1. Contact details of the data controller and the data protection officer
FRAEND GmbH (hereinafter also referred to “FRAEND”, “we” or “us”) offers you the opportunity to use various services free of charge via our website “fraend.com” and our applications (“apps”) “FRAEND” (hereinafter collectively referred to as “services” or “FRAEND websites“).
We are the data controller in accordance with the General Data Protection Regulation (GDPR). Our contact details are as follows:
Our data protection officer can be contacted at:
In the following we provide you with comprehensive information about the purposes for which and scope within which we process your personal data during the use of the FRAEND websites.
2. Collection and processing of personal data
You can generally use the FRAEND websites – for which no payment or registration is required – without providing personal data. In certain cases, we will collect the personal data listed in Section 3. This fundamentally only occurs when necessary for the provision of a functional website or app, or for our content and services. Furthermore, we process personal data in connection with the use of FRAEND where you provide this data voluntarily, e.g. in the context of registration, a competition, an enquiry sent to us, or because there is another legal basis for this (see Section 4).
3. Categories of data processed
As soon as you visit fraend.com or use one of the apps, our system automatically collects certain technical information. This can include:
Furthermore, we process the following personal data where a contractual relationship exists between you and us, or where you have communicated the data to us in another manner:
4. Occasions, reasons for and content of processing: The FRAEND websites and services in
We always process your data on the basis of one or more legal permissions or with your consent.
a. Submission of reviews and comments
Personal data is collected by FRAEND when you as a customer submit your review of a product, service, service provider or retailer (hereinafter also referred to as “online shop”), or participate in a survey. In this context, FRAEND collects the data specified in the respective form and the IP address assigned to the device used by you at the relevant point in time.
Information about you will only be published on the relevant FRAEND websites when this is indicated in the field of the form. In the case of opinions about online shops, the customer or order number specified by you is also shared with the specific online shop; this is an integral part of our review and comment function, because only then can the online shop be notified of your comments and opinions. We collect and process the data you provide in order to be able to publish your review or comment as desired (Art. 6 para. 1 lpoint b GDPR). In particular, we also require your email address, so we can contact you in the event of complaints and give you the opportunity to respond (Art. 6 para. 1 point c GDPR).
b. Shopping function
Based on Art. 6 para. 1 point b) of the GDPR, we additionally collect personal data when you as a customer directly submit a contractual offer for specific products listed on the FRAEND websites without leaving FRAEND and being redirected to the websites of the online shops offering these products (the “shopping function”). FRAEND collects this data in order to initiate the contract, as well as for the invoicing of the respective online shop for our brokerage service.
FRAEND transmits this personal data to the respective online shop, where this is required for the conclusion and processing of your contract. If FRAEND and/or the online shop utilises the services of third parties as service providers for the completion and processing of the contract, e.g. for the processing of the payment or the shipping of goods (hereinafter referred to as “service providers”), the required data will only be shared with these third parties of the fulfillment and processing of your order. During the process of handling your order or purchase, you will also receive emails to the email address you provided from the respective online shop (e.g. order or purchase confirmation) and, if applicable, from service providers (e.g. payment confirmation or information about the shipping process).
c. Forms, comparison calculator and payment services for the shopping function:
Unless otherwise indicated, FRAEND itself will collect the data you enter in the respective contact forms.
When you enter data in contact forms, we will only use the data for the purpose of conducting the communication with you and/or to provide the service you request; this constitutes our legitimate interest. The processing takes place in accordance with Art. 6 para. 1 point B of the GDPR.
d. Emails and Newsletter
We may use the email address you provided when registering or initiating a buying contract to contact you in relation to goods and services, your purchases or general information about FRAEND. The processing of email addresses takes place on the basis of our legitimate interest in advertising our goods and services in accordance with Art. 6 para. 1 point f GDPR.
We will use your email address to send you our newsletter, provided that you have subscribed to it and consented to receiving it, including potential advertisements. In this such cases we will process your email address for the purposes of sending the newsletter as requested (Art. 6 para. 1 point b GDPR). You can object to the use of your email address for such purposes at any time in writing or via email (firstname.lastname@example.org) effective for the future, without incurring any costs other than the transmission costs according to basic rates.
