1. Responsible Body & Data Protection Officer

freenet digital GmbH, Karl-Liebknecht-Straße 32, 10178 Berlin, Germany (hereinafter „freenet digital“), represented by its managing directors, is a freenet Group company. The group data protection officer of freenet group who also serves as data protection officer of freenet digital GmbH can be contacted at Hollerstraße 126, 24782 Büdelsdorf, Germany or via email to datenschutz@freenet.ag

freenet digital processes data according to German and EU privacy laws. “DSGVO” is an abbreviation for the German version of the EU General Data Protection Regulation (GDPR). “TMG” is the abbreviation for the German Telemedia Act. “BDSG” is the abbreviation for the German Federal Data Protection Act. “TKG” means the German Telecommunications Act.

Personal data means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

2. Data Processing: Purpose, Legal Basis, Recipients

We process personal data only to enter into, and to fulfill, agreements with our users and clients (based on Art. 6 sec. 1b DSGVO, 11-15a TMG), or for other purposes to which users have expressly consented (Art. 6 sec. 1a, 7, 8 DSGVO; § 13 sec. 2 TMG). Furthermore, the processing of data can be based on justified interests of freenet digital or a third party if and to the extent such interests outweigh the civil rights and the fundamental freedom rights of the user (Art. 6 sec. 1 f, 31 BDSG).

We only work with third party processors of personal data that ensure the compliance with applicable privacy laws. Any such cooperation is based on a separate data processing agreement (Art. 28 DSGVO). All data processing takes place within the European Economic Area, or in such other countries that have a level of data protection which the European Commission has officially approved as secure (Art. 45 DSGVO), or with companies that provide privacy guarantees based on the EU standard contractual clauses pertaining to data protection (Art. 46, 93 sec. 2 DSGVO), binding internal data protection rules (Art. 47 DSGVO), or approved codes of conduct (Art. 40 DSGVO).

2.1 Logfiles

For each website visit we automatically process and store some or all data below related to the visitor in logfiles (Art. 6 Abs. 1f DSGVO, § 15 Abs. 1 TMG):

(1) Type and version number of browser used

(2) Operating system of user device

(3) Internet service provider

(4) Date and time of user access

(5) Website from where user accessed our website (referrer)

(6) Websites accessed by user through our website

We process this data to support the distribution and display of our website contents, to ensure the operability of our systems of information technology and to optimize our website. Logfile data is always stored separately from other user data.

2.2 Registration; User Accounts

If users opt to provide personal information as part of their registration, to participate in surveys and sweepstakes, to subscribe to a newsletter and/or to sign up to services, their data will be transmitted to freenet digital within the provided entry mask (Art. 6 sec. 1a, b, Art. 88 DSGVO §§ 13 sec. 2, 14 TMG, § 26 BDSG). This data may include full name and address of user and company represented by user, telephone numbers, email addresses and other as provided by the user.

When registering, user IP address as well as date and time of the registration are stored to prevent the misuse of the Vene.io service, and for freenet digital to provide their contents and services. This data will not be passed on to third parties unless freenet digital is under a statutory obligation to pass on. Users will be informed about the purpose of the data entry before completing the entry.

User Account. User accounts are password-protected. Users are responsible for keeping their password confidential. freenet digital recommends to not share passwords with anyone. freenet digital never requests the password in unexpected phone calls. Users can access and modify the data in their user account at any time by logging in with their user name and their password.

2.3 How to Contact freenet digital

We provide an entry mask through which users can contact freenet digital. Alternatively, you can contact us through the contact email address provided on the Vene.io website. All information including personal information provided through these channels will automatically be stored (Art. 6 sec. 1 b, f DSGVO, § 14 TMG) exclusively to manage the user request.

2.4 Cookies

Cookies are small text files that the browser stores on the user device (Art. 6 sec. 1f DSGVO, § 15 Abs. 3 TMG). Cookies are transmitted from the user device to the website accessed by user and so enable the recognition of a user device by the website. We use cookies to optimize the usability of our website. Users can disable cookies in their web browser. Existing cookies can be deleted. More information about how to manage and delete cookies can be found here:

http://www.aboutcookies.org.uk/managing-cookies

2.5 Social Media Plugins and Other Integrated Third-Party Services; Links to Third-Party Websites

Our websites may include links to, and interactive plugins of, third-party social network providers and third-party providers of other services (Art. 6 sec. 1a, f DSGVO, §§ 13 sec. 2, 15 sec. 3 TMG).

We have no control over the contents of the third-party websites we link to and therefore, we do not assume any responsibility for these contents. These interactive plugins may collect and send to the third party your IP address, the fact that you visit our website, and they may set cookies for the operability of the plugin. The plugins are either hosted by the respective third party or by us. In all cases, the use of third party plugins is subject to the terms and conditions and the privacy policies of these third-party providers.

