Comtravo Privacy Statement

Comtravo is a service of Comtravo GmbH, Schinkestraße 20, 12047 Berlin (hereinafter "Comtravo").

Comtravo offers business travel services in a quick, easy, and uncomplicated way via email, online booking tool, phone, or the Comtravo app and makes them directly bookable for users.

The team at Comtravo takes the protection of your personal data very seriously. The following privacy statement informs you about the details of the collection, processing, and storage of your personal data when using Comtravo.

1.  Data controller

Data controller within the meaning of the GDPR for the processing of your personal data is:

Comtravo GmbH
Schinkestraße 2012047 Berlin
Email: datenschutz@comtravo.com

2.  Collection, processing and use of personal data

2.1 In the sense of the German Federal Data Protection Act (BDSG) and the General Data Protection Regulation (GDPR) the term “personal data” means all individual details of personal or factual circumstances, which make it possible to draw conclusions about the identity of a particular person. Your personal data is used if you provide it to us voluntarily, for example in the context of a contact (clause 4), or if the collection of personal data is necessary for the establishment, execution, or termination of a legal transaction with our company.

2.2 We commit ourselves to take all necessary reasonable measures to ensure a secure transmission and a dutiful and responsible handling of your personal data. Personal data will not be passed on to third parties beyond this unless it is necessary to enforce our rights, there is a legal obligation to do so, or an official order.

After the contract has been fully processed, the personal data will be blocked or deleted for further use; this does not affect tax or commercial law regulations that may require longer retention periods.

3.  Log files, anonymized data

3.1 The use of our website www.comtravo.com is generally possible without disclosing your identity. When visiting the individual pages of our website, only access data is transmitted to our servers, in particular the following access data:

- browser type/browser version
- operating system used
- referrer URL (the previously visited website)
- host name of the accessing computer (IP address)
- time of the server request

3.2 This access data cannot be assigned to specific persons. We do not combine this data with other data sources. After a statistical evaluation for the purpose of optimizing our website, this data is deleted.

The legal basis for the temporary storage of the data and the log files is Art. 6 para. 1, lit. f GDPR.

The temporary storage of the IP address by the system is necessary to enable delivery of the website to the user's computer. For this purpose, the user's IP address must remain stored for the duration of the session.

The storage in log files is done to ensure the functionality of the website. In addition, we use the data to optimize the website and to ensure the security of our information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

These purposes are also our legitimate interest in data processing according to Art. 6 para. 1 lit. f GDPR.

The data are deleted as soon as it is no longer necessary to achieve the purpose of its collection. If the data are recorded for the provision of the website, this purpose is achieved when the respective session is concluded.

If the data are stored in log files, this will be after seven days at the latest. Storage beyond this period is possible. In this case, the IP addresses of the users are deleted or alienated so that an assignment of the visiting client is no longer possible.

4.  Getting in contact with Comtravo

There are various channels available to you for contacting Comtravo. Your personal data will only be collected to the extent that you have voluntarily provided it in this context.

4.1 If you contact us by email, we will collect the email address as well as the additional personal data voluntarily communicated (e.g., name/pseudonym, address, telephone number).

4.2 In order to process your requests faster and more accurately, we use the software of the company Zendesk Inc., 989 Market Street #300, San Francisco, CA 94102, USA ("Zendesk"). Zendesk may access the software application for the purpose of providing technical support for the software, so we cannot rule out the possibility that Zendesk will be in contact with your personal data in the process. In order to ensure an appropriate level of data protection, we have placed Zendesk under special data protection obligations so that any access to your personal data is carried out in compliance with and in application of the European data protection standard, strictly bound by instructions and not for its own purposes. For more information, please refer to Zendesk's privacy policy at www.zendesk.com/company/customers-partners/privacy-policy/. For the use of Zendesk, we have concluded a data processing agreement in accordance with the EU standard contractual clauses.

4.3 Existing Customer Advertising (direct marketing)

We reserve the right to use the email address provided by you during registration or the booking process in accordance with the statutory provisions to send you the following content by email in the future, provided that you have consented to this use and processing of your email address:

- additional interesting offers from our portfolio,
- event information,
- technical information,
- new special offers related to our products and services,
- individual customer advisory service,
- requests for customer feedback,
- questions about special requests.

