Privacy Policy
Below we provide you with an overview of what data we collect for what purpose and how we ensure the protection of the data on our Website
What is Personal Data?
Personal data is any information relating to an identified or identifiable natural person. Personal data includes e.g. name, email address or telephone number. Personal data also includes information about hobbies, memberships or websites viewed. The applicable legal basis for processing data can be found, in particular, in the Regulation (EU) 2016/679 of the European Parliament and Council of 27 April 2016, repealing the directive 95/46/EC on the protection of individuals with regard to the processing of personal data, on the free movement of such data (“General Data Protection Regulation”, GDPR) as well as in the Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG) and the German Telemedia Act (Telemediengesetz, TMG). Below we provide you with an overview
Who is the Controller of my Data? How is my data processed?
The controller (“we/us/our” or “Ulinzi Conservation Coffee”) is Ulinzi Conservation Coffee, Arnulfstr. 171, 80634 München, represented by the managing director Steffen Sauer.
email: steffen@ulinzi-conservation-coffee.com
phone: +49 (0)1797562389
Your data will be used for the following purposes:
To provide the functioning Website or Service, to implement the applicable privacy policy and carrying out the contractual relationship and our Service, to analyze your use of our Service and improve our Service with our legitimate interests of marketing and fraud prevention, or as otherwise explained in our applicable privacy policy or by any communication by us. Furthermore, your data will be processed by us with your explicit consent, for example sending newsletters.
We as well as our external service partners receive your data for processing for the purpose of providing our Service. You provide data if this is necessary for the aforementioned purposes. If you chose to refrain from providing such data, you may face disadvantages, for example, limited or no possibility of using our Service.
Visiting the Website
If you browse our Website www.ulinzi-conservation-coffee.com, the provider of the website automatically collects and stores information in so-called “server-log-files” that your browser transfers to us. These are:
type/version of the browser, system software used, referrer URL, hostname of the device, time of the server request, IP-address or other unique device identifier.
If you are using a mobile device, the following data is additionally collected through the Website: country code, language, hostname of the device, name and version of the operational system. We use this data only for statistical analysis, for the purpose of operation, security and optimization of our Website. However, we reserve the right to check this data retrospectively if there is a justified suspicion of illegal use based on concrete indications. This data is then stored because this is the only way to prevent the misuse of our Website and, if necessary, allow us to investigate any crimes committed. The storage of this data is necessary in order to protect us as the person responsible for processing the data. As a matter of principle, this data will not be passed on to third parties unless there is a legal obligation to pass it on or the transfer of data serves criminal prosecution purposes.
This data processing is based on Art. 6 (1) f. GDPR or TMG and we wish to achieve the legitimate interests of stabilizing and improving our Website, quality insurance and fraud prevention.
Newsletter
With the newsletter we inform the user about the Website, our Service and us. When registering for the newsletter, you have to provide an email address. This email address will be transmitted to and stored by us (or a provider as specified below). After registration, you will receive an email to confirm the registration (“double opt-in”). Via clicking the registration link you have given your consent to the processing of your personal data for receiving our newsletter according to Art. 6 (1) a. GDPR and we may process such data accordingly.
In case of registration for the newsletter, we (or our provider as specified below) also store the IP address, the device name, the mail provider as well as the name and the date of Registration.
Use of Mailchimp - Transfer of Data outside the EU
The mail provider “Mailchimp” by Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA receives and processes on our behalf the data necessary for the order, in particular email address, IP address, device name. These data are processed on servers in the USA. MailChimp is certified according to “privacy shield”. The “privacy shield” is an agreement between the European Union (EU) and the USA to ensure compliance with European data protection standards in the USA.
Mailchimp is a service with which the dispatch of newsletters can be organized and analyzed. With the help of Mailchimp we can analyze our newsletter campaigns. When you open an e-mail sent with Mailchimp, a file contained in the e-mail (so-called web beacon) connects to the Mailchimp servers in the USA. This allows Mailchimp and/or us to determine whether a newsletter message has been opened and which links have been clicked on. In addition, technical information is recorded (e.g. time of registration, IP address, browser type and operating system). This information cannot be assigned to the respective newsletter recipient. They are used exclusively for statistical analysis of newsletter campaigns. The results of these analyses can be used to better adapt future newsletters to the interests of the recipients.
If you do not want Mailchimp to analyze your data, you must unsubscribe from the newsletter. For this purpose, we provide a respective link in every newsletter.