The content of our newsletters is partly selected based on your prior use of the FRAEND websites and your expressed interest in products and content. This enables us to tailor the respective newsletter specifically to you and your interests. For example, if you have previously searched for apparel goods on the FRAEND websites, we would rather present you with apparel goods in our newsletter than other product groups. For this purpose, we also process data that we have collected via our cookies (for more information about these cookies, see paragraph 9 c. below), and link them to your email address. The legal basis for this data processing and the display of content relevant to you is Art. 6 para. 1 point f GDPR. However you can object to this data processing at any time (see section 16 a).
e. IP addresses
On the internet, every device needs a clear address in order to transmit data. This is known as its IP address. It is a technical requirement for the IP address to be saved, at least temporarily, in order to facilitate the delivery of the internet page and app content to the user's device.
a) Log files
For security purposes, our servers save the IP address in so-called log files for 14 days. Reasons for this include being able to determine what happens if an attack (DoS) is made on FRAEND websites, or if illegal analysis of our databases occurs. This is based on Art. 6 para. 1 point f GDPR.
b) Geolocalisation etc.
Before any further or other processing, we shorten the IP addresses, then process them in an anonymised state. Unabbreviated IP addresses are not processed further.
The processing of the (abbreviated) IP addresses allows us to display content with regional relevance on all FRAEND websites that are accessed from within a certain region. This so-called geolocalisation, or basing the appearance of a website on the location from which it is accessed takes place exclusively on the basis of anonymised IP addresses, and only to a regional level. Under no circumstances can the geographical information obtained, in this manner be used to determine the specific location of a user.
f. Location information of devices
If you use the FRAEND pages on a mobile device or our app, we may collect information about your location if you have instructed your device to send such information to the application via the privacy settings on that device. For example, we may use the transmitted location information to perform analyzes on the use of our app. You can change the privacy settings of your device at any time to disable the sharing of location information. Please note that disabling location information may affect certain features of our app or mobile website. If you have questions about the privacy settings of your device, we suggest you contact the manufacturer of your device or your mobile service provider for help.
5. Occasions, reasons for and content of processing: FRAEND User Account
FRAEND offers you the possibility of creating your own customer account free of charge. To use the "FRAEND User Account" customer account, you must register with a valid email address and a password. We then use this data to provide you with the customer account, to manage it and to enable its use. This processing is based on Art. 6 para. 1 point b GDPR.
When registering for the “FRAEND User Account” customer account, you consent to FRAEND using cookies to collect information about your use of FRAEND and connecting this information to your customer account for the purpose of personalised emails. Usage data is collected and saved whenever you search for or view products, add products to Wallet or purchase products using the shopping function. On the basis of your usage behaviour, FRAEND creates a list of potential interests, which it uses to select content specifically tailored to you and display this content on FRAEND pages, thus offering you the full range of functions available with the "FRAEND User Account" customer account. This processing of data and, in particular the linking of data with your account, is based on Art. 6 para. 1 point a GDPR. Furthermore, this data processing and display of content relevant to you constitutes a legitimate interest in connection with Art. 6 para. 1 point f GDPR.
Based on this data, we also send you product-related and FRAEND-related messages that we assume will be of interest to you to the email address associated with your customer account. The aim of these messages is to help you find the products and services that are right for you. Product recommendations and price information is typically included in the product-related emails. In this way, we will send you mails regarding price decreases for products you have searched for or viewed, as well as mails regarding suitable product alternatives or accessories. We will also inform you about price drops for products in Wallet (see "Wallet" below). FRAEND-related messages are also sent via email and typically refer to promotions, marketing campaigns and news (e.g. new discounts, voucher codes and competitions). In addition, FRAEND-related messages serve to provide you with information regarding new features and usage possibilities both for general use of FRAEND and for use of your FRAEND customer account.
Alongside the services described above, the "FRAEND User Account" customer account also offers you the following functions described below:
You can “save” FRAEND products by adding them to “Wallet”. You are identified as the owner of your “Wallet” list by the cookies that are used. The “Wallet” list allows you to compare products with one another in terms of their specifications. The “Wallet” list will be added to by FRAEND with any products for which you have accessed the checkout screen but not completed the purchase using FRAEND's “shopping function”. Based on your “Wallet” list, you will receive product recommendations via email, for example if the prices of the products you have saved change. The legal basis here is Art. 6 para. 1 point b GDPR.
b. Order history
If you use the shopping function, we provide an order history on the basis of Art. 6 para. 1 point b GDPR, provided that you were logged in to your “FRAEND User Account” account at the time of purchase. Your order is linked to the pseudonymous user ID stored by us. In the order history you receive an overview of your completed purchases, as well as the processing and shipping status of current orders. You also have access to a contact form which you can use to make enquiries about your orders to FRAEND customer service. When submitting the form, an email with the email address given at the time of purchase will be sent to email@example.com.
c. Account settings
You can change your password or delete your account in the customer account settings.