If the sending of electronic information is not necessary for the fulfillment of the contract (e.g., email in an informational form) and the legal basis is required by Art. 6 para. 1 sentence 1 lit. b) GDPR, the processing is based on the legal basis pursuant to Art. 6 para. 1 sentence 1 lit. f) GDPR. Our legitimate interests in the aforementioned processing are to improve and optimize our services, to send direct marketing and to ensure customer satisfaction. We delete your personal data when you terminate your user contract, but no later than three years after termination of the contract.

We would like to inform you that you can object to the receipt of direct marketing and the processing of data for the purpose of direct marketing at any time without incurring any costs other than the transmission costs according to the basic rates. You have a general right to object without providing any reasons (Art. 21 para. 2 GDPR). After you have expressed your objection, we will delete your personal data in connection with existing customer advertising. To do so, click on the registration link in the respective email or send us your objection to the contact details stated in the section "Information" (clause 8).

4.4 White paper for advertising consent

If you provide us with your contact details (e.g., email address) when downloading a white paper or similar editorial products, you also separately agree to be informed about new products, offers, and promotions from us. This consent is valid until revoked, which you can declare at any time with effect for the future. For example, by sending an email to datenschutz@comtravo.com.

5.  Newsletter

On our website you have the option of subscribing to a free newsletter. When registering for the newsletter, the data from the input mask are transmitted to us.

- Email address
- First name and surname (optional)

In addition, the following data are collected during registration:

- IP address of the calling computer
- Date and time of registration

Your consent is obtained for the processing of data during the registration process and reference is made to this privacy statement.

No personal data are passed on to third parties in connection with the processing of data for the dispatch of newsletters. Your personal data will only be used for the purpose of sending the newsletter.

The legal basis for the processing of the data after registration for the newsletter by the user is Art. 6 para. 1 lit. a GDPR if the user has given his consent.

The personal data will be deleted as soon as it is no longer necessary to achieve the purpose for which it was collected. The user's email address is therefore stored as long as the newsletter subscription is active.

The other personal data collected during the registration process are usually deleted after a period of seven days.

The newsletter subscription can be canceled by the user concerned at any time.

This also enables revocation of the consent to the storage of the personal data collected during the registration process.

6. Disclosure of personal data

Your personal data will only be passed on to the extent necessary for the processing of the contract. In particular, for the processing of payments to Comtravo, we pass on the data required for this purpose to the credit institution commissioned with the payment or to the payment and invoice service provider commissioned by us, if applicable. The processing of payments to Comtravo is carried out via the following service providers:

Payment by credit card:

If you choose the payment method "credit card" of the payment service provider Stripe, the payment will be processed by the payment service provider Stripe Payments Europe Ltd, Block 4, Harcourt Centre, Harcourt Road, Dublin 2, Ireland, to whom we pass on the information you provided during the order process together with information about your order (name, address, account number, bank code, credit card number, if applicable, invoice amount, currency, and transaction number). Your personal data will only be passed on for the purpose of payment processing with the payment service provider Stripe Payments Europe Ltd. For more detailed information on Stripe's data protection, please visit the URL https://stripe.com/de/terms.

The data required for payment processing is transmitted securely via the "SSL" procedure and used by Stripe and Comtravo exclusively for payment processing. Stripe is PCI DSS certified according to its own information. Stripe transfers, processes, and, if necessary, stores personal data outside the EU. Stripe ensures adherence to an appropriate level of data protection by concluding so-called "standard contractual clauses" (European Commission's Standard Contractual Clauses or "Model Clauses"). For the use of Stripe, we have concluded a data processing agreement in accordance with the EU standard contractual clauses.

