General information

The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy.

Data recording on this website

• Who is the responsible party for the recording of data on this website (i.e., the “controller”)?

  The data on this website is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Policy.

• How do we record your data?

  We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form. Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website.

• What are the purposes we use your data for?

  A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns. If contracts can be concluded or initiated via the website, the transmitted data will also be processed for contract offers, orders or other order enquiries.

• What rights do you have as far as your information is concerned?

  You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency.
  Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues.

• Analysis tools and tools provided by third parties

  There is a possibility that your browsing patterns will be statistically analyzed when your visit this website. Such analyses are performed primarily with what we refer to as analysis programs.
  For detailed information about these analysis programs please consult our Data Protection Declaration below

Cloudflare

We use the “Cloudflare” service provided by Cloudflare Inc., 101 Townsend St., San Francisco, CA 94107, USA. (hereinafter referred to as “Cloudflare”). Cloudflare offers a content delivery network with DNS that is available worldwide. As a result, the information transfer that occurs between your browser and our website is technically routed via Cloudflare’s network. This enables Cloudflare to analyze data transactions between your browser and our website and to work as a filter between our servers and potentially malicious data traffic from the Internet.
In this context, Cloudflare may also use cookies or other technologies deployed to recognize Internet users, which shall, however, only be used for the herein described purpose.

The use of Cloudflare is based on our legitimate interest in a provision of our website offerings that is as error free and secure as possible (Art. 6(1)(f) GDPR).

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details and further information on security and data protection at Cloudflare can be found here:
https://www.cloudflare.com/privacypolicy/.

The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the
following link:
https://www.dataprivacyframework.gov/participant/5666.

Data protection

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration. Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected. We herewith advise you that the transmission of data via the Internet (i.e., through e-mail communications) may be prone to security gaps. It is not possible to completely protect data against third-party access.

Information about the responsible party (referred to as the 'controller' in the GDPR)

The data processing controller on this website is: Memoryto OÜ, Karamelli tn 2 // Pärnu mnt 139b, 11317 Tallinn, Estonia. Phone: +372 55662254, Mobile: +49 152 1847 8196, E-mail: [email protected]. The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, e-mail addresses, etc.).

Storage duration

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply.

General information on the legal basis for the data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) DSGVO. The consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR.

Designation of a data protection officer

We have appointed a data protection officer: Memoryto OÜ, Karamelli tn 2 // Pärnu mnt 139b, 11317 Tallinn, Estonia. Phone: +372 55662254, Mobile: +49 152 1847 8196, E-mail: [email protected].

Recipients of personal data

In the scope of our business activities, we cooperate with various external parties. We only disclose personal data to external parties if required for contract fulfillment, legal obligations, or other legitimate interests as per Art. 6 (1)(f) GDPR. Processors and joint controllers are bound by agreements to ensure compliance.

Revocation of your consent to the processing of data

You can revoke any consent you have already given us at any time. This shall not affect the lawfulness of data processing before the revocation.

Right to object to the collection of data in special cases; right to object to direct advertising (Art. 21 GDPR)

You have the right to object to the processing of your personal data under Art. 6(1)(e) or (f) GDPR. If your personal data is being processed for direct advertising, you have the right to object at any time.

Right to log a complaint with the competent supervisory agency

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, particularly in their place of domicile, work, or alleged violation.

Right to data portability

You have the right to have data processed automatically on the basis of your consent or in fulfillment of a contract handed over to you or a third party in a machine-readable format.

Right to demand processing restrictions

You have the right to demand the restriction of processing in specific cases, such as disputing the correctness of data or unlawful processing.

SSL and/or TLS encryption

This website uses SSL or TLS encryption to protect confidential content, such as purchase orders or inquiries. Encrypted connections are indicated by 'https://' in the browser's address line.

Cookies

Our websites and pages use what the industry refers to as 'cookies.' Cookies are small data packages that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser. Cookies can be issued by us (first-party cookies) or by third-party companies (third-party cookies). Third-party cookies enable the integration of certain services of third-party companies into websites (e.g., cookies for handling payment services). Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of these cookies (e.g., the shopping cart function or the display of videos). Other cookies may be used to analyze user behavior or for promotional purposes. Cookies, which are required for the performance of electronic communication transactions, for the provision of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error-free and optimized provision of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies has been requested, the processing occurs exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TDDDG); this consent may be revoked at any time. You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete-function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited. Which cookies and services are used on this website can be found in this privacy policy.