You can also prevent the loading of plugins by using a script blocker, e.g. NoScript: http://noscript.net/

Our websites may contain links to websites and other content of third parties. freenet digital does not have control over these websites and contents but the respective third party. Therefore, freenet digital cannot assume any responsibility for these websites and contents.

2.6 Google Analytics

We use Google Analytics, a web analytics service provided by Google Inc. (" Google "). Google Analytics uses "cookies", text files that are stored on your computer and allow an analysis of the use of the website. The information generated by the cookie about your use of this site are usually sent to a server of Google in the U.S. and stored there. In the case of activation of the IP anonymization on this Web site, the IP address of Google will be truncated within Member States of the European Union or other parties to the Agreement on the European Economic Area before. Only in exceptional cases, the full IP address is sent to a Google server in the USA and is shortened. On behalf of the operator of this site Google will use this information to evaluate your use of the website, compiling reports on website activity together and to provide other with website and internet related services to the site operator. Which is within the scope of Google Analytics that your browser sends IP address cannot be merged with other data held by Google. You can prevent the storage of cookies by selecting the appropriate settings on your browser, we point out, however, that in this case not all the features of this site are in full use. You can also extend the coverage of the generated by the cookie and prevent your use of the site-related data (including your IP address) to Google and the processing of these data by Google, by following the link below to download and install the available browser plug-in: http://tools.google.com/dlpage/gaoptout?hl=de

2.7 Pre-contractual and Contractual Data Processing

We process “Inventory Data” and “Usage Data” for pre-contractual and contractual purposes. “Inventory Data” means data that is required to make, define, amend and terminate the relationship to the user (§ 14 sec. 1 TMG). “Usage Data” is processed while providing the vene.io service as required to provide and bill the service (§ 15 sec. 1 TMG). When using third party providers for billing purposes, we transmit Inventory Data and traffic data (as defined in § 96 sec. 1 TKG) only to parties that have agreed to comply with all legal requirements pertaining to the principles of confidentiality of telecommunications and data protection (Art. 6 sec. 1b, f DSGVO, § 97 sec. 1 sentence 3, 4 TKG, § 15 sec. 5 TMG).

2.8 Personal ID-Documents

We may request, and make copies of, personal identification documents of users to verify information provided by the user (Art. 6 sec. 1b DSGVO, § 95 sec. 4 sentence 1, 3 TKG, § 20 Personalausweisgesetz (German ID-Card Act)).

2.9 Enforcing and Defending Against Legal Claims

We reserve the right to transmit personal data to money collecting agencies for the purpose of enforcing and defending against legal claims (Art. 6 sec. 1 b, f, sec. 4 DSGVO; § 24 sec. 1, no. 2 BDSG).

3. Data Retention Period

As a general principle, personal information will be deleted when the justified purpose of their processing has been achieved (Art. 17 sec. 1a DSGVO). Where we are obliged to retain certain data beyond the achievement of the original purpose for their processing, e.g. under applicable tax or trade laws pertaining to the archiving of documents, we will retain this data but its use for any other purpose will be restricted (Art. 18 sec. 1c DSGVO; Art. 17 Abs. 3b, e DSGVO, § 35 BDSG, § 15 Abs. 4 sentence 2 TMG).

Inventory Data and Usage Data will be deleted in accordance with § 13 sec. 4 TMG when user leaves our websites or otherwise stops using our services.

4. Marketing

From time to time, freenet digital and its authorized partners may send messages about services and products that may be interesting for the user including SMS, MMS, Push Messages, Regular Mail and Email to the user PROVIDED THAT AND ONLY TO THE EXTENT THAT user has given its consent to such marketing activities. Consents can be revoked at any time by sending an Email to our customer service or by sending a letter to freenet digital GmbH, Karl-Liebknecht-Str. 32, 10178 Berlin, Germany.

Only to the extent that the user has given his/her consent, freenet digital may use Inventory Data and Usage Data of the user for the following purposes:

• Market Research

• Product Research

• Customer Service

• Advertising of Products and Services

• Needs-oriented Design of Telemedia Services

You can revoke your consent to our use of Inventory Data and Usage Data as described above at any time over the channels though which we use to obtain user consents (e.g. Mail, Email, Fax, Online) without any costs incremental to your regular base tariffs.

5. Rights of Data Subjects

Regarding all personal information processed by freenet digital, each Data Subject is entitled to the claims of Information (Art. 15 DSGVO), Correction (Art. 16 DSGVO), Deletion (Art 17 DSGVO), Limited Processing (Art. 18 DSGVO) and Data Portability (Art. 20 DSGVO). “Data Subject” means an identified person, or identifiable natural person, i.e. a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Additionally, Data Subjects may contact the regulatory authority which is responsible for regulating freenet digital GmbH: Berliner Beauftragte für Datenschutz und Informationsfreiheit, An der Urania 4-10, 10787 Berlin, Germany.

23.05.2018 freenet digital GmbH