Privacy policy

This Privacy Policy clarifies the nature, scope, and purpose of processing personal data (hereinafter referred to as “Data”) within our online offering and the related websites, apps, features, and content, as well as external online presence, e.g., our social media profiles (collectively referred to as “online offer”). With regard to the terminology used, e.g., “Processing” or “Responsible”, we refer to the definitions in Article 4 of the General Data Protection Regulation (GDPR). For specific information on data processing in the Productlane app, read the appropriate section at the bottom of this page.

1. Responsible

Productlane GmbH

Raphael Fleckenstein, Patrick Göler von Ravensburg

Albert-Roßhaupter-Str. 3b

81369 Munich, Germany

[email protected]

1.1 Types of Processed Data:

- Inventory data (e.g., names, addresses).

- Contact information (e.g., e-mail, phone numbers).

- Content data (e.g., text input, photographs, videos).

- Usage data (e.g., websites visited, interest in content, access times).

- Meta/communication data (e.g., device information, IP addresses).

1.2 Purpose of Processing

- Provision of the online offer, its functions, and contents.

- Answering contact requests and communicating with users.

- Safety measures.

- Reach measurement/marketing.

1.3 Used Terms

“Personal data” means any information relating to an identified or identifiable natural person (hereinafter the “data subject”); a natural person is considered as identifiable, which can be identified directly or indirectly, in particular by means of assignment to an identifier such as a name, to an identification number, to location data, to an online identifier (e.g., cookie) or to one or more special features that express the physical, physiological, genetic, mental, economic, cultural, or social identity of this natural person.

“Processing” means any process performed with or without the aid of automated procedures or any such process associated with personal data. The term goes far and includes virtually every handling of data.

“Responsible person” means the natural or legal person, public authority, body or body that decides, alone or in concert with others, on the purposes and means of processing personal data.

1.4 Major Legal Bases

In accordance with Art. 13 GDPR, we inform you about the legal basis of our data processing. Unless the legal basis in the data protection declaration is mentioned, the following applies: The legal basis for obtaining consent is Article 6 (1) lit. a and Art. 7 DSGVO, the legal basis for the processing for the performance of our services and the execution of contractual measures as well as the response to inquiries is Art. 6 (1) lit. b DSGVO, the legal basis for processing in order to fulfill our legal obligations is Art. 6 (1) lit. c DSGVO, and the legal basis for processing in order to safeguard our legitimate interests is Article 6 (1) lit. f DSGVO. In the event that vital interests of the data subject or another natural person require the processing of personal data, Art. 6 para. 1 lit. d DSGVO as legal basis.

1.5 Safety Measures

We ask you to inform yourself regularly about the content of our privacy policy. We will adjust the privacy policy as soon as the changes to the data processing we make require it. We will notify you as soon as the changes require your participation (e.g., consent) or other individual notification.

1.6 Cooperation with Contracting Entrepreneurs and Third Parties

If, in the context of our processing, we disclose data to other persons and companies (contract processors or third parties), transmit them to them, or otherwise grant access to the data, this will only be done on the basis of legal permission (e.g., if a transmission of the data to third parties, as required by payment service providers, pursuant to Art. 6 (1) (b) GDPR to fulfill the contract), you have consented to a legal obligation or based on our legitimate interests (e.g., the use of agents, web hosters, etc.).

If we commission third parties to process data on the basis of a so-called “contract processing contract”, this is done on the basis of Art. 28 GDPR.

1.7 Transmission in Third Countries

If we process data in a third country (i.e., outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using the services of third parties or disclosure or transfer of data to third parties, this will only take place if it is done to fulfil our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation, or on the basis of our legitimate interests. Subject to legal or contractual permissions, we will only process or transfer the data in a third country if the special requirements of Art. 44 ff. DSGVO are met. This means that the processing is carried out, for example, on the basis of special guarantees, such as compliance with officially recognized special contractual obligations (so-called “standard contractual clauses”).

1.8 Rights of the Affected Persons

You have the right to ask for confirmation as to whether the data in question is being processed and for information about this data as well as for further information and a copy of the data in accordance with Art. 15 GDPR.

In accordance with Art. 16 DSGVO, you have the right to demand the completion of the data concerning you or the correction of the incorrect data concerning you.

In accordance with Art. 17 GDPR, you have the right to demand that the relevant data be deleted immediately or, alternatively, to require a restriction of the processing of data in accordance with Art. 18 GDPR.