Payment by invoice: 

In the case of payment by invoice, we reserve the right to forward your personal data (name, address) to the following company for the purpose of conducting a credit assessment:

We also transmit personal data collected in the course of the contractual relationship with you concerning the application, execution, and termination of this business relationship as well as data concerning non-contractual behavior or fraudulent behavior to the following credit bureau:

Verband der Vereine Creditreform e.V. ("Creditreform")
Hellersbergstraße 12
41460 Neuss

The legal bases for these transfers are Art. 6 para. 1 lit. b and Art. 6 para. 1 lit. f of the GDPR. Transfers based on Art. 6 A - 1 lit. f of the GDPR may only take place insofar as this is necessary to protect the legitimate interests of the controller or third parties and does not override the interests or fundamental rights and freedoms of the data subjects which require the protection of personal data. The exchange of data with the Verband der Vereine Creditreform e.V. ("Creditreform") also serves the fulfillment of legal obligations to carry out creditworthiness checks on customers (§ 505a of the German Civil Code, §18a of the German Banking Act).

7.  Transfer of your personal data to third countries

If we process data in a third country (i.e., outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of third-party services or the disclosure or transfer of data to other persons, bodies or companies, this will only take place in accordance with the legal requirements.

Subject to express consent or contractually or legally required transfer, we only process or allow data to be processed in third countries with a recognized level of data protection, contractual obligation through so-called standard protection clauses of the EU Commission, in the presence of certifications, or binding internal data protection rules (Art. 44 to 49 GDPR, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de).

8. Cookies

Cookies are text files that contain data from visited websites or domains and are stored by a browser on the user's computer. A cookie is primarily used to store information about a user during or after their visit within an online offer. Stored information may include, for example, language settings on a website, login status, items in a basket, or where a video was watched. We also include in the term cookies other technologies that perform the same functions as cookies (e.g., when user details are stored using pseudonymous online identifiers, also known as "user IDs").

The following cookie types and functions are distinguished:

- Temporary cookies (also: session cookies):
Temporary cookies are deleted at the latest after a user has left an online offer and closed their browser.

- Persistent cookies: Persistent cookies remain stored even after the browser is closed. For example, the login status can be saved, or preferred content can be displayed directly when the user visits a website again. Likewise, the interests of users used for range measurement or marketing purposes can be stored in such a cookie.

- First-party cookies: First-party cookies are set by us.

- Third-party: Third-party cookies are mainly used by advertisers (so-called third parties) to process user information.

- Necessary (also: essential or strictly necessary) cookies: Cookies may be absolutely necessary for the operation of a website (e.g., to store logins or other user inputs or for security reasons).

- Statistics, marketing, and personalization cookies: Furthermore, cookies are usually also used in the context of range measurement and when a user's interests or behavior (e.g., viewing certain content, using functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to show users content that matches their potential interests. This procedure is also referred to as "tracking", i.e., tracking the potential interests of users. Insofar as we use cookies or "tracking" technologies, we will inform you separately in our privacy statement or in the context of obtaining consent.

Notes on legal bases: The legal basis on which we process your personal data using cookies depends on whether we ask you for consent. If this is the case and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed with the help of cookies is done on the basis of our legitimate interests (e.g., in the business operation of our online offer and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.

Storage period: If we do not provide you with explicit information on the storage period of persistent cookies (e.g., in the context of a so-called cookie opt-in), please assume that the storage period can be up to two years.

General information on revocation and objection (opt-out): Depending on whether the processing is based on consent or legal permission, you have the option at any time to withdraw any consent you have given or to object to the processing of your personal data by cookie technologies (collectively referred to as "opt-out"). You can initially declare your objection by means of your browser settings, e.g., by deactivating the use of cookies (whereby this may also restrict the functionality of our online offer). An objection to the use of cookies for online marketing purposes can also be declared by means of a variety of services, especially in the case of tracking, via the websites https://optout.aboutads.info and https://www.youronlinechoices.com/. In addition, you can obtain further instructions on how to object within the framework of the information on the service providers and cookies used.

Processing of cookie data on the basis of consent: Before we process or allow data to be processed in the context of the use of cookies, we ask users to give their consent, which can be revoked at any time. Before consent has been given, cookies are only used if they are absolutely necessary for the operation of our online offer.