Details on Mailchimp and its privacy policy can be found here: https://mailchimp.com/legal/privacy/The data stored for the purpose of newsletter subscription will be stored by us until you unsubscribe from the newsletter and will be deleted from our servers as well as from the servers of MailChimp after you unsubscribe from the newsletter. Data stored by us for other purposes remain unaffected.
OPT-OUT: You can withdraw your consent to the storage of data, the email address and their respective use for sending the newsletter at any time. This can be done free of charge (except for the transmission costs) and via a link in the newsletter itself or notification to us or, if applicable, to Mailchimp.
Contacting us
When contacting us via email, your details are stored for the purpose of processing the enquiry and, if applicable, follow-up questions based on your consent based on the legal basis of Art. 6 (1) a. GDPR or Art. 6 (1) b. GDPR based on a pre-contractual or existing contract relationship. For sending emails we may also use the services by Mailchimp. For more details please refer to “Use of Mailchimp; Transfer of Data outside the EU” above.
Does automated processing incl. “Profiling” take place?
In general, we do not process any data via automated processing incl. “profiling” making via the Website or Service. However, such profiling may happen by third party providers through the Website or Service. We will inform you about such fact if possible.
Profiling means any automated processing of personal data consisting in the use of such personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects relating to the performance of work, economic situation, health, personal preferences, interests, reliability, behavior, location or relocation of that natural person. Examples of such profiling include the analysis of data (e.g. based on statistical methods) with the aim of displaying personalized advertising or giving shopping tips. The data subject shall not be subject to a decision based exclusively on automated processing, including profiling, which has legal effect against him or significantly affects him or her in a similar manner. This shall not apply where the decision (i) is necessary for the conclusion or performance of a contract between the data subject and the data controller, (ii) is admissible under Union or Member State law to which the data controller is subject and where such law contains appropriate measures to safeguard the rights, freedoms and legitimate interests of the data subject or (iii) is taken with the data subject’s express consent. In such exceptional cases, the person responsible shall take appropriate measures to safeguard the rights, freedoms and legitimate interests of the data subject, including at least the right to obtain the intervention of a person by the data subject, to state his own position and to challenge the decision.
What Third Party Services, Cookies, Analytics and Links to Social Networks does the Website use?
Cookies
In order to offer you a convenient online service featuring numerous functions, our Website uses text files (“Cookies”) containing information to identify returning visitors for the time of their visit to our Website. Cookies are usually saved on your device and do not cause any harm. Cookies facilitate the transfer of specific content, such as entering data, which has already been supplied, and help us identify popular sections of our Website.
The processing of data when using Cookies is based on our legitimate interests of a statistical analysis of the user relationship for marketing and quality assurance purposes according to Art. 6 (1) f. GDPR or TMG.
OPT-OUT: You can deactivate the use of Cookies in the settings of your browser at any time. To find out how to change the settings, please consult the help function of your browser. You may also deactivate and manage a lot of online Cookies by different businesses on the US-website http://www.aboutads.info/choices/ or the EU-website http://www.youronlinechoices.com/uk/your-ad-choices/. However, we want to point out that without Cookies the use and comfort of use of our services may be restricted.
Google Analytics
We use Google Analytics, a web analytics tool offered by Google (inter alia Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland and Google LLC, Mountain View, CA, USA) (“Google“). This analysis service uses so-called “cookies”. For analysis, text files will be stored on your device. The information stored in the corresponding files about the use of this website are generally transmitted and stored in Google servers in the USA. As the IP anonymization is active on this Website, your IP address will be shortened by Google within the member states of the European Union (EU). This information will be used to evaluate your use of the services offered here and enable the operator of this website to analyze your website activity and provide other services associated with the website service. The IP address transmitted from your browser, as part of Google Analytics will not be merged with other data from Google.
If personal data are processed this is based on our legitimate interests of marketing and quality assurance purposes according to Art. 6 (1) f. GDPR or TMG.
OPT-OUT: Adjusting the settings of your browser software can prevent the use of cookies. In this case, it may be possible that the functions of the service offered here cannot be used in its entirety. Furthermore, it is possible to prevent the acquisition and processing of data generated by the “cookies” in relation to the use of this website, by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=de
In addition, you can prevent Google from collecting the data generated by the cookies about your use of the websites and the processing of this data by Google by downloading and installing the browser plug-in available at https://support.google.com/adsense/answer/142293?hl=en.
For users who have their usual residence in the European Economic Area or Switzerland, Google Ireland Limited is the data controller for your data, unless otherwise stated in the privacy notices of a particular service. Google Ireland Limited is therefore the company affiliated with Google which is responsible for processing your data and complying with applicable data protection laws.
You can also find more information in Google’s privacy policy https://www.google.com/policies/privacy/.