6. Sharing of data
When you interact and communicate on the FRAEND platform, you can choose the visibility and sharing options for account. There are three different account types on FRAEND: Private, Public and Official.
"Public information" can be viewed / seen by anyone, on or off the platform, also if they don't have an account. This includes your profile image, username, first name and any information you might share with a public audience. You, other platform users and FRAEND can provide access to or send public information to anyone on or off the platform, like search results or through external tools like APIs. Public information can be viewed, reshared or downloaded through third-party service providers such as search engines, APIs and by apps, websites and other services that integrate with FRAEND.
"Account information" include products you follow, collections you follow and the public collections that you have created on FRAEND. If your account is set as "Public", anyone on and off the platform, also if they don't have an account, can see your account information. For Official accounts, account information can only be viewed by users of the platform, based on a paid subscription plan. For Private accounts, account information can only be seen by users of the platform that you have an opt-in friend connection with.
7. Location of processing
We ourselves do not transfer your personal data to countries outside of the European Economic Area ("EEA"), except in cases where it is permitted under the GDPR. Whether third parties, with whom you have your own contractual relationship (such as with Facebook, if you have a Facebook account) transfer data to countries outside of the EEA, is beyond our knowledge and influence.
Some of our contractual partners also process data in countries outside of the EEA. In order to also ensure the protection of your personal rights in the context of these data transfers, we use the standard contractual clauses of the EU Commission pursuant to Art. 46 para. 2 point c GDPR when drafting contractual relationships with recipients in third countries.
For the US, the European Commission decided on 12th July 2016, that under the regulations of the EU-US Privacy Shields an adequate level of data protection exists (adequacy decision, Art. 45 GDPR). Further information - including the certification of the service providers we use - is available at https://www.privacyshield.gov. We only use US service providers who are certified under the EU-US Privacy Shield.
8. Origin of data
In certain cases, we also receive data because you have consented to it being transmitted to us.
As you know, apps are regularly made available to download via third-party providers (e.g. iTunes, Google etc.). If under the applicable terms and conditions of use of such a provider, FRAEND GmbH becomes your contractual partner for the acquisition of the app, we process the data made available to us by the third-party provider to whatever extent is necessary for the fulfilment of contract, so that you can download the app to your mobile device.
9. Disclosure of your data to third parties
We will only disclose your personal data to third parties where such a transmission is necessary in order to fulfil our legal obligations to you, and where this is visibly done by or together with another provider (e.g. in the case of cooperation agreements), where we are otherwise legally entitled or obliged to disclose the data, or where you have provided us with the relevant consent.
In certain cases, we also use external service providers or affiliated companies, which we have contracted to process data for us in accordance with our instructions. Such service providers are contractually bound by us as data processors in compliance with the strict provisions of the GDPR, and are not permitted to use your data for any further purposes. Data processors used by us perform in particular the following services: data centre, newsletter distribution and web/app analysis.
This disclosure of data to data processors takes place on the basis of Art. 28 para. 1 GDPR, or alternatively on the basis of our legitimate interest in the economic and technical benefits associated with the use of specialised data processors, Art. 6 para. 1 point f GDPR.
Where we are legally obliged to do so, or where this is permitted under data protection law, we will disclose personal data to public authorities, e.g. to police or the state prosecutor’s office (Art. 6 para. 1 point c GDPR). The disclosure of this data takes place on the basis of our legitimate interest in combating abuse, the prosecution of crimes, and in safeguarding, asserting and enforcing claims, which are not considered to be outweighed by your rights and interests in the protection of your personal data, Art. 6 para. 1 point f GDPR.
10. Cookies and other technologies
In order to ensure the full functionality of the FRAEND websites, FRAEND and the third parties named below will save files to your device that amongst other things collect information regarding the use of a website or app, as well as additional data such as the IP address of the computer and information about the software being used (see above).