You can also manage many of the online ad cookies on your own via the US site www.aboutads.info/choices/ or the EU site www.youronlinechoices.com.
www.youronlinechoices.com is a service of the European Interactive Digital Advertising Alliance (EDAA), a non-profit association (AiSBL under Belgian law) based in Brussels, concerning the retrieval of information on online interest-based advertising and preference management.

For further information, please also refer to our Cookie Policy.

9.  Integration of external providers for statistical, analysis, and marketing purposes

9.1 We use services from external providers for statistical, market research, and marketing purposes, as well as to link our website with social networks. This enables us to provide a user-friendly, optimized use of the website. The external providers use cookies to control their services (clause VIII). Personal data are not processed and/or stored unless otherwise explained below.

9.2 Many of the external providers offer the possibility of declaring a direct objection to the use of the respective service, e.g., by setting an opt-out cookie. If you activate a corresponding opt-out cookie, the external provider will no longer store any data on your usage behavior in the future. A selective objection to an individually selected choice of external services is also possible.

9.3 Furthermore, you can also object to the use of cookies directly via the opt-out platform of the Bundesverband Digitale Wirtschaft e.V. (BVDW) at www.meine-cookies.org/cookies_verwalten/praeferenzmanager.html or via the deactivation page of the Network Advertising Initiative at www.networkadvertising.org/choices/.

9.4 We also inform you about the services of external providers currently used on our website, as well as about the purpose and extent of the respective data processing in each individual case and about your existing opt-out options. For more information on interest-based advertising and opt-out options please visit the following link: www.youronlinechoices.com.


Google 360 Analytics

This website uses Google 360 Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google Analytics uses these performance cookies, which are stored on your computer with your consent and which allow an analysis of your use of the website. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. However, due to the activation of the IP anonymization ("anonymizeIP“) on this website, your IP address will be shortened beforehand 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 transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator.

The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data.

We use Google 360 Analytics to analyze and regularly improve the use of our website. The statistics obtained enable us to improve our offer and make it more interesting for you as a user.

Third Party Provider Information: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001, Email: support-deutschland@google.com.

Terms of use: http://www.google.com/analytics/terms/de.html
Data protection overview: https://policies.google.com/?hl=de&gl=de
Privacy statement: http://www.google.de/intl/de/policies/privacy

We would like to point out that the Google Analytics cookie has a storage period of 26 months.

The data processing associated with this is carried out on the basis of Art. 6 para. 1 a) of the GDPR in accordance with your consent.

You can revoke your consent to the use of performance cookies at any time with effect for the future.

You may also 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 fully utilize all the functions of this website.

You can also prevent the collection and transmission of data relating to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

Google Ads (formerly Adwords) and Conversion Tracking

We use Google Ads and Conversion Tracking of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter "Google"). In the event of your consent, if you click on an ad served by Google, a cookie will be placed on your computer. These cookies loose their validity after 30 days, do not contain any personal data, and are therefore not used for personal identification. If you visit certain pages of our website and the cookie has not yet expired, Google and we will be able to recognize that you have clicked on the ad and have been redirected to that page. Each Google Ads customer receives a different cookie. As a result, the cookies cannot be tracked through the websites of Google Ads customers.

The information collected with the help of the cookie is used to compile conversion statistics for Adwords customers who have opted for Google Ads and Conversion Tracking. The Adwords customers learn the total number of users who have clicked on their advertisement and been redirected to a page with a Conversion Tracking tag. However, they do not receive any information that can be used to personally identify users.

We have concluded a data processing agreement with Google in accordance with the EU standard contractual clauses.

The legal basis of the processing is your consent in accordance with Art. 6 para. 1 lit. a GDPR. If you do not want data to be collected and processed via Google Ads, you can refuse your consent or revoke it at any time with effect for the future.

Objection to the processing of personal data: You can also prevent the cookie from being placed by adjusting the settings in your browser software.

In addition, you can deactivate the use of cookies through Google by following the link below and installing the plugin provided there www.google.com/settings/ads/plugin or by deactivating Google Conversion Tracking at http://www.google.com/settings/ads/onweb/?hl=de.