You have the right to demand that the data relating to you, which you have provided to us, be obtained in accordance with Art. 20 GDPR and request their transmission to other persons responsible.

In accordance with Art. 77 DSGVO, you have the right to file a complaint with the competent supervisory authority.

2. Revocation

You have the right to revoke the granted consent in accordance with Art. 7 para. 3 DSGVO with effect for the future.

2.1 Right to Object

You can object to the future processing of your data in accordance with Art. 21 GDPR at any time. The objection may in particular be made against processing for direct marketing purposes.

2.2 Cookies and Opposition Right in Direct Advertising

“Cookies” are small files that are stored on users’ computers. Diverse information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or “session cookies” or “transient cookies”, are cookies that are deleted after a user leaves an online service and closes his browser. In such a cookie, e.g., the contents of a shopping cart are stored in an online store or a login status. The term “permanent” or “persistent” refers to cookies that remain stored even after the browser has been closed. Thus, e.g., the login status will be saved if users visit it after several days. Likewise, in such a cookie, the interests of the users can be stored, which are used for range measurement or marketing purposes. A “third-party cookie” refers to cookies that are offered by providers other than the person who manages the online offer (otherwise, if it is only their cookies, this is called “first-party cookies”).

We can use temporary and permanent cookies and clarify this in the context of our privacy policy.

If users do not want cookies stored on their computer, they are asked to disable the option in their browser’s system settings. Saved cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional restrictions of this online offer.

A general contradiction to the use of cookies used for online marketing purposes can be found in a variety of services, especially in the case of tracking, via the US website [http://www.aboutads.info/choices/](http://www.aboutads.info/choices/) or the EU site [http://www.youronlinechoices.com/](http://www.youronlinechoices.com/) be explained. Furthermore, the storage of cookies can be achieved by switching them off in the settings of the browser. Please note that not all features of this online offer may be used.

2.3 Business-Related Processing

In addition, we process:

- Contract data (e.g., subject, term, customer category).

- Payment data (e.g., bank details, payment history).

From our customers, prospects, and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising, and market research.

2.4 Hosting

The hosting services we use are for the purpose of providing the following services: infrastructure and platform services, computing capacity, storage and database services, security, and technical maintenance services we use to operate this online service.

Here we, or our hosting provider, process inventory data, contact data, content data, contract data, usage data, meta and communication data of customers, interested parties, and visitors to this online offer on the basis of our legitimate interests in an efficient and secure provision of this online offer acc. Art. 6 para. 1 lit. f DSGVO i.V.m. Art. 28 DSGVO (conclusion of data processing contract).

2.5 Survey of Access Data and Logfiles

We, or our hosting provider, collects data on the basis of our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO on every access to the server on which this service is located (so-called server

log files). The access data includes the name of the retrieved web page, file, date and time of retrieval, the amount of data transferred, message about successful retrieval, browser type and version, the user’s operating system, referrer URL (the previously visited page), IP address, and the requesting provider.

Logfile information is stored for security purposes (e.g., to investigate abusive or fraudulent activities) for a maximum of 7 days and then deleted. Data whose further retention is required for evidential purposes shall be exempted from the cancellation until the final clarification of the incident.

2.6 Ordering at Online Shop and Customer Account

We process the data of our customers as part of the ordering process in our online shop to allow them to select and order the selected products and services, as well as their payment and delivery or execution.

The processed data includes inventory data, communication data, contract data, payment data, and persons affected by the processing belong to our customers, prospects, and other business partners. Processing is for the purpose of providing contractual services in the context of the operation of an online shop, billing, delivery, and customer service. Here we use session cookies for the storage of the shopping cart contents and permanent cookies for the storage of the login status.

Processing is based on Art. 6 para. 1 lit. b (execution of order transactions) and c (legally required archiving) DSGVO. The required information for the establishment and fulfillment of the contract is required. We disclose the data to third parties only in the context of extradition, payment, or in the context of legal permissions and obligations to legal advisors and authorities. The data will be processed in third countries only if necessary for the fulfillment of the contract (e.g., on customer’s request upon delivery or payment).

Users can optionally create a user account, in particular by being able to view their orders. As part of the registration, the required mandatory information will be communicated to the users. The user accounts are not public and cannot be indexed by search engines. If users have terminated their user account, their data will be deleted with regard to the user account, subject to their retention is for commercial or tax law reasons according to Art. 6 para. 1 lit. c DSGVO necessary. Information in the customer account remains until its deletion with subsequent archiving in case of a legal obligation. It is the responsibility of the users to secure their data upon termination before the end of the contract.