This typically involves the use of so-called cookies. Cookies are small files that your browser saves on your device in a folder created especially for this purpose. These allow it to be determined, for example, whether you have ever visited a website before. If you decide to stay logged into your user account despite leaving the FRAEND websites, cookies can also be used to save your login data e.g. for the user account, so that you do not need to enter this data every time you access the site.
Many cookies contain unique identifier known as a cookie ID. This code consists of a sequence of characters that allow websites and servers to be mapped to the specific internet browser in which the cookie has been saved. This enables the websites visited to differentiate the individual browser of a specific user from other internet browsers that contain different cookies. This data is not collated with any other data sources.
You can prevent us from using cookies at any time by adjusting the corresponding setting in your internet browser, and thus permanently opt out. Furthermore, you can delete existing cookies at any time using your internet browser or other software programs. This is possible in all conventional internet browsers. If you deactivate cookies in the internet browser you use, you may not be able to make full use of all the functions of our website. In addition, you have the opportunity to object to analysis cookies and services (i.e. you can opt out; see Sections 10 and 11).
When using apps, a functionally comparable technology is used instead of cookies.
b. Web storage (session storage and local storage)
Web storage provides two data objects, the session storage and the local storage. The entries in session storage are removed automatically after the browser or app is closed. You can erase the entries in local storage (“Recently Viewed”) at any time by deleting the history in your browser.
The session storage saves information in order to recognise your browser or device from previous visits, and thus provide you with easier access to our services. You can prevent the use of web storage by changing the corresponding setting in your browser, which may restrict the functionality of the FRAEND websites.
The processing of data in web storage takes place on the basis of Art. 6 para. 1 point f) GDPR. Our legitimate interest lies in the purposes of processing as described above.
c. FRAEND cookies
Cookies created by FRAEND allow the collection of information regarding browser type/version, resolution, previous/new display variant, URL clickstream (order of the pages of our website that you have visited previously), time of visit(s) to the websites, the reference in the FRAEND database for the products/services added to “Wallet”, and the cookie number, but not personal details such as name, address or email address. We use these cookies for purposes of advertising, market research and when required, for the design of our services in conjunction with user needs. The cookies of FRAEND are valid for a maximum of two years, unless you delete them sooner. The processing of data is justified in this case by Art. 6 para. 1 point f) GDPR, however you can object to this processing with effect for the future by clicking here. The subsequently set opt-out cookie and your objection remain valid as long as you do not delete your browser cookies.
11. Web/app analysis services, marketing
In order to continuously improve our content and adapt it to the interests of our users, and to display usage-based online advertising, we use a number of services that collect data from our website and the app, and analyse this data for us. Where these service providers are not themselves the data controller with specific regard to data protection legislation, they are always bound by instructions when processing the pseudonymised user data on the basis of a data processing agreement. The legal basis for this processing is always Art. 6 para. 1 point f GDPR.
Not all access to the FRAEND pages is carried out via a web browser. In cases where users access FRAEND from a mobile device, disabling cookies or changing web browser settings may not be possible.
In the following, you can find details of the analysis services and marketing partners we use:
a. Facebook Website Custom Audiences and Facebook Conversion Pixel
Please click here if you do not wish data to be collected via Custom Audiences.
You can object to this processing of data via the Facebook Conversion Pixel with effect for the future by clicking here.
b. Google Products
a) Google AdSense
We have integrated Google AdSense on this website. Google AdSense is an online service that allows the mediation of advertising on third-party websites. Google AdSense is based on an algorithm that selects advertisements for third-party websites based on the content of the respective third-party website. Google AdSense permits interest-oriented targeting of internet users, which is implemented by generating individual user profiles.
The operating company of the Google AdSense component is Alphabet Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA.
The purpose of the Google AdSense component is the integration of advertisements into our website. Google AdSense saves a cookie to your browser. The definition of cookies is available above. Saving the cookie allows Alphabet Inc. to analyse the use of our website. Each time one of the individual pages of this website, which we operate and on which a Google AdSense component has been integrated, is visited, the internet browser on your device is automatically prompted by the respective Google AdSense component to send data to Alphabet Inc. for the purposes of online advertising and the invoicing of commissions. Within the framework of this technical process, Alphabet Inc. receives knowledge of personal data, such as the IP address of the data subject, which is used by Alphabet Inc., amongst other things, to determine the origin of the visitor and the clicks, and subsequently to facilitate commission invoicing.
