Privacy Policy

Duty to provide information when collecting personal data in accordance with Art. 13 GDPR

DETAILS OF THE PERSON RESPONSIBLE (THE COMPANY)

twinu GmbH i.L.
Augustenstr. 15
80333 München
info@twinu.com

DATA PROTECTION OFFICER

If you have any questions about data protection, please contact our data protection officer at privacy@twinu.com or at the postal address given above with the addition of “data protection officer”.

PROCESSING OF YOUR PERSONAL DATA – PURPOSES AND LEGAL BASES

DATA PROCESSING IN THE COMPANY

We process personal data on the basis of data protection regulations of the General Data Protection Regulation (GDPR) as well as the Federal Data Protection Act (BDSG) and, if applicable, the data protection laws of the individual federal states. The data of the following groups of people are processed by the responsible persons in the company to fulfill their tasks.In detail this means:
Customer data are used for the implementation and support of the contractual relationship or the pre-contractual relationship as well as for contact inquiries and for communication on the basis of Art. 6 Paragraph 1 Sentence 1 Letter b) GDPR and Art. 6 Paragraph 1 Sentence 1 Letter c) GDPR Personal data of our suppliers and service providers as well as their employees for the initiation and implementation of our contractual relationships on the basis of Art. 6 Para. 1 S. 1 Letter b) GDPR and Art. 6 Para. 1 S. 1 Letter c) GDPR
Employee data is stored for the establishment, implementation and termination of employment relationships (Art. 88 GDPR, Section 26 BDSG).
Applicant data is stored for the implementation of the application process and the decision on the establishment of an employment relationship (Art. 88 GDPR, § 26 BDSG). Documents from unsuccessful applicants will be deleted four months after the end of the application process. STORAGE PERIODThe personal data stored by us will be deleted in accordance with legal requirements. We delete the data as soon as they are no longer required for the processing purpose, a given consent is revoked or other permissions are no longer applicable.Data must, for example, be kept for commercial or tax law reasons or the storage of which is still necessary for the assertion, exercise or defense of legal claims, will be deleted as soon as this is no longer the case.

YOUR RIGHTS

If we process your personal data, you have the following rights as a data subject:
- a right to information about the processed data and to a copy,- a right to rectification if we process incorrect data about you,
- a right to deletion, unless there are exceptions to why we are still saving the data, for example retention obligations or limitation periods
- a right to restriction of processing,
- the right to withdraw consent to data processing at any time,
- a right to object to processing in the public or legitimate interest,
- a right to data portability,
- a right of appeal to a data protection supervisory authority if you find that we are not processing your data properly. The Bavarian State Office for Data Protection Supervision is responsible for our company. If you are in another federal state or not in Germany, you can also contact the data protection authority there.

USE OF COOKIES

So-called cookies are used on parts of this website. They are small text files which are stored on the device with which you access this website. Different categories of cookies are used:
- Essential cookies are necessary for ensuring the core functionality of our website
- Functional cookies are cookies that are used for tracking user behaviour on our website to improve the functionality of our website
- Marketing cookies are cookies we are using for serving interest-based ads
- External media cookies: These cookies serve the purpose of displaying external media (such as videos or maps)

The legal basis for the use of essential cookies is Art. 6 (1) (f) GDPR -a legitimate interest. Our legitimate interest for the usage of these cookies is providing a functioning website.The legal basis for the usage of the other cookies is Art. 6 (1) (a) GDPR — your consent. Without your consent no non-essential cookies will be set. You can withdraw your consent anytime with effect for the future by contacting us.

USE OF THIRD-PARTY PROVIDER TOOLS

In order to provide and continuously improve our services, we are using the services of the following third-party providers which may also process personal data. These third-party providers have been selected diligently and in line with the requirements of the GDPR.

GOOGLE
Unless otherwise stated in the data privacy policy, the operator of all Google services mentioned here is Google Ireland Limited,Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland.

