Circleback GmbH
Kollwitzstraße 64
10435 Berlin
E-Mail: brett@circleback.works
Registry office
Amtsgericht Charlottenburg Berlin
Company number: HRB 235815 B
Representative
acc. to German law (Art. 55 section 2 RStV):
Brett Dickey
Circleback GmbH
Kollwitzstraße 64
10435 Berlin
Disclaimer
The entire content of the website of the Circleback GmbH is protected by copyright. You may download or print out individual pages and/or parts of the Circleback GmbH website only to the extent that this is done within the scope of their intended use. Copyright notes must not be deleted or modified. Any duplication, transmission or alteration without the prior written consent of the Circleback GmbH is prohibited unless legally permissible on the basis of the few exceptions provided for by copyright law.
The Circleback GmbH makes its best efforts to ensure that the information presented is reliable and correct. However, the Circleback GmbH does not assume any liability for damage or loss directly or indirectly caused in connection with accessing or using the website or with respect to its performance or requests sent to the site, or any connection with websites owned and operated by third parties.
Clicking on links may lead you to websites outside the Circleback GmbH. The Circleback GmbH has neither checked the links or their content nor does the Circleback GmbH assume any liability with respect to technological quality or their content, including products or services offered or in any other respect.
The following data protection information refers to the use of the company website of Circleback GmbH.
Controller for the data processing in connection with the use of our website is
Circleback GmbH
Kollwitzstraße 64
10435 Berlin
Circleback GmbH is not legally required to have a dedicated data protection officer yet. If you would like to inform us about any data protection related issues, please e-mail us to dataprotection@circleback.works.
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.
Cookies are small text files that are stored locally on a visitor’s device (e.g. PC, smartphone, tablet PC) while connecting to a website. They may contain various information about the used end device and how you use the website. In case of a new connection to the Cookie-setting web server they will be transferred for the purpose of recognizing user and device settings.
GDPR is the abbreviation for the General Data Protection Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (Data Protection Directive) adopted on 14 April 2016.
3.1. IP address and log files
a) Explanation and purpose of data processing:
We process the following information for every access to our website:
The IP address and the information regarding the request of your Internet browser is technically necessary for the use of our website. Without processing this data, it is impossible to access and to display web pages. The IP address will be anonymized by shortening or erasing it when the necessity for access or use of our website ends.
The above mentioned data will be processed by us for the following purposes:
Information regarding transmitted data volume, browser type and browser version, display resolution, and the operation system used are processed to optimize the display of the content, assess the utilization of the system, and to optimize our website, if applicable, based on statistical analyses.
b) Legal basis:
Basis for the processing is Art. 6 Subsection 1 littoral f GDPR. The legitimate interest for the processing is the technical facilitation of our web presence, the optimization of the content display for the user and the future optimization of our web presence.
c) Right to object:
In case of data processing based on Art. 6 Subsection 1 littoral f GDPR you have, notwithstanding other rights, a right to object. Please refer in this regard to clause 8 below (“Rights of the data subject“).
3.2. Use of cookies by our server
a) Explanation and purpose:
Our websites use cookies set by our webserver. You will be shown a respective notice at least when you connect to our website for the first time.
The cookies used by our server serve partly as basis for the analysis of the utilization of our website with the help of analysis tools (refer in this regard to clauses 3.3. to 3.8.), to detect several connected requests of one user and to attribute these to one session. In addition, some of our websites contain a so-called session cookie. It is needed for the functionality of our website. Session cookies are deleted automatically after closing the session (i.e. the browser tab in which our website was displayed).
b) Disabling of cookies:
You can disable the storage of cookies in your browser settings. In addition, you can delete stored cookies in your browser. This may have the consequence that certain functionalities of the website can’t be used at all or that using our website is less convenient.
c) Legal basis:
Basis for this data processing is Art. 6 Subsection 1 littoral f GDPR. The legitimate interest for the processing is to enable the use of our website and its functionalities. With regard to the cookies set for analysis tools you can find specific information in clauses 3.3. to 3.8.
d) Right to object:
In case of a data processing on the basis of Art. 6 Subsection 1 littoral f GDPR you have, notwithstanding other rights, a right to object. Please refer in this regard to clause 6 below (“Rights of the data subject“).