You can prevent cookies from being used by our website at any time, as already described above, by adjusting the corresponding setting in the internet browser used, and thus permanently opt out.
Activating this setting in the internet browser would also prevent Alphabet Inc. from saving a cookie on the information technology system of the data subject. Furthermore, you can delete any cookie saved by Alphabet Inc. at any time using your internet browser or other software programs.
Google AdSense additionally uses so-called tracking pixels. A tracking pixel is a miniature graphic that is embedded into websites in order to allow log file recording and log file analysis, which allows a statistical analysis to be performed. This embedded tracking pixel means Alphabet Inc. can recognise when a website was opened by a data subject, and the links that the data subject clicked. Tracking pixels are used, amongst other things, to analyse the visitor traffic of a website.
Google AdSense sends personal data and information, including the IP address, which is necessary for the creation and invoicing of the displayed adverts, to Alphabet Inc. in the USA, where it is saved and processed. Under certain circumstances, Alphabet Inc. may disclose the personal data collected using this technical process to third parties.
Google AdSense is explained in greater detail at this link https://www.google.co.uk/intl/en/adsense/start/#/?modal_active=none and https://policies.google.com/technologies/partner-sites?hl=de. More information and options for the deactivation of this advertising placement can be found at https://adssettings.google.com/u/0/authenticated?hl=en.
b) Google AdWords
We have integrated Google AdWords on this website. Google AdWords is an online advertising service that allows advertisers to place advertisements both in the search results of Google and in Google’s advertising network. Google AdWords allows an advertiser to predefine certain keywords, by means of which an advertisement is displayed in the search results of Google exclusively when the user of the search engine accesses search results related to the keyword. In the Google advertising network, the advertisements are distributed to thematically relevant websites using an automated algorithm with reference to the predefined keywords. The operating company of the services of Google AdWords is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA. The purpose of Google AdWords is to promote our website by displaying interest-based advertising on the websites of third-party companies and in the search results of the Google search engine, as well as displaying third-party advertising on our website. If you come to our website via a Google advertisement, Google saves a so-called conversion cookie to the information technology system of the data subject. The definition of cookies is available above. A conversion cookie becomes invalid after thirty days and is not used to identify the data subject. Until the conversion cookie expires, it is used to determine whether certain sub-pages, for example the shopping basket of an online shop system, are accessed on our website. The conversion cookie allows both us and Google to track whether a data subject that comes to our website via an AdWords advertisement generates sales, i.e. whether a purchase has been completed or aborted.
The data and information collected by the conversion cookie is used by Google to create visitor statistics for our website. In turn, these are used by us to determine the total number of users that have accessed FRAEND via AdWords advertisements, and thus to determine the success or failure of the respective AdWords advertisements, and to optimise these for the future. Neither our company nor any other advertising customers from Google AdWords receive information from Google that could allow the data subject to be identified.
The conversion cookie saves personal information, for example the websites visited by the data subject. For each visit to our websites, personal data is sent to Google in the USA, including the IP address of the internet connection used by the data subject. This personal data is saved by Google in the USA. Under certain circumstances, Google may disclose the personal data collected using this technical process to third parties.
The data subject can prevent cookies from being used by our website at any time, as already described above, by adjusting the corresponding setting in the internet browser used, and thus permanently opt out. Activating this setting in the internet browser in use would also prevent Google from saving a conversion cookie on the information technology system of the data subject. Furthermore, you can delete any cookie saved by Google AdWords at any time using your internet browser or other software programs.
The data subject also has the option of withdrawing consent for the display of interest-based advertising from Google. To do this, the data subject should access the link https://adssettings.google.com/u/0/authenticated?hl=en and change the desired settings in each internet browser that they use.
You can also deactivate or opt out of Google advertisements https://privacy.google.com/?hl=gb#google-experience wholly or in part.
You can also object to this processing of data by AdWords with effect for the future by clicking here.
c) Google Analytics
We have integrated Google Analytics (with anonymisation function). Google Analytics is a web analysis service. Web analysis is the recording, collection and evaluation of data regarding the behaviour of visitors to websites. A web analysis service collects data, amongst other things, about the websites from which a data subject arrived at another website (known as the referrer), which sub-pages of the website were accessed, or how often and for how long a sub-page was viewed. A web analysis is predominantly used for optimisation of a website and for the cost-benefit analysis of online advertising.