More information on Google Ads (formerly AdWords) and Conversion Tracking as well as Google's privacy statement can be found at: http://www.google.com/privacy/ads.

Google Search Ads 360

Provided your consent has been given, we use Google 360 Search Ads. The use of Google Search Ads 360 enables Google and its partner sites to display ads based on previous visits to our or other sites on the Internet. The data collected in this context may be transferred by Google to a server in the USA for evaluation and stored there. Unlike Google Ads (formerly Adwords) & Conversion Tracking which is limited to the Google Search Network, Google Search Ads 360 allows the exchange of ads and keywords with multiple supported search engines.

We would like to point out that the Google Search Ads 360 cookie has a maximum storage period of 30 days.

The legal basis for the processing is your consent in accordance with Art. 6 para. 1 lit. a GDPR. If you do not want data to be collected and processed via Google Search Ads 360, you can refuse your consent or revoke it at any time with effect for the future.

Objection to the processing of personal data: You can also prevent the collection and forwarding of personal data (in particular your IP address) and the processing of this data by deactivating the execution of JavaScript in your browser.

In addition, you can prevent the collection and transmission of data relating to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.

Google Dynamic Remarketing

We also use the Remarketing function in Google AdWords of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter "Google").

Given your consent, the Remarketing function enables us to present website users with advertisements based on their interests on other websites within the Google ad network (i.e., on Google itself, so-called "Google Ads" or on other websites). To do this, your interaction on our website is analyzed, in particular which offers you were interested in, in order to be able to show you targeted advertising on other sites even after you have visited our website. For this purpose, Google stores cookies in your browser that visit certain Google services or websites in the Google Display Network. Via this cookie, the visits of these users are recorded. This number serves to uniquely identify a web browser on a specific computer and not to identify a person; personal data is not stored.

Data processing: We have concluded a data processing agreement with Google.

The legal basis of the processing is your consent in accordance with Art. 6 para. 1 lit. a GDPR. If you do not want data to be collected and processed via Google Dynamic Remarketing, you can refuse your consent or revoke it at any time with effect for the future.

In addition, you can deactivate the use of cookies by Google by following the link below and installing the plugin provided there: http://www.google.com/settings/ads/plugin.

More information on Google Ads (formerly AdWords) and Google's privacy statement can be found at: http://www.google.com/privacy/ads.

Campaign Manager (formerly DoubleClick by Google)

This website also uses the online marketing tool Campaign Manager from Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Given your consent, the Campaign Manager places cookies to serve advertisements that are relevant to users, to improve campaign performance reports, or to prevent a user from seeing the same advertisements more than once. Via a cookie ID, Google records which advertisements are displayed in which browser and can thus prevent them from being displayed more than once.

In addition, Campaign Manager can use cookie IDs to record so-called conversions that are related to ad requests. This is the case, for example, when a user views a Campaign Manager advertisement and later visits the advertiser's website with the same browser and makes a purchase. According to Google, Campaign Manager cookies do not contain any personal information.

Due to the marketing tools used, your browser automatically establishes a direct connection with the Google server. We have no influence on the scope 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 the Campaign Manager, Google receives the information that you have called up the corresponding 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 are not logged in, it is possible that the provider will find out and store your IP address.

Furthermore, the Campaign Manager (DoubleClick Floodlight) cookies used allow us to understand whether you complete certain actions on our website after you have viewed or clicked through ("Conversion Tracking") one of our display/video advertisements served on Google or another platform via the Campaign Manager. Campaign Manager uses this cookie to understand the content with which you have engaged on our websites so that we may subsequently deliver some targeted advertising to you.

For more information on Campaign Manager, please visit: https://marketingplatform.google.com/about/enterprise/
and on Google data protection in general at: https://www.google.de/intl/de/policies/privacy.
Alternatively, you can visit the Network Advertising Initiative (NAI) website at: http://www.networkadvertising.org.

We would like to point out that this cookie has a storage period of 30 days.

The legal basis of the processing is your consent in accordance with Art. 6 para. 1 lit. a GDPR. If you do not want data to be collected and processed via Campaign Manager, you can refuse your consent or revoke it at any time with effect for the future.