Campaign Manager
This Website uses Google’s (by inter alia Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland and Google LLC, Mountain View, CA, USA) online marketing tool Campaign Manager (Double Click). Campaign Manager uses cookies to serve ads relevant for you or our users, to improve campaign performance reports, or to prevent you/them from seeing the same ads more than once. Such ads may come from Google or other third parties. Third-party vendors, including Google, use cookies to serve ads based on a user’s prior visits to the Website. Google uses a cookie ID to track which ads appear in which browser, thereby preventing them from appearing more than once. In addition, Campaign Manager can use cookie IDs to collect conversions related to ad requests. This is the case, for example, when you or a user sees a Campaign Manager ad and later visits the advertiser’s website with the same browser and buys something there. According to Google, Campaign Manager cookies do not contain any personally identifiable information.
Because of the marketing tools used, your browser automatically connects directly to Google’s server. We have no influence on the extent and further use of the data collected by Google through the use of this tool and therefore inform you according to our state of knowledge: Through the integration of Campaign Manager, Google receives the information that you have called the relevant part of our Website or clicked on an advertisement from us. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, it is possible for the provider to find out and store your IP address.
In addition, the Campaign Manager cookies used enable us to understand whether you are performing any actions on our Website after you have accessed or clicked on one of our display/video ads on Google or another platform via Campaign Manager (conversion tracking). Campaign Manager uses this cookie to understand the content that you have interacted with on our Website in order to send you targeted advertisements later.
The legal basis for such data processing is your consent (Art. 6 (1) a. GDPR) or our legitimate interests of marketing and quality assurance purposes (Art. 6 (1) f. GDPR or TMG).
OPT-OUT: You can prevent participation in this tracking process by setting your browser software accordingly; or by disabling conversion tracking cookies by setting your browser to block cookies from the www.googleadservices.com domain, https://www.google.de/settings/ads, whereby this setting is deleted when you delete your cookies; or by disabling the interest-based ads of the providers that are part of the ‘About Ads’ self-regulatory campaign via the link http://www.aboutads.info/choices, whereby this setting is deleted when you delete your cookies; or by permanently disabling it in your Firefox, Internet Explorer or Google Chrome browsers via the link http://www.google.com/settings/ads/plugin; or by setting the appropriate cookies setting. We would like to point out that in this case you may not be able to use all functions of our Website to their full extent.
In addition, you can prevent Google from collecting the data generated by the cookies about your use of the websites and the processing of this data by Google by downloading and installing the browser plug-in available at https://support.google.com/adsense/answer/142293?hl=en.
For users who have their usual residence in the European Economic Area or Switzerland, Google Ireland Limited is the data controller for your data, unless otherwise stated in the privacy notices of a particular service. Google Ireland Limited is therefore the company affiliated with Google which is responsible for processing your data and complying with applicable data protection laws.
For more information about Campaign Manager, please visit https://www.google.de/doubleclick and Google’s privacy policy https://www.google.de/intl/de/policies/privacy. Alternatively, you can visit the Network Advertising Initiative (NAI) website at http://www.networkadvertising.org
Links to Social Networks
The Website is connected via links to the social networks Facebook, Instagram and LinkedIn. We,Ulinzi Conservation Coffee, Arnulfstr. 171, 80634 München, represented by the managing director Steffen Sauer, operate the following pages (“Social-Media-Pages”) on the following social media networks (“Social Media”):
Facebook:
facebook.com or mobile app by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA or Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland, please refer to privacy policy https://www.facebook.com/policy.php
opt-out: https://www.facebook.com/ads/preferences or https://www.facebook.com/settings
Instagram:
instagram.com or mobile app by Facebook Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland, please refer to privacy policy http://instagram.com/about/legal/privacy/
opt-out: https://www.instagram.com/accounts/privacy_and_security/
Controller for Data Processing
When you visit our Social-Media-Pages, data is processed both by us and by the responsible social media provider as the responsible party.
The respective provider of Social Media assumes the data protection obligations towards you as the user, such as information on data processing, and is the contact person for your rights. This follows from the fact that such provider has direct access to the relevant information on the Social-Media-Page and the processing of your data.
Is my Data transferred outside the EU?
Data Processing outside the EU
We only pass on data that we receive via the Social-Media-Pages to third parties in accordance with the provisions of this Privacy Policy
When using Facebook, Instagram, or LinkedIn data may also be processed outside the EU.