The operating company of the Google Analytics component is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA.
For the web analysis via Google Analytics we use the suffix "_gat._anonymizeIp". This suffix means that the IP address of the internet connection used by the data subject is abbreviated and anonymised by Google if the access to our websites originates in a Member State of the European Union or from another signatory state to the Treaty on the European Economic Area.
The purpose of the Google Analytics component is the analysis of visitor traffic on our website. Google uses the data and information obtained, amongst other things, to analyse the use of our website, in order to compile online reports for us which identify the activities on our websites, and in order to provide additional services relating to the use of our website.
Google Analytics saves a cookie to the information technology system of the data subject. The definition of cookies can be found above. Saving the cookie allows Google to analyse the use of our website. Each time one of the individual pages of this website, which we operate and on which a Google Analytics component has been integrated, is visited, the internet browser on the information technology system of the data subject is automatically prompted by the respective Google Analytics component to send data to Google for the purposes of online analysis. Within the framework of this technical process, Google receives knowledge of personal data, such as the IP address of the data subject, which is used by Google, amongst other things, to determine the origin of the visitor and the clicks, and subsequently to facilitate commission invoicing.
We use the Google Analytics feature “Demographic and Interests Reporting”. In order to compile these statistical reports, Google makes use of data that Google has collected in connection with interest-based advertising and visitor data (e.g. age, gender and interests) from third-party providers. FRAEND cannot associate this data with a specific person or a specific user ID, but Google may be able to do so. You can opt out of data collection by Google by turning Google “ad personalisation” off at the following link: https://www.google.de/settings/ads.
We also use the Google Analytics feature “Google Signals”. This feature provides aggregated reports on cross-device user counts as well as different groups of users based on the different device combinations they use. This information is not associated for us with a specific person or a specific user ID. However, in order to compile these reports, Google uses the data of its users who have the “ad personalisation” option turned on in their Google account settings. For this reason, we assume that Google can associate the data with specific users who have Google accounts. You can opt out of the collection of data via Google Signals by turning Google “ad personalisation” off in your Google account: https://support.google.com/ads/answer/2662922?hl=en.
You can also object to this processing of data via Google Analytics with effect for the future by clicking here.
d) Google Dynamic Remarketing
On the website, we use the remarketing or “similar audiences” function of Google Inc. (“Google”), operated by Google Remarketing is Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA. This function allows the provider to target visitors to the website individually, by displaying interest-based advertisements that are personalised for the visitors to the provider’s website if they have visited other websites in the Google Display network. Google uses so-called cookies to perform the analysis of the website use, which forms the basis for creating personalised, interest-based advertisements. To this end, Google saves a small file with a series of numbers in the browsers of visitors to the website. This number is used to record visits to the website and anonymised data about the use of the website. The personal data of visitors to the website is not saved. If you subsequently visit another website in the Google Display network, you will be shown advertisements that have a greater probability of including products and product groups that you have already viewed.
You also have the option at any time of opting out of Google's interest-based advertising. To do this, you should access the link https://adssettings.google.com/u/0/authenticated?hl=en and change the desired settings in each internet browser that you use.
e) Google Tag Manager
FRAEND uses the Tag Manager from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Tags are the IDs of data elements. Tracking pixels from the third-party providers named here are loaded on the websites. The Tag Manager tool itself (which implements the tags) is a cookie-free domain and does not record personal data. The tool ensures that other tags are triggered, which in turn may record data. However, Google Tag Manager does not access this data. Further information is available here: https://www.google.com/intl/en-uk/tagmanager/use-policy.html and https://policies.google.com/privacy?hl=en-GB&gl=de.
f. Twitter Remarketing (contact with FRAEND users)
This website uses Twitter’s remarketing feature (Twitter Inc., 1355 Market Street Suite 900, San Francisco, CA 94103, USA) to enable FRAEND to address users with advertising on Twitter that is based on their interests. For this purpose, Twitter uses so-called “tags”. These tags are used to record data on website visits and website usage. When a user visits a website containing such a tag, Twitter saves a cookie in the user’s browser. This cookie’s unique ID is recorded, and it is included in the target audience for remarketing on Twitter. Twitter users can deactivate this function by following the instructions provided here: https://support.twitter.com/articles/20171528.
You can also object to this processing of data via Twitter with effect for the future by clicking here.