Consent with Cookieyes

To protect user privacy according to Art. 6(1)(c) GDPR we need to collect consent to set cookies from our website users. For that purpose we use the consent platform of CookieYes Limited of 3 Warren Yard Warren Park, Wolverton Mill, Milton Keynes, MK12 5NW, United Kingdom, website: https://www.cookieyes.com/ (hereafter referred to as 'Cookieyes'). Cookieyes identifies all cookies and scripts on our website which are subject to cookie consent. It categorizes the cookies and makes them available as a cookie audit table to website users so they may accept or deny usage of cookies. Cookieyes also automatically blocks certain third party cookies until a user gives consent. Third party cookies are stored under a different domain (URL) than a user is currently visiting.

Consent with Usercentrics

This website uses the consent technology of Usercentrics to obtain your consent to the storage of certain cookies on your device or for the use of specific technologies, and to document the former in a data protection compliant manner. The party offering this technology is Usercentrics GmbH, Sendlinger Straße 7, 80331 München, Germany, website: https://usercentrics.com/ (hereinafter referred to as 'Usercentrics').
Whenever you visit our website, the following personal data will be transferred to Usercentrics:

• Your declaration(s) of consent or your revocation of your declaration(s) of consent,
• Your IP address,
• Information about your browser,
• Information about your device,
• The date and time you visited our website,
• Geolocation.

Server log files

The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises: The type and version of browser used, The used operating system, Referrer URL, The hostname of the accessing computer, The time of the server inquiry, The IP address. This data is not merged with other data sources. This data is recorded on the basis of Art. 6(1)(f) GDPR. The operator of the website has a legitimate interest in the technically error-free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded.

Contact form

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent. The processing of these data is based on Art. 6(1)(b) GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6(1)(f) GDPR) or on your agreement (Art. 6(1)(a) GDPR) if this has been requested; the consent can be revoked at any time. The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions, in particular retention periods.

Request by email, telephone, or fax

If you contact us by e-mail, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent. These data are processed on the basis of Art. 6(1)(b) GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6(1)(f) GDPR) or on the basis of your consent (Art. 6(1)(a) GDPR) if it has been obtained; the consent can be revoked at any time. The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions - in particular statutory retention periods - remain unaffected.

Registration on this website

You have the option to register on this website to be able to use additional website functions. We shall use the data you enter only for the purpose of using the respective offer or service you have registered for. The required information we request at the time of registration must be entered in full. Otherwise, we shall reject the registration. To notify you of any important changes to the scope of our portfolio or in the event of technical modifications, we shall use the e-mail address provided during the registration process. We shall process the data entered during the registration process on the basis of your consent (Art. 6(1)(a) GDPR). The data recorded during the registration process shall be stored by us as long as you are registered on this website. Subsequently, such data shall be deleted. This shall be without prejudice to mandatory statutory retention obligations.

Registration with Google

Instead of registering directly on this website, you can register with Google. The provider of this service is Google Ireland Limited ('Google'), Gordon House, Barrow Street, Dublin 4, Ireland. To register with Google, you must only enter your Google name and password. Google will identify you and confirm your identity to our website. When you sign in with Google, we may be able to use certain information in your account to complete your profile with us. You decide whether you want this information to be used and if so, which information it is, within the framework of your Google security settings, which you can find here: https://myaccount.google.com/security and https://myaccount.google.com/permissions. The data processing associated with Google’s registration is based on our legitimate interest in making the registration process as simple as possible for our users (Art. 6(1)(f) GDPR). Since the use of the registration function is voluntary and the users themselves can decide on the respective access options, no conflicting predominant rights of the data subjects are apparent. The company is certified in accordance with the 'EU-US Data Privacy Framework' (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.

Google Tag Manager

We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create any user profiles, does not store cookies, and does not carry out any independent analyses. It only manages and runs the tools integrated via it. However, the Google Tag Manager does collect your IP address, which may also be transferred to Google’s parent company in the United States. The Google Tag Manager is used on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the quick and uncomplicated integration and administration of various tools on his website. If appropriate consent has been obtained, the processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25 (1) TDDDG, insofar the consent includes the storage of cookies or the access to information in the user’s end device (e.g., device fingerprinting) within the meaning of the TDDDG. This consent can be revoked at any time. The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.