GOOGLE MAPS
This website incorporates the API service “Google Maps” in order to be able to depict geographical information. The use of Google Maps makes it possible for Google to collect, process and use data on your use of the service.  By using Google Maps, information about the use of this website including your IP address and the (start) address entered in the route planner function can be transmitted to Google in the USA.  The map content is transmitted by Google directly to your browser and integrated by it into the website. We have no influence on the scope of the data collected by Google in this way. We also have no influence on the further processing and use of the data by Google. We have no influence and therefore cannot accept any responsibility for this. You can find further information on the processing of your data by Google at the Google data privacy information.The following data is collected and processed:
- IP addresses
- Location information
- Usage data
- Date and time of visit
- URLs
The legal basis for this data processing is your consent according to Art. 6 (1)(a) GDPR. If you do not want Google to collect, process or use data about you via our website, you can refuse your consent or withdraw it at any time with effect for the future. The data will be stored for as long as it is necessary for the purpose of the procession. The data will be deleted as soon as it is no longer needed for the processing purposes.
As part of the processing, the data may be transferred to the following recipients besides Google Ireland Limited:
- Google LLC.
- Alphabet Inc.
Data may be transferred to the USA as part of processing by Google Maps. The security of the transmission is ensured by so-called standard contractual clauses, which guarantee that the processing of personal data is subject to a security level that corresponds to that of the GDPR. If the standard contractual clauses are not sufficient to ensure an adequate level of security, we will obtain your consent in accordance with Art. 49 (1)(a) GDPR prior to the data processing.

GOOGLE TAG MANAGER
This website uses the service “Google Tag Manager”. The tag manager is a tool for managing so-called tags that are used during tracking in online marketing. In doing so, the tag manager does not process any personal data, since it merely serves to manage other services – e.g., Google Analytics, etc. You can find further information on the tag manager at: https://www.google.com/intl/de/tagmanager/use-policy.html

GOOGLE ANALYTICS
This website uses the service “Google Analytics”. The operator of this service is the company Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. Google Analytics is a web analysis service, and, by placement of cookies and the information acquired by this, it enables us to make inferences about user behavior on our website.  The information generated by the cookies is sent to a Google server in the USA and stored there. Our website uses the service Google Analytics on an exclusively pseudonymous basis. Your IP address is only recorded in abbreviated form and is hence anonymized.
The following data is collected and processed:
- IP-Addresses (anonymized)
- Usage data- Click path
- App updates
- Browser information
- Device information
- JavaScript support
- Pages visited
- Referrer URL
- Downloads
- Flash-version
- Location information
- Purchase activity
- Widget interactions
- Date and time of visit
The legal basis of the processing is your consent according to Art. 6 (1)(a) GDPR. If you do not want Google Analytics to collect and process the aforementioned data, you can refuse your consent or withdraw it at any time with effect for the future. The data will be stored for as long as it is necessary for the purpose of the procession. The data will be deleted as soon as it is no longer needed for the processing purposes.
As part of the processing, the data may be transferred to the following recipients besides Google Ireland Limited:
- Google LLC.
- Alphabet Inc.
Data may be transferred to the USA as part of processing by Google Analytics. The security of the transmission is ensured by so-called standard contractual clauses, which guarantee that the processing of personal data is subject to a security level that corresponds to that of the GDPR. If the standard contractual clauses are not sufficient to ensure an adequate level of security, we will obtain your consent in accordance with Art. 49 (1)(a) GDPR prior to the data processing.

GOOGLE AUDIENCES / REMARKETING
This website uses the service “Google Audiences/Remarketing”. The operator of this service is the company Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. The purpose of this service is to display advertising to users based on their interests. This requires conducting an analysis of website use, which is carried out using cookies. In this process, the cookies store anonymized or pseudonymized data regarding the use of the website.  If you visit additional websites that also use these services, then you will be shown advertising that matches your previous interests. You can find more information at https://www.google.com/privacy/ads/The following data is collected and processed:
- Pages visited
- IP Addresses
- Duration of visit
- Other data on use of websites
- Content user is interested in
The legal basis of the processing is your consent according to Art. 6 (1)(a) GDPR. If you do not want Google Audiences to collect and process the aforementioned data, you can refuse your consent or withdraw it at any time with effect for the future.The data will be stored for as long as it is necessary for the purpose of the procession. The data will be deleted as soon as it is no longer needed for the processing purposes.
As part of the processing, the data may be transferred to the following recipients besides Google Ireland Limited:
- Google LLC.
- Alphabet Inc.
Data may be transferred to the USA as part of processing by Google Audiences. The security of the transmission is ensured by so-called standard contractual clauses, which guarantee that the processing of personal data is subject to a security level that corresponds to that of the GDPR. If the standard contractual clauses are not sufficient to ensure an adequate level of security, we will obtain your consent in accordance with Art. 49 (1)(a) GDPR prior to the data processing.