As part of the registration and re-registration and use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. A transfer of these data to third parties does not take place unless it is necessary for the prosecution of our claims or there is a legal obligation in accordance with Art. 6 para. 1 lit. c DSGVO.

The deletion takes place after expiry of legal warranty and comparable obligations, the necessity of keeping the data is checked every three years; in the case of legal archiving obligations, the deletion takes place after its expiration (end of commercial law (6 years) and tax law (10 years) retention obligation).

2.7 Privacy Notice in the Application Procedure

We process the applicant data only for the purpose and in the context of the application process in accordance with the legal requirements. The processing of the applicant data takes place in order to fulfill our (pre-) contractual obligations in the context of the application process within the meaning of Art. 6 para. 1 lit. b. DSGVO Art. 6 para. 1 lit. f. DSGVO if the data processing e.g., is required for us in the context of legal proceedings (in Germany, § 26 BDSG applies additionally).

The application process requires applicants to provide us with the applicant data. The necessary applicant data are, as far as we offer an online form marked, otherwise result from the job descriptions and basically include the information on the person, postal and contact addresses and the application documents, such as cover letter, CV, and the certificates. In addition, applicants can voluntarily provide us with additional information.

By submitting the application to us, the applicants agree to the processing of their data for the purposes of the application process in accordance with the nature and scope set forth in this Privacy Policy.

Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are voluntarily communicated within the framework of the application procedure, their processing is additionally carried out in accordance with Art. 9 (2) lit. b DSGVO (e.g., health information such as disability or ethnic origin). Insofar as special categories of personal data within the meaning of Art. 9 (1) GDPR are requested from applicants in the context of the application procedure, their processing is additionally carried out in accordance with Art. 9 para. 2 lit. a GDPR (for example health data, if necessary for the profession).

If provided, applicants can submit their applications to us via an online form on our website. The data will be encrypted and transmitted to us according to the state of the art. Furthermore, applicants can send us their applications via e-mail. However, please note that e-mails are generally not sent in encrypted form and that applicants themselves must provide encryption. We can therefore take no responsibility for the transmission of the application between the sender and the reception on our server and therefore recommend rather to use an online form or the postal delivery. Instead of applying via the online form and e-mail, applicants still have the opportunity to send us the application by postal delivery.

The data provided by the applicants may be further processed by us in the event of a successful application for employment purposes. Otherwise, if the application for a job offer is not successful, the applicants’ data will be deleted. Applicants’ data will also be deleted if an application is withdrawn, which the applicants are entitled to at any time.

The cancellation is subject to a legitimate cancellation of the candidate, after the expiration of a period of six months, so that we can answer any follow-up questions to the application and meet our obligations under the Equal Treatment Act. Invoices for any reimbursement of travel expenses are archived in accordance with the tax regulations.

2.8 Registration Function

Users need to create a user account. As part of the registration, the required mandatory information will be communicated to the users. The data entered during registration will be used for the purpose of using the offer. Users may be informed by e-mail about offer- or registration-related information, such as changes in the scope of the offer or technical circumstances. If users have terminated their user account, their data will be deleted with regard to the user account, subject to their retention is for commercial or tax law reasons according to Art. 6 para. 1 lit. c DSGVO necessary. It is the responsibility of the users to secure their data upon termination before the end of the contract. We are entitled to irretrievably delete all user data stored during the term of the contract.

In the context of the use of our registration and registration functions as well as the use of user accounts, the IP address and the time of the respective user action will be saved. The storage is based on our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. A transfer of these data to third parties does not take place, unless it is necessary for the prosecution of our claims or there is a legal obligation in accordance with Art. 6 para. 1 lit. c DSGVO. The IP addresses will be anonymized or deleted after 7 days at the latest.

2.9 Contact

When contacting us (e.g., by contact form, e-mail, telephone or via social media) the information of the user to process the contact request and its processing in accordance with Art. 6 para. 1 lit. b) DSGVO is processed. User information can be stored in a Customer Relationship Management System (“CRM System”) or comparable request organization.

We delete the requests if they are no longer required. We check the necessity every two years; furthermore, the legal archiving obligations apply.

2.10 Comments and Contributions

If users leave comments or other contributions, their IP addresses may be stored for 7 days based on our legitimate interests within the meaning of Art. 6 para. 1 lit. f. DSGVO. This is for our own safety, in case someone leaves illegal content in comments and contributions (insults, prohibited political propaganda, etc.). In this case, we can be prosecuted for the comment or post and are therefore interested in the identity of the author.