3.3. Google Analytics (web analysis)
a) Explanation and purpose:
This website uses Google Analytics. This is a service provided by Google Ireland Limited ("Google"), a company incorporated and operated under the laws of Ireland (registration number: 368047) with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). Google Analytics uses cookies that are saved on your computer and enable us to analyze how you use our website. The information collected by the cookie contain e.g. browser type and version, operation system system used, display resolution, referrer URL (the website you visited before), anonymized IP-address of your end device, time of the request, length of your visit on specific sites, downloaded data, and more. You can find further information about the cookies used by Google here.
The information generated by the cookie regarding your usage is submitted to a Google server in the USA, where it is saved. Insofar as data is processed outside the EU/EEA and there is no level of data protection corresponding to the European standard, we have concluded EU standard contractual clauses with the service provider to establish an appropriate level of data protection. The parent company of Google Ireland, Google LLC, is based in California, USA. A transfer of data to the USA and access by US authorities to the data stored by Google cannot be ruled out. The USA is currently considered a third country from a data protection perspective. You do not have the same rights there as within the EU/EEA. You may not be entitled to any legal remedies against access by authorities.
We use Google Analytics on our website by anonymizing your IP address (so-called IP-masking). Your IP-address is anonymized by Google in the European Union or other member states of the European Economic Area Treaty by shortening your IP address.
As requested by the operator of this website, Google will then use this information to evaluate how users use our website, create reports about website activities and provide other services for the website operator related to the use of the website and Internet use. These reports help us to analyze the use of our website and to improve it on a regular basis. The statistics gathered allow us to improve our offering and design it in a way that is more attractive to you. Your IP address will not be combined with any other data collected by Google.
We chose a maximum retention period of 14 months for data connected to cookies, user IDs or advertising ID.
b) Disabling cookies:
You can disable the storage of cookies in your browser settings. You can also delete stored cookies in your browser. This may have the consequence that certain functionalities of the website can’t be used at all or that using our website is less convenient.
To prevent data (inclusive your IP address) generated by the cookie with regard to the use of our website from being gathered and processed by Google, you can install the Google browser add-on found here. As an alternative to the add-on, you can also use this link to opt out of collection. A guide to implementing the opt-out-cookie can be found here. This stores an opt-out cookie that prevents the collection of your data on our site in the future. This applies to this browser only and for this website only. If you delete all your browser cookies afterwards, you must install the opt-out cookie again.
c) More information about Google Analytics:
More information on data protection in connection with Google Analytics you can find here.
d) Legal Basis:
Basis for the processing is Art. 6 Subsection 1 littoral f GDPR. The legitimate interest for the processing is the analysis of usage data to identify and correct failures in addition to optimizing the configuration of our website.
e) Right to object:
In case of a data processing on the basis of Art. 6 Subsection 1 littoral f. f GDPR you have, notwithstanding other rights, a right to object. Please refer in this regard to clause 8 below (“Rights of the data subject“).
3.4. Google Tag Manager
We manage website tags (website code) with Google Tag Manager. It facilitates the administration and development of our website offering and shortens your website load time. The Google Tag Manager only implements website code. The Google Tag Manager does not set cookies and does not collect personally identifiable information. The tool merely integrates website code stored by us through which, if necessary, data is collected. The tool only serves to facilitate the modulation of the respective code, but does not itself access the data processed by the code. We will inform you about all integrated tags in this privacy statement. You can find more information about the Google Tag Manager and the terms of use on the pages of Google here.
3.5. Fullstory
For the purpose of designing and continuously optimizing our web pages according to our needs, based on Art. 6 Subsection 1 littoral f GDPR, we use the analysis service of Fullstory, a service of FullStory, Inc.,120 Ottley Drive NE, Suite 100, Atlanta, GA 30324, USA (“Fullstory”). Fullstory stores and collects data anonymously through cookies. The information generated by these cookies about your use of our websites include your:
Data is transferred to a Fullstory server in the USA. The recordings of these sessions make it possible to analyze and then optimize the website experience of our visitors. You can activate the opt-out link here. For more information about privacy related to Fullstory, please refer to their privacy policy.