FRAEND includes GeoLite2 data created by MaxMind, available from https://maxmind.com. GeoLite2 databases are free IP geolocation databases comparable to, but less accurate than, MaxMind’s GeoIP2 databases. The GeoLite2 Country and City databases are updated on the first Tuesday of each month. The GeoLite2 ASN database is updated every Tuesday.
h. Mixpanel FRAEND uses the analytics service Mixpanel, a service of Mixpanel Inc., a company incorporated under the laws of the State of Delaware in the United States of America. The Mixpanel service logs page views and page activity. To enable this, log data is transmitted to Mixpanel. You can find more information about the use of your data on the privacy page of the Mixpanel service https://mixpanel.com/legal/privacy-policy/ in the paragraphs provided for this purpose. If you do not want Mixpanel to receive log information about your activities on this Web site, you can stop recording logs of your activities using the "opt out cookie" that you can download from https://mixpanel.com/legal/privacy-overview/ Please note, however, that this cookie and thus the recording prohibition will be deleted as soon as you delete your cookies in the settings of your browser. Please note that as the operator of the website you are on, we have no influence on the use of your data.
12. Social networks
Each time one of the individual pages of this website, on which a social network component (Facebook plug-in, Google+ plug-in, LinkedIn plug-in, Twitter plug-in) has been integrated, your internet browser is automatically prompted by the respective component of the social network to download a display of the corresponding component. Further information about the technical integration of each respective network can be accessed at the following links: Facebook: https://developers.facebook.com/docs/plugins/?locale=en_US, Google+: https://developers.google.com/+/, LinkedIn: https://developer.linkedin.com/plugins, Twitter: https://about.twitter.com/de/resources/buttons. Within the scope of this technical process, the respective network receives concrete information about which subpages of our website you have visited.
Every time you access our website and are simultaneously logged into a social network, the social network in question detects which specific subpage of our webpage you have visited for the entire duration of each respective stay on our website. This information is collected by the respective component of the social network and associated with your account on the network. If you click on one of the social network buttons integrated on our website, post a comment or make a recommendation, the social network then assigns this data and information to the personal user account of the social network and stores the personal data. Google, for example, connects this personal data with other Google services, citing an optimisation of their services as the reason for doing so.
The network is sent information via the respective network component that you have visited our website, provided that you are logged into the network at the time our website is accessed; this occurs regardless of whether you click the component or not. If you do not wish for this information to be transmitted to the respective social network, then you can prevent this transmission by logging out of your respective social network account before accessing our website. However, the social network also records your page views regardless of whether you are logged into the social network when you visit FRAEND pages.
We have integrated components of Facebook on this website. Facebook is a social network.
A social network is a place for social meetings on the internet, an online community which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for exchanging opinions and experiences, or enable the internet community to provide personal or business-related information. Facebook allows social network users to create private profiles, upload photos and socialise by making friend requests, amongst other options.
Facebook is operated by Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a data subject lives outside of the United States or Canada, the controller responsible for processing personal data is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
We have integrated components of Twitter on this website. Twitter is a multilingual, publicly accessible microblogging service on which users may publish and spread so-called “tweets” (i.e. short messages) which are limited to 280 characters. These short messages are accessible to everyone, including those who are not logged into Twitter. The tweets are also displayed to the so-called followers of the respective user. Followers are other Twitter users who follow a user's tweets. Furthermore, Twitter allows users to address a wider audience via hashtags, links or retweets.
Twitter is operated by Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.
13. Payment providers
We have integrated Stripe to facilitate payments on this website. Stripe is an online payment service provider of Stripe, Inc185 Berry Street, Suite 550, San Francisco, CA 94107, USA. FRAEND uses Stripe to process payments for some of our existing customers and provide billing information to these customers. For those existing customers who are billed with Stripe, the following data is sent, and stored by Stripe. If you sign up to a paid FRAEND subscription, the following data will be sent to Stripe, and saved by them:
If you wish to avoid sending your data to Stripe, you can do so by not signing up for a paid FRAEND plan. If you do so however, your ability to use FRAEND’s functions could be severely reduced. You may find further information about Stripe’s data processing and data protection here: https://stripe.com/us/privacy
We use the subscription billing and recurring payments software Chargebee by Chargebee Inc., 340 S. Lemon Avenue, Suite 1537, Walnut, California 91789, USA. FRAEND uses Chargebee to process payments for some of our existing customers and provide billing information to these customers. For those existing customers who are billed with Chargebee, the following data is sent, and stored by Chargebee. If you sign up to a paid FRAEND subscription, the following data will be sent to Chargebee, and saved by them:
If you wish to avoid sending your data to Chargebee, you can do so by not signing up for a paid FRAEND plan. If you do so however, your ability to use FRAEND’s functions could be severely reduced. You may find further information about Chargebee's data processing and data protection here: https://www.chargebee.com/privacy.html
14. Other services
Other services used by us include:
a. Facebook Connect
You can also log into a Facebook account to post comments on certain FRAEND websites.