Objection to the processing of personal data: You can prevent participation in this tracking process in various ways:

a) by setting your browser software accordingly: the suppression of third-party cookies means that you will not receive any third-party advertisements;

b) by disabling cookies for Conversion Tracking by setting your browser to block cookies from the domain http://ww.googleadservices.com, https://www.google.de/settings/ads, whereby this setting will be deleted when you delete your cookies;

c) by deactivating the personalized advertisements of the providers that are part of the self-regulatory campaign "About Ads" via the link http://www.aboutads.info/choices, whereby this setting will be deleted when you delete your cookies;

d) by permanently deactivating it in your Firefox, Internet Explorer or Google Chrome browsers under the link http://www.google.com/settings/ads/plugin. We would like to point out that in this case you may not be able to fully utilize all the functions of this website to their full extent.

In addition, you can prevent Google from collecting the data generated by cookies about your use of the websites and the processing of this data through Google by downloading and installing the browser plugin available at https://support.google.com/adsense/answer/142293?hl=de under "Ad Settings", "Extension for Campaign Manager Deactivation".

Heap Analytics

On selected pages of our website, we use Heap Analytics, a service of Heap Analytics Inc., 116 Natoma St., San Francisco, CA 94105, USA ("Heap Analytics"), in order to receive daily information about the usage behavior on the pages of our website. Heap Analytics uses cookies that are stored on the terminal device (e.g., PC) used by you when you visit our website. The anonymized information generated by the cookies about the user behavior on our website is transferred to a server of Heap Analytics in the USA and stored there. The IP address provided by Heap Analytics from your browser will not be merged with other data from Heap Analytics.

You can prevent cookies from being saved by setting your browser software accordingly. However, we would like to point out that in this case you may not be able to fully utilize all the functions of this website. The privacy statement of Heap Analytics can be found here: www.heapanalytics.com/privacy.

Optimizely

Optimizely by Optimizely Inc. (631 Howard Street, Suite 100 San Francisco, CA 94105) is a web analytics service that is used for A/B and multivariate testing. By means of this cookie-based service, the user's browser can be identified, and the use of the provider's website can be analyzed.

Optimizely tracking can be deactivated by the user at any time for the future by following the instructions at www.optimizely.com/opt_out.

Bing Ads Conversion Tracking

This website also uses Conversion Tracking from Microsoft (Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA). Given your consent, Microsoft Bing Ads will place a cookie on your computer if you have visited our website via a Microsoft Bing Ad. In this way, Microsoft Bing and we can learn that someone has clicked on an advertisement, been redirected to our website and arrived at a previously determined target page (conversion page). We only learn the total number of users who clicked on a Bing Ad and were then redirected to the conversion page. No personal information about the user's identity is disclosed.

The legal basis of the processing is your consent in accordance with Art. 6 para. 1 lit. a GDPR. If you do not want data to be collected and processed via Bing, you can refuse your consent or revoke it at any time with effect for the future.

For more information about data protection and the cookies used by Microsoft Bing, please visit the Microsoft website: privacy.microsoft.com/de/privacystatement.

For the use of Bing Ads Conversion Tracking, we have concluded a data processing agreement in accordance with the EU standard contractual clauses.

Xing Plugin

The "XING Share Button" of XING AG (Dammtorstraße 29-32, 20354 Hamburg, Germany; "XING") is used on this website. When you call up this website, a connection to the servers of XING is established briefly via your browser and the "XING Share Button" functions (in particular the calculation/display of the counter value) are provided.

XING does not store any personally identifiable data of the user about the visit of this offer. In particular, XING does not store any IP addresses. There is also no evaluation of usage behavior via the use of cookies in connection with the "XING Share Button".

The respective current data protection information on the "XING Share Button" and additional information can be found at the following link: www.xing.com/app/share?op=data_protection.

LinkedIn Plugin

On our website, plugins of the social network LinkedIn are integrated. These are provided by LinkedIn Corporation, 2029 Stierlin Court, Mountain View CA 94043 ("LinkedIn").