For users who have their usual residence in the European Economic Area or Switzerland, Google Ireland Limited is the data controller for your data, unless otherwise stated in the privacy notices of a particular service. Google Ireland Limited is therefore the company affiliated with Google which is responsible for processing your data and complying with applicable data protection laws. You can also find more information in Google’s privacy policy https://www.google.com/policies/privacy/.
The US companies of Facebook, Instagram, LinkedIn and Google are each certified in accordance with the EU-US Privacy Shield agreement, which guarantees compliance with data protection regulations in the EU. For more information please refer to: https://www.privacyshield.gov
Data Processing and Legal Basis
With our Social-Media-Pages, we can communicate with you and provide you with interesting information. We may receive further data from you through your comments, shared images, messages and reactions, which we then process to answer or communicate with you. If you use Social Media on several end devices, a cross-device analysis of the data can take place.
Furthermore, the providers of the Social-Media-Pages may use your data on your behavior, interests etc. and may also use cookies and tracking technologies to analyze and improve their services.
Data processing takes place with your consent or for the purpose of answering your enquiry (Art. 6 (1) a, b GDPR) or on the basis of legitimate interests in improving the services and presentation to the outside world (Art. 6 (1) f GDPR).
Use of Page Insights and Cookies on Facebook
On our Facebook pages the Page Insights function to process statistical data from users is used. (see also the agreement at: https://www.facebook.com/legal/terms/page_controller_addendum). This involves the processing of data in the form of so-called 'page insights' by Ulinzi Conservation Coffee and Facebook, which are described in more detail at https://www.facebook.com/business/a/page/page-insights.
Evaluations and statistics are generated in the form of page insights from the usage data of the Facebook pages, which support us in improving our marketing activities and our external presence. We may also learn about users and their behavior who interact with or use our Facebook Pages to display relevant content and develop features that may be of interest to them. These page statistics show us, for example, which people from certain target groups interact most with our Facebook Page or which content on the Facebook Page was visited, shared or liked when and how often. When classifying people into target groups, demographic data or data about the location of a person is also included in order to place targeted advertisements with these people. If you use Facebook on several end devices, a cross-device analysis of the data can take place. The data collected in this way is statistically processed and usually anonymous, i.e. we cannot establish any reference to the individual person.
Information on these page insights and data processing can be found, for example, in Facebook's data protection statement at https://www.facebook.com/policy.php or at https://www.facebook.com/business/a/page/page-insights.
Facebook also uses cookies and storage technologies. More information can be found here: https://www.facebook.com/policies/cookies/
Data processing and Cookies when using LinkedIn
On our LinkedIn pages LinkedIn and Ulinzi Conservation Coffee may use your data for careers and recruiting services (see also the data processing agreement: https://legal.linkedin.com/dpa). Data on how you use LinkedIn may be shared with us and certain third parties as described in detail here: https://www.linkedin.com/legal/privacy-policy#share. LinkedIn also uses cookies and similar technologies as set forth here: https://www.linkedin.com/legal/cookie_policy
Instagram Insights and Cookies on Instagram
When using Instagram and you have an account there, Instagram can assign your activities to your profiles there. On our Instagram pages the Instagram Insights function to process statistical data from users is used (see also for Facebook which is connected to the provider of Instagram the agreement at: https://www.facebook.com/legal/terms/page_controller_addendum). This involves the processing of data in the form of so-called ‘Instagram Insights’ by Instagram and Ulinzi Conservation Coffee, described in more detail at https://help.instagram.com/788388387972460?helpref=faq_content.
Evaluations and statistics are generated in the form of Instagram Insights from the usage data of the Instagram pages, which support us in improving our marketing activities and our external presence. Instagram Insights lets us learn more about our users and the performance of our website. For this purpose Instagram provides us with statistics on specific posts and stories created to find out how users interacted with them. When classifying people into target groups, demographic data or data about the location of a person is also included in order to place targeted advertisements with these people. If you use Instagram on several end devices, a cross-device analysis of the data can take place. The data collected in this way is statistically processed and usually anonymous, i.e. we cannot establish any reference to the individual person.
Instagram also uses cookies and similar technologies. For more information please refer to: http://instagram.com/about/legal/privacy/
When using our Website and Service, your data may be transferred to countries outside the EU because of the use of third-party providers.
Use of Services on the Website that process data outside the EU - When visiting the Website, data may be transferred to countries outside the EU, for example when we use a Google service (see Google Analytics / Campaign Manager above) and/or a social networks service. The US companies providing the services of Facebook, Instagram, Google/YouTube, Twitter and LinkedIn are certified under EU-US-Privacy-Shield and comply with data protection standards applicable in the EU. The “Privacy Shield” is an agreement between the European Union (EU) and the USA to ensure compliance with European data protection standards in the USA. For more information on Privacy Shield please refer to https://www.privacyshield.gov/.