b. Google Maps
c. Google reCaptcha
For security purposes, this site uses reCaptcha, a service provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (Google). This service determines whether the information in an online form has been provided by a human being or fraudulently by automated machine processing. Your previously abbreviated IP address and any other data required for the service will be transmitted to Google. Only in exceptional cases will the full IP address be transferred to a Google server in the US and abbreviated there. The data transmitted by your browser while using reCaptcha will not be merged with other data from Google. Further information about Google's data protection guidelines is available at: https://policies.google.com/privacy?hl=en.
15. Retention period
We only store personal data as long as we are legally entitled to do so and as long as the purpose for processing data is still valid. Data will then be erased after a short period of time.
It is, however, not always possible for us to specify the exact retention period for all data or categories of data. In regards to the retention period, we strictly adhere to the law. If, for example, it is still possible to make claims in regards to a contract, we retain the corresponding data and, when Art. 6 para. 1 point f GDPR is applied, your interests and/or basic rights and fundamental freedoms limit the retention period to be implemented and play a significant role in determining it once the requirements of the law are taken into consideration.
16. Repetition of notices of consent
Below you will find the notices of consent FRAEND uses on its websites and which you have issued to FRAEND if required. FRAEND records these statements of consent where appropriate. You may revoke your statement(s) of consent at any point in time, with effect for the future.
Registration for the “FRAEND User Account” customer account:
Consent to receive email advertising
17. Contact data and your rights as the data subject
If you have any questions or suggestions regarding data protection or how to exercise your rights as the data subject, please contact our data protection officer (immediately) at any time:
a. Revocation of consent/Objection to the processing of data
You may revoke your previously given consent at any point in time, with effect for the future, by contacting the address provided above. You may object to your email address being used for the purpose of sending out the newsletter at any time with effect for the future by contacting us either electronically or by post at firstname.lastname@example.org or Brunnenstr. 42 in 10115 Berlin, without incurring any costs other than the postage costs in accordance with the basic tariff.
You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you, which is carried out on the basis of a legitimate or public interest. This also applies to profiling based on these provisions. In the event of an objection, we will no longer process personal data unless we can prove compelling and legitimate reasons for processing that outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.
If we process personal data for direct marketing purposes, you have the right to object at any time to the processing of the personal data for the purpose of such advertising by contacting us at the aforementioned contact address. This also applies to profiling, insofar as it is associated with such direct marketing. In addition, you have the right, on grounds relating to your particular situation, to object to the processing of personal data concerning you for scientific or historical research purposes, or for statistical purposes, unless such processing is necessary for the performance of a task carried out for reasons of public interest.
b. Art. 15 GDPR – right of access for the data subject
You have the right to request confirmation from us as to whether personal data relating to you is processed and, if so, what data this entails as well as the specific circumstances surrounding the processing of data.
c. Art. 16 GDPR – right to rectification:
You have the right to request that we immediately rectify any incorrect personal data concerning you. Taking into account the purposes of the processing, you also have the right to request that incomplete personal data concerning you be completed, also by means of a supplementary declaration.
d. Art. 17 GDPR – right to erasure:
You have the right to request that we immediately erase personal data concerning you if and to the extent the legal requirements to this regard are met.
e. Art. 18 GDPR – right to the restriction of processing:
You have the right to restrict the processing if and to the extent the legal requirements are met.
f. Art. 20 GDPR – right to data portability:
If data is processed by virtue of consent or in order to fulfil a contract, you have the right to receive the personal data that you have provided to us in a structured, common and machine-readable format, and in so far that it is technically feasible, to transmit this data to another controller without us impeding this process or to have this data directly transferred to another controller.
g. Existence of automated decision-making
We refrain from automatic decision-making including profiling according to Art. 22 GDPR.
October 1 2019