within Facebook. A visual and written list of the Facebook Social Plugins can be viewed here: https://developers.facebook.com/docs/plugins/.

Facebook is certified under the Privacy Shield Agreement, thereby guaranteeing to comply with European privacy legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).

When a user uses a feature of this online offer that includes such a plugin, their device will establish a direct connection to the Facebook servers. Facebook will directly transmit the content of the plugin to the user’s device and incorporate it into the online offer. Data processed as part of this process can be used to create user profiles. We therefore have no influence on the amount of data that Facebook collects with the help of this plugin and therefore inform the users based on our level of knowledge.

Through the integrated plugins, Facebook is informed that a user has accessed the corresponding page of the online offer. If the user is logged in to Facebook, Facebook is able attribute the visit to the user’s Facebook account. If users interact with the plugins, for example by pressing the Like button or leaving a comment, this information is transmitted from your device directly to Facebook and stored there. If a user is not a member of Facebook, it is still possible for Facebook to find out and store their IP address. According to Facebook, only anonymized IP addresses are stored in Germany.

The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the related rights and configuration options to protect the privacy of users, can be found in Facebook's privacy policy: https://www.facebook.com/about/privacy/.

Users who are Facebook members and do not want Facebook to collect data about them via this online offer and attribute this information to their Facebook member data, must log out of Facebook and delete their cookies before using our online offer. Other settings and objection options regarding the use of data for advertising purposes can be accessed in the Facebook profile settings: https://www.facebook.com/settings?tab=ads or via the US site http://www.aboutads.info / choices / or EU site http://www.youronlinechoices.com/ . The settings are platform-independent, i.e. they will be adopted for all devices, such as desktop computers or mobile devices.

Instagram

We may integrate Instagram features and content provided by Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, in our online offering. This may include, for example, content such as images, videos or text and buttons that allow users to share content from this online offering within Instagram. If the users are Instagram members, the Instagram platform will be able to attribute the used of the contents and functions mentioned above to users’ Instagram profiles. Instagram privacy policy: http://instagram.com/about/legal/privacy/.

Pinterest

We may integrate Pinterest features and content provided by Pinterest Inc., 635 High Street, Palo Alto, CA, 94301, USA, in our online offering. This may include, for example, content such as images, videos or texts and buttons that allow users to share content from this online offering within Pinterest. If the users are Pinterest members, the Pinterest platform Pinterest will be able to attribute the use of the contents and functions and functions mentioned above to users’ Pinterest profiles. Pinterest Privacy Policy: https://about.pinterest.com/privacy-policy.

 

Impressum

According to § 5 TMG
Rambergstr. 5, Hannover, 30161
Fon: +49 (0) 176 436 04249
Mail: hello (at) paigebrunton . com
Internet address: https://www.paigebrunton.com, https://www.thepaigestudio.com, https://www.squaresecrets.com
Responsible for the content according to § 55 ABS. 2 RSTV: Paige Brunton

DISCLAIMER

Liability for content.
The contents of our pages were created with great care. However, we can not guarantee the correctness, completeness and actuality of the content. As a service provider, we are responsible for our own content on these pages according to the general laws according to § 7 Abs.1 TMG. According to §§ 8 to 10 TMG, however, we as service providers are not obliged to monitor transmitted or stored third-party information or to search for circumstances which indicate an illegal activity. Obligations to remove or block the use of information according to general laws remain unaffected. Liability in this regard, however, is only possible from the time of the knowledge of a specific infringement.

Liability for links.
Our website contains links to external websites of third parties on whose contents we have no influence. Therefore, we can not assume any liability for these third-party content. The respective provider or operator of the pages is always responsible for the contents of the linked pages. The linked pages were checked for possible legal violations at the time of linking. Illegal contents were not recognizable at the time of linking. A permanent control of the content of the linked pages is, however, without concrete evidence of an infringement is unreasonable. We will remove such links immediately if we become aware of any legal infringements.

Copyright.
The content and works created and / or used by the site operators on these pages are subject to German copyright law. The copying, processing, distribution and any kind of exploitation outside the limits of copyright require the consent of the respective author or creator. Downloads and copies of this site are only permitted for private, non-commercial use. If the content on this site is not created by the operator, the copyrights of third parties are respected. In particular contents of third parties are marked as such. Should you nevertheless be aware of a copyright infringement, we ask for a corresponding note. If we become aware of legal violations, we will immediately remove such content.

Google Analytics.
This website uses Google Analytics, a web analytics service provided by Google, Inc. (»Google«). Google Analytics uses cookies, which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. On this website the IP anonymization feature is activated. As a result Google will truncate/anonymize the last octet of the IP address for Member States of the European Union as well as for other parties to the Agreement on the European Economic Area. Only in exceptional cases, the full IP address is sent to and shortened by Google servers in the USA. On behalf of the website provider Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage to the website provider. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

How to prevent being tracked by Google Analytics on paigebrunton.com: You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of this website. Furthermore you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en.