If you visit a page of our website that is provided with such a plugin, a connection to the LinkedIn servers is established and the plugin will be displayed on the website by a notification to your browser. To the server of LinkedIn is transmitted, which of our sites you have visited.

If you are logged in as a member of the LinkedIn network, LinkedIn assigns this information to your personal user account. When using the plugin functions (e.g., clicking "Like"), this information is also allocated to your personal account in the social network.

If you want to prevent such data transmission, you must log out of your LinkedIn network account before you visit our Internet site.

FullStory

On our website, we use the FullStory service provided by Fullstory Inc. (818 Marietta Street, Atlanta, GA 30318, USA). FullStory is an analysis service that records user behavior on our website. These records of visitor sessions allow us to evaluate them and then improve the website experience for visitors. FullStory stores and collects data anonymously using cookies. 

The legal basis of the processing is your consent in accordance with Art. 6 para. 1 lit. a GDPR. If you do not want data to be collected and processed via FullStory, you can refuse your consent or revoke it at any time with effect for the future. 

It is possible for the user of our website to deactivate this data processing at any time. To do so, please follow the instructions at https://www.fullstory.com/optout. For the use of Fullstory, we have concluded a data processing agreement in accordance with the EU standard contractual clauses.

Outbrain

This website uses the pixel of Outbrain UK Ltd, 5 New Bridge Street, London, EC4V 6JA, UK. This pixel is used to measure website usage and serve personalized advertisements. No personal data is collected. The data collected by the pixel includes, but is not limited to: device, pages visited on our website, browser, and anonymized IP address. 

The legal basis of the processing is your consent in accordance with Art. 6 para. 1 lit. a GDPR. 

If you do not want Outbrain to collect and process the aforementioned data, you can refuse your consent or revoke it at any time with effect for the future. For more information on the data protection of Outbrain UK Ltd., please visit the following link: https://www.outbrain.com/de/legal/privacy.

LinkedIn Insight Tag

We use the conversion tracking and analysis technology of LinkedIn Inc. on our website (2029 Stierlin Ct, Mountain View, CA 94043, USA).

The LinkedIn Insight Tag enables us, among other things, to show you personalized advertising. In addition, the tag collects data about website usage and provides us with aggregated and anonymized reports on ad activity. For this purpose, a cookie is placed on your computer or a pixel is used.

The data collected is encrypted and anonymized by LinkedIn within 7 days. They are deleted within 90 days. LinkedIn does not share any personal data with us, but only provides us with aggregated reports on ad performance and target group through this data.

The information collected is also processed on the servers of LinkedIn Inc. in the USA. For the use of LinkedIn, we have concluded a data processing agreement in accordance with the EU standard contractual clauses. 

You have the right and the possibility to prevent the collection of data by LinkedIn on our website. You can deactivate the tracking by clicking on this link. For more information on LinkedIn's data protection, please visit the following link: https://www.linkedin.com/legal/privacy-policy.

The legal basis for the processing is your consent in accordance with Art. 6 para. 1 lit. a GDPR. If you do not want the aforementioned data to be collected and processed via LinkedIn, you can refuse your consent or revoke it at any time with effect for the future.

We store your data as long as we need it for the respective purpose (campaign evaluation) or as long as you have not objected to the storage of your data or revoked your consent.The collected data are encrypted. For more information, please click here. You can find the LinkedIn privacy statement and the LinkedIn opt-out here.

HubSpot

On this website, we use the service HubSpot for various purposes. HubSpot is a software company from the USA with a branch in Ireland. Contact: HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, Phone: +353 1 5187500.

Hubspot is an integrated software solution that we use to cover various aspects of our online marketing. This information is stored on servers of our software partner HubSpot. It can be used by us to get in contact with visitors of our website and to determine which services offered by our company are of any interest to them. All information we collect is subject to this privacy statement. We use all collected information exclusively to optimize our marketing activities.

The legal basis for the processing is your consent in accordance with Art. 6 para. 1 lit. a GDPR. If you do not want the aforementioned data to be collected and processed via Hubspot, you can refuse your consent or revoke it at any time with effect for the future. 