3.6. Youtube integration
On our web pages we offer our visitors and customers rich information around Circleback and the development of our company. In addition to texts and photos, we sometimes also provide informative videos. For this we use, based on Art. 6 Subsection 1 littoral f GDPR, a service of Youtube, LLC, 901 Cherry Ave. San Bruno, CA 94066, USA (“Youtube”). For this purpose, we place a Youtube cookie when someone visits a page containing a Youtube video. Thereby, a connection to a Youtube server is established. The information generated by the cookie about your use of our web pages includes your:
This data is transferred to a Youtube server in the USA, where it is stored. The processing of this data to improve our websites by enriching and complementing our content with informative videos is considered to be our legitimate interest. You can prevent the installation of a Youtube cookie in advance by a corresponding setting of your browser software; or object to this processing by deleting cookies via your browser settings; or by changing the corresponding settings in Google’s privacy center here. Under Youtube’s privacy policy, you’ll find more information about how Google collects and uses the data and your rights and privacy opportunities.
3.7. Contact forms: Webflow integration
On our website, we inform visitors about the development of our company. If a visitor wants to contact us or wants to get notified or informed about our development or wants to provide us with information or feedback, he can choose to do so through a structured web form. For this we use, based on Art. 6 Subsection 1 littoral f GDPR, a service of Webflow, Inc., 398 11th Street, 2nd Floor, San Francisco, CA 94103.
We process only the information you choose to provide us with (e.g. name, email, postcode, URL) to answer your question and to handle your request. We are happy to delete any data you provided at any time. Please let us know by writing an email to dataprotection@circleback.works.
You can find further information about the cookies used by Webflow here.
You can find links to the following social media platforms on our website:
If you visit these websites please be aware that the controller of these websites may collect and process information that is linked to your user account and is stored and processed according to the privacy regulations of the respective controller. Please ask the respective controller of the linked website for information about the details of the data processing prior to accessing the respective websites.
There are existing contracts with the following recipients that process data on our behalf according to Art. 28 GDPR:
a) You have the right to ask for a confirmation if we process personal data concerning your person. If this is the case you have the right to request information about all personal data according to the applicable law (Art. 15 GDPR) This does not apply, if
and the provision of such information would involve a disproportionate effort and the processing for other purpose is excluded by appropriate technical and organizational measures.
b) Furthermore, you have the right to obtain rectification of inaccurate data concerning yourself and – taking into account the purposes of the processing – you have the right to have incomplete personal data completed, including by means of providing a supplementary statement (Art. 16 GDPR). In the cases listed in Art 17 subsection 1 litoral a – f GDPR, you also have the right to have your data erased, unless an exemption listed in Art. 17 subsection 3 GDPR applies. In the cases listed in Art. 18 subsection 1 GDPR you have the right to obtain restriction of processing. If Art 20 subsection 1 GDPR applies, then a right of data portability exists.
c) You have the right to fill a complaint with a supervisory authority if you are convinced that the processing of your personal data infringes the GDPR.
d) You have the right to object to the processing of your data based on a legitimate interest.
You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning yourself which is based on point (f) of Article 6 (1). The execution of your right to object may have the consequence that our entire website or certain functionalities of our website cannot be used at all or that the use of our website is less convenient.
The regulatory body responsible for Circleback GmbH is:
Landesbeauftragte für Datenschutz und Informationsfreiheit Berlin, Friedrichstraße 219, 10969 Berlin
Tel.: 030 1388 9777 (Monday to Friday from 10:00 to 13:00)
Internet: https://www.datenschutz-berlin.de/
To exercise your rights as a data subject, simply send a letter by post or email to the address indicated in Clause 1.
(Version 1.0 – Date: March 1, 2022)