GOOGLE ADS (formerly GoogleAdwords) and Google Ads Conversion Tracking
This website uses the service “Google AdWords”. The operator of this service is the company Google Ireland Limited, Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. The purpose of this service is so-called conversion tracking, i.e., we can detect what happened after you clicked on our advertisements. Cookies are placed for this purpose, but they are only valid for a limited time.
The following data is collected and processed:
- Cookie-ID
- Visited Pages
- IP Addresses
- Duration of visit
- Usage data
- Content user is interested in
- Clicked Ads
- Web requests
- Cookie information
- Referrer URL
- Browser language
- Browser type
The legal basis of the processing is your consent according to Art. 6 (1)(a) GDPR. If you do not want Google Ads to collect and process the aforementioned data, you can refuse your consent or withdraw it at any time with effect for the future.The data will be stored for as long as it is necessary for the purpose of the procession. The data will be deleted as soon as it is no longer needed for the processing purposes.
As part of the processing, the data may be transferred to the following recipients besides Google Ireland Limited:
- Google LLC.
- Alphabet Inc.
Data may be transferred to the USA as part of processing by Google Ads. The security of the transmission is ensured by so-called standard contractual clauses, which guarantee that the processing of personal data is subject to a security level that corresponds to that of the GDPR. If the standard contractual clauses are not sufficient to ensure an adequate level of security, we will obtain your consent in accordance with Art. 49 (1)(a) GDPR prior to the data processing.

YOUTUBE
This website uses the service “YouTube” to insert videos into the page. The operator of the software necessary for this purpose is the company Google Ireland Limited Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. The integration of YouTube content is carried out in “extended privacy mode”. This ensures that YouTube does not initially store cookies on your device. As a result, YouTube no longer stores any information about visitors until you watch the video.When you click on the video, your IP address is sent to YouTube, which tells YouTube that you have watched the video. If you are logged in to YouTube, this information is also associated with your account. This can be prevented by logging out of YouTube before viewing the video.Accordingly, the following data can be collected and processed:
- IP Addresses
- Referrer URL
- Device Information
- Watched videos
The legal basis of the processing is your consent according to Art. 6 (1)(a) GDPR. If you do not want YouTube to collect and process the aforementioned data, you can refuse your consent or withdraw it at any time with effect for the future.The data will be stored for as long as it is necessary for the purpose of the procession. The data will be deleted as soon as it is no longer needed for the processing purposes.
As part of the processing, the data may be transferred to the following recipients besides Google Ireland Limited:
- Google LLC.
- Alphabet Inc.
Data may be transferred to the USA as part of processing by YouTube. The security of the transmission is ensured by so-called standard contractual clauses, which guarantee that the processing of personal data is subject to a security level that corresponds to that of the GDPR. If the standard contractual clauses are not sufficient to ensure an adequate level of security, we will obtain your consent in accordance with Art. 49 (1)(a) GDPR prior to the data processing.

GOOGLE WEB FONTS
On this website the service Google Web Fonts is used. The service is provided by Google Ireland Limited Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland.  Google Web Fonts enables us to load and display external fonts, so-called Google Fonts, on our website. Google Web Fonts is locally integrated on our website. This means that the fonts are not loaded from Google servers. In the context of processing via Google Web Fonts, the following personal data is collected and processed:
- IP address
The legal basis for this processing is Art. 6 (1)(f) GDPR — a legitimate interest. Our legitimate interest in the processing is to present the website in an attractive and user-friendly manner. Local hosting ensures that no data is transferred to Google, and no data transfer takes place. Personal data is stored for as long as it is necessary to fulfill the purpose of processing. The data is deleted as soon as it is no longer required for the purpose.