The personal data will be kept for as long as they are necessary to fulfill the purpose of the processing. The data will be deleted as soon as they are no longer necessary to achieve the purpose.

10. Use of content delivery networks

Your data are stored on the system of Amazon Web Services (AWS) LLC, P.O. Box 81226, Seattle, WA 98108-1226, in the AWS availability zone "Ireland (eu-west-1)". Amazon assures not to transfer the data outside the availability zone (aws.amazon.com/de/agreement/, see §3.2). AWS LLC, according to its own information, complies with the data protection standard applicable in the European Union (aws.amazon.com/de/privacy/ and aws.amazon.com/de/compliance/eu-data-protection/). Data retention of all personal data within the European Union is guaranteed by AWS LLC. Additional information can be found here: https://aws.amazon.com/de/blogs/security/customer-update-aws-and-the-eu-us-privacy-shield/. For more information on AWS Compliance, please visit: aws.amazon.com/de/compliance/. For more information on the data centre, please visit: aws.amazon.com/de/security/.

11. Rights of the data subjects

11.1 Overview 

Where your personal data are processed, you are deemed to be a data subject as defined in the GDPR and, in addition to the right to revoke the consent you have given to us, you have the following rights vis-à-vis the controller:

- the right to information about your personal data stored by us (Art. 15 GDPR), in particular you can request information about the processing purposes, the category of personal data, the categories of recipients to whom your data have been or will be disclosed, the planned storage period, the origin of your data if it has not been collected directly from you,
- the right to rectification of inaccurate personal data or completion of correct data (Art. 16 GDPR),
- the right to erasure of your personal data stored by us (Art. 17 GDPR), insofar as no legal or contractual retention periods or other legal obligations or rights to further storage are to be observed by us,
- the right to restriction of the processing of your personal data (Art. 18 GDPR) if you dispute the accuracy of the data, if the processing is unlawful but you oppose its erasure, if we no longer need the data but you require it for the establishment, exercise, or defense of legal claims, or if you have objected to the processing in accordance with Art. 21 GDPR,
- the right to data portability according to Art. 20 GDPR, i.e., the right to have selected data stored by us about you transferred in a commonly used, machine-readable format, or to request the transfer to another responsible party,
- the right to lodge a complaint with a supervisory authority. Generally, you can turn to the supervisory authority of your usual place of residence or workplace or our company headquarters for this purpose.

11.2 Right to object

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Art. 6 para. 1 lit. e or f of the GDPR; this also includes profiling based on those provisions. The controller shall no longer process the personal data concerning you unless the controller demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of the establishment, exercise, or defense of legal claims.

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

If you object to the processing for direct marketing purposes, the personal data concerning you will no longer be processed for these purposes.In the context of the use of information society services ­– and notwithstanding Directive 2002/58/EC – you may exercise your right to object by automated means using technical specifications.

11.3 Right to revoke the data protection declaration of consent

You have the right to revoke your data protection declaration of consent at any time. Revocation of the consent will not affect the legality of any processing that took place on the basis of the consent before the revocation.

11.4 Right to lodge a complaint with a supervisory authority

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

The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint, including the possibility of a judicial remedy pursuant to Art. 78 GDPR.

12. No obligation to provide us with your personal data

There is no obligation to provide us with your personal data. However, we may need your data to perform a contract, e.g., if you wish to purchase one or more products on our website. If you do not provide us with the personal data required for this and requested by us, about which you are informed in the context of this privacy statement, we may not be able to enter into a contract with you or fulfill a contract already concluded.

If you also prevent us from receiving data that is required to use our website, e.g., through technical measures, it is possible that you may not be able to fully use our website or not be able to use it at all.

13. Up-to-dateness and documentation of the privacy statement

It may become necessary to amend this privacy statement as a result of the further development of our website or the implementation of new technologies. We reserve the right to change the privacy statement at any time with effect for the future. We recommend that you review the current privacy statement from time to time and save or print it.

14. Scope of the privacy statement

This privacy statement applies to all pages of www.comtravo.com that are located on our server. It does not extend to any linked websites or websites of third parties.