Google Analytics

This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system, and the user’s origin. This data is assigned to the respective end device of the user. An assignment to a user-ID does not take place. Furthermore, Google Analytics allows us to record your mouse and scroll movements and clicks, among other things. Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing user behavior patterns (e.g., cookies or device fingerprinting). The website use information recorded by Google is, as a rule, transferred to a Google server in the United States, where it is stored. The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your consent at any time. Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/. The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.

IP anonymization

Google Analytics IP anonymization is active. As a result, your IP address will be abbreviated by Google within the member states of the European Union or in other states that have ratified the Convention on the European Economic Area prior to its transmission to the United States. The full IP address will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator of this website, Google shall use this information to analyze your use of this website to generate reports on website activities and to render other services to the operator of this website that are related to the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.

Browser plug-in

You can prevent the recording and processing of your data by Google by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en. For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.

Contract data processing

We have executed a contract data processing agreement with Google and are implementing the stringent provisions of the Estonian data protection agencies to the fullest when using Google Analytics.

Google AdSense (not personalized)

This website uses Google AdSense, an ad embedding service provided by Google Ireland Limited ("Google"), Gordon House, Barrow Street, Dublin 4, Ireland. We use Google AdSense in the "non-personalized" mode. Contrary to the personalized mode, the ads are not based on your previous user patterns and the service does not generate a user profile for you. Instead, the service uses so-called "context information" to choose the ads that are posted for you to view. The selected ads are thus based e.g., on your location, the content of the website you are visiting at the time, or the search terms you are using. To learn more about the distinct differences between personalized targeting and targeting that has not been personalized by Google AdSense, please click on the following link: https://support.google.com/adsense/answer/9007336. Please keep in mind that if Google Adsense is used in the non-personalized mode, it is possible that cookies are stored or comparable recognition technologies (e.g., device fingerprinting) are used. The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your consent at any time. Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/. You have the option to autonomously adjust the advertising settings in your user account. To do so, please click on the link provided below and log in: https://adssettings.google.com/authenticated. For more information about Google’s advertising technologies, please click here: https://policies.google.com/technologies/ads and https://www.google.de/intl/de/policies/privacy/. The company is certified in accordance with the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the US, which is intended to ensure compliance with European data protection standards for data processing in the US. Every company certified under the DPF is obliged to comply with these data protection standards. For more information, please contact the provider under the following link: https://www.dataprivacyframework.gov/participant/5780.

Smartlook

We use the Smartlook analysis software from Smartsupp.com s.r.o., Šumavská 524/31, Veveří, 602 00 Brno, Czech Republic, EU, as part of our legitimate interest in a technically flawless online offering and its economically efficient design and optimization in accordance with Art. 6 Paragraph 1 Letter f of GDPR. This tool records movements on the observed websites in so-called heat maps. This allows us to anonymously identify where visitors click and how far they scroll. This enables us to make our website better and more customer-friendly. The protection of your personal data is very important to us when using this tool. All data is collected without us being able to assign it to specific users. We can only track how the mouse is moved, where clicked and how far scrolled. The screen size of the device, the device type, information about the browser, the country from which access was made and the preferred language are also recorded. If personal data from you or third parties is displayed on a website, Smartlook automatically hides it. We cannot therefore track them. You can prevent the use of the Smartlook tool by using a "Do Not Track header". Then no data will be collected about your visit to our website. To do this, you must set your browser accordingly. How to do it is dependent on your browser. You can find instructions for Google Chrome at: https://support.google.com/chrome/answer/2790761. You can find Smartlook's privacy policy here: https://help.smartlook.com/en/articles/3244452-privacy.

Google Fonts (local embedding)

This website uses so-called Google Fonts provided by Google to ensure the uniform use of fonts on this site. These Google fonts are locally installed so that a connection to Google’s servers will not be established in conjunction with this application. For more information on Google Fonts, please follow this link: https://developers.google.com/fonts/faq and consult Google’s Data Privacy Declaration under: https://policies.google.com/privacy?hl=en.