TYPEFORM
On this website the service Typeform is used. Typeform is operated by TYPEFORM SL, C/Bac de Roda, 163, 08018 Barcelona, Spain. Typeform is a service that we use to display online surveys on our website and to run promotional lotteries.In this context, the following data may be collected and processed:- IP address- e-mail address- Visit duration- Date and time of the visit- If applicable, other data collected in the course of the survey/promotional lottery (in particular user names) The legal basis of the processing is your consent according to Art. 6 (1)(a) GDPR. If you do not want the above data to be collected and processed by Typeform, you can refuse your consent or revoke it at any time with effect for the future.The personal data will be stored for as long as it is necessary to fulfill the purpose of processing. The data will be deleted as soon as they are no longer required for the purpose.Within the scope of processing via Typeform, data may be transferred to the USA. The security of the transmission is regularly ensured by so-called standard contract clauses, which guarantee that the processing of personal data is subject to a security level that corresponds to that of the DSGVO.

MAILCHIMP / NEWSLETTER DATA
If you would like to receive the newsletter offered on the website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter. Further data is not collected or only on a voluntary basis. For the handling of the newsletter, we use newsletter service providers, which are described below.This website uses the services of MailChimp to send out its newsletters. The provider is the Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.Among other things, MailChimp is a service that can be deployed to organize and analyze the sending of newsletters. Whenever you enter data for the purpose of subscribing to a newsletter (e.g. your e-mail address), the information is stored on MailChimp servers in the United States.With the assistance of the MailChimp tool, we can analyze the performance of our newsletter campaigns. If you open an e-mail that has been sent through the MailChimp tool, a file that has been integrated into the e-mail (a so-called web-beacon) connects to MailChimp’s servers in the United States. As a result, it can be determined whether a newsletter message has been opened and which links the recipient possibly clicked on. Technical information is also recorded at that time (e.g. the time of access, the IP address, type of browser and operating system). This information cannot be allocated to the respective newsletter recipient. Their sole purpose is the performance of statistical analyses of newsletter campaigns. The results of such analyses can be used to tailor future newsletters to the interests of their recipients more effectively.If you do not want to permit an analysis by MailChimp, you must unsubscribe from the newsletter. We provide a link for you to do this in every newsletter message.
The data is processed based on your consent (Art. 6(1)(a) GDPR). You may revoke any consent you have given at any time by unsubscribing from the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place prior to your revocation.The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter or the newsletter service provider and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://mailchimp.com/eu-us-data-transfer-statement/ and https://mailchimp.com/legal/data-processing-addendum/#Annex_C_-_Standard_Contractual_Clauses.After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6(1)(f) GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.For more details, please consult the Data Privacy Policies of MailChimp at: https://mailchimp.com/legal/terms/.


AMAZON ALEXA SKILL

If you use our Alexa Skills, your personal data will also be passed on to Amazon via Alexa-enabled devices. Twinu GmbH has no influence on any data processing by Amazon. For how Amazon handles your personal data, please visit Amazon's privacy policy at: https://www.amazon.com/gp/help/customer/display.html?nodeId=GX7NJQ4ZB8MHFRNJ and https://www.amazon.de/-/en/gp/help/customer/display.html?nodeId=GX7NJQ4ZB8MHFRNJ.

You can find more information specifically about Alexa, Echo devices and your privacy when using Amazon Skills here: https://www.amazon.de/gp/help/customer/display.html/?nodeId=GA7E98TJFEJLYSFR

There you will also find more information on how to delete your voice recordings. However, Twinu GmbH has no access to this.

Types of data processed:
- Storage of email address and search terms.
- Storage of personal usage logs.

Categories of data subjects:
Users of the Alexa skill (in the following we also refer to the data subjects as "users").

Purpose of processing:
Twinu GmbH does not have access to data in your Amazon account, especially your Amazon registration data. Twinu GmbH also does not have access to voice recordings. In order to enable the functions of the skill and to improve the user experience, the individual user identification ("UserID") assigned by Amazon and the text content of your request are transmitted. This is done and to enable the functions of the Alexa skill.
The storage of the "UserID", the storage of search terms and logs on the use of the Alexa skill are also stored and evaluated for statistical evaluation and based on this to improve our offer and make it more interesting for you as a user. We process this data on the basis of our legitimate interest in a needs-based design of our Alexa skills and because your interests in the exclusion of processing do not prevail (Art. 6 Para. 1 lit. f GDPR). The "UserID" is anonymous and does not make you recognizable as a person, not even your Amazon account. It is an identifier generated by Amazon. Twinu GmbH cannot use the "UserID" to draw any conclusions about the identity of the user.

Transfer to third parties
We transmit the responses generated by our Alexa Skills back to Amazon so that the response can be output via your Alexa device.