Further Third-Party Providers that process data outside the EU
Data is transferred outside the EU due to the integration of cloud and hosting services who work on our behalf and assist us in carrying out our business activities (legal basis Art. 6 (1) b. or f. GDPR) or you explicit consent (legal basis Art. 6 (1) a. GDPR).
We use the service by Amazon Web Services, Inc., 410 Terry Avenue North Seattle WA 98109, USA for the purpose of hosting your data provided through the Website or Service, whereas data might be processed in the USA. AWS is certified according to EU-US-Privacy-Shield and complies with data protection standards applicable in the EU. For further information please refer to https://aws.amazon.com/compliance/eu-data-protection/ and https://aws.amazon.com/compliance/germany-data-protection/
For sending emails and newsletters we use the services by Mailchimp. For more details please refer to “Use of Mailchimp; Transfer of Data outside the EU” explained above.
Your Rights and Objections, Contact Details
In accordance with the statutory provisions, you as the data subject have the right to receive information about your data stored by us free of charge at any time.
In addition, you can assert your rights to correction, deletion or restriction of the processing or the right to object at any time. This also applies to your right to receive your data in a structured, current and machine-readable format or (if applicable) to request the transmission to another person responsible (data portability).
If you have provided us with your personal data on the basis of a consent, you can withdraw the consent at any time for the future.
As explained above, these aforementioned rights must be exercised vis-à-vis Facebook, Twitter, LinkedIn, YouTube or Instagram respectively.
You or the person affected also have the right to lodge a complaint with a supervisory authority at your choice (for example: https://www.datenschutz-bayern.de/vorstell/impressum.html). An overview of the Data Protection Authorities may be found here: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html or http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080
As a Facebook user, you can at any time influence how your user behavior is recorded when you visit Facebook pages. To do this, you can manage the settings for advertising preferences in your Facebook account or at https://www.facebook.com/ads/preferences, or the Facebook settings in your account or at https://www.facebook.com/settings. Facebook also provides opportunities to contact or exercise rights at https://www.facebook.com/help/contact/2061665240770586 or https://www.facebook.com/help/contact/308592359910928.
As a LinkedIn user, you can at any time influence how your user behavior is recorded when you visit LinkedIn pages. To do this, you can manage the advertising and general settings in your account under https://www.linkedin.com/psettings/privacy. LinkedIn also provides opportunities to contact and exercise rights under https://www.linkedin.com/legal/privacy-policy, https://www.linkedin.com/legal/cookie-policy and for individual messages online via https://www.linkedin.com/help/linkedin/ask/TSO-DPO.
As an Instagram user, you can at any time influence how your user behavior is recorded when you visit Instagram pages. To do this, you can manage the settings for advertising preferences in your Instagram account or under https://www.instagram.com/accounts/privacy_and_security/. Instagram also provides opportunities to contact or exercise rights at https://help.instagram.com/contact/1845713985721890 or http://instagram.com/about/legal/privacy/
Duration of data processing and Deletion Periods
As a rule, we only store your personal data for as long as it is necessary for the execution of the contract or the respective purpose and limit the storage period to an absolutely necessary minimum.
In the case of long-term contractual relationships, these storage periods may vary, but are generally limited to the duration of the contractual relationship or, with regard to the inventory data, to the maximum legal retention periods (e.g. in accordance with the German Commercial Code (Handelsgesetzbuch, HGB) and the Tax Code (Abgabenordnung, AO)).
Criteria for the storage period include whether the data is still up-to-date, whether the contractual relationship with us still exists, whether an inquiry has already been processed, whether a process has been completed or not, and whether legal retention periods for the personal data concerned are relevant or not.
Data Security
We have installed technical and organizational measures in order to safeguard our Website and/or Service against loss, destruction, access, changes or the distribution of your data by unauthorized persons.
The Website is operated through a safe SSL-connection. If an SSL-connection is activated third parties are prevented from reading any data that are transferred by you to us.
We will store your data on servers, which are located within the European Union and, as applicable and set forth in this privacy policy, in the USA.
Access and Changes to this Privacy Policy
This privacy policy is accessible via our website and may be downloaded and printed anytime. We reserve the right to change the regulations of this privacy policy as well as our additional privacy policies at any time, taking into account currently applicable data protection provisions. In case of any changes, you will be notified and you will have to agree to the modified provisions.
Contact
For any inquiries and additional questions about processing personal data please contact steffen@ulinzi-conservation-coffee.com