Furthermore, we reserve the right, in accordance with our legitimate interests Art. 6 para. 1 lit. f. DSGVO to process the information of users for the purpose of spam detection.

2.11 Payment Information

When you make payments for our services, no credit or debit card information is stored on our servers. This information is stored by our third-party PCI-compliant payment processing companies. We work with the following providers:

Stripe Inc., 185 Berry Street, Suite 550, San Francisco, CA 94107 (USA).

All credit and debit card transactions occur between the computer from which the transaction originates and our payment processor. When you use one of our trial phases or subscriptions or purchase something through the service, credit card information and other financial information we need to process the payment is collected and stored with a payment service provider. We also collect certain limited information, such as your zip code, mobile phone number, and details of your transaction history. In addition, these payment service providers usually provide us with very limited information about you, such as the unique “token”, which enables you to make further purchases using the data stored by the service providers, as well as your card type, expiration date, and last four digits of the number.

We have entered into separate so-called “Data Processing Agreements” with both PayPal and Stripe, in

which we commit PayPal and Stripe to protect the data of our customers, not disclose them to third parties, and comply with the provisions of the standard contractual clauses according to Art. 46 GDPR in the case of a transfer of personal data to the USA.

3. Productlane App

3.1 Collection of Personal Data When Using the Web App

a) For the use of the Productlane app, a registration is necessary.

- **E-mail Address**: All data that you send to us from login or login (e.g., e-mail address, profile information) will be transmitted in encrypted form. This encryption protects the confidentiality of the data exchange between your computer and our web server and helps, e.g., to prevent the interception of data. As encryption technology, we use SSL (Secure Socket Layer).

- Organization Name: Besides your email, we need to collect your organization name to create a domain for your end-users.

With regard to our databases, all technical precautions have been taken to store your data in a secure environment. Access to your information is reserved only for employees who need to complete their professional activities and is only granted for quality control, complaint review, and fraud prevention purposes. All our employees are required to comply with data protection regulations and instructed accordingly.

Any personal information that you provide to us through our app will only be used for the purposes for which you provided us with this information.

All data that can be entered after registration in the app is voluntary and is intended to improve the effectiveness of Productlane services. These optional data are as follows:

- Projects data (title, description, progress, target date, status, milestone).

b) By registering an account on the web, you might use third-party services, the connection between these third-party services happens in accordance with the third-party service terms of use.

c) Productlane's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

4. Deletion of Data

The data processed by us are deleted or limited in their processing in accordance with Articles 17 and 18 GDPR. Unless explicitly stated in this privacy policy, the data stored by us are deleted as soon as they are no longer required for their purpose and the deletion does not conflict with any statutory storage requirements. Unless the data is deleted because it is required for other and legitimate purposes, its processing will be restricted. That means the data is blocked and not processed for other purposes. This applies, for example, for data that must be kept for commercial or tax reasons.

According to legal requirements in Germany, the storage takes place in particular for 6 years pursuant to § 257 paragraph 1 HGB (trading books, inventories, opening balance sheets, annual accounts, trade letters, accounting documents, etc.) and for 10 years in accordance with § 147 Abs. 1 AO (books, records, management reports, accounting documents, trade and business letters, documents relevant to taxation, etc.).

5. Delete User Account

To delete your Productlane account and all related data, please contact our support team at [email protected] from the email address associated with your account. If you receive an automated response, please answer directly to this message and we will take it from there.

If you instead want to only unsubscribe to our promotional emails, you can do so by clicking on the unsubscribe button in the email.

Please note that once we delete your account, it cannot be recovered. In addition, note that it may take our outbound email system up to 72 hours to remove you from our email rotation.

6. Additional Rights for Residents of California

If you are a resident of California, you have the right to opt-out of certain data-sharing practices with third parties who may use your Personal Data solely for their own purposes. Your right to opt-out is limited to information we “sell” to these third parties. “Sell” in this case may not mean providing data in exchange for money – we don’t do that. “Sell” may instead mean the disclosure of data, including technical device data that does not identify you directly, when a third party might use that data for its own purposes, such as for personalized advertising. We do not have actual knowledge that we sell personal information of minors under 16 years of age.

For instructions on how to exercise your rights, please visit our Do Not Sell My Personal Information page.

7. Confidentiality

- Strict Access Controls: We enforce strict access controls and permissions that restrict access to confidential data only to authorized personnel. This includes implementing multi-factor authentication, strong password policies, and role-based access controls.

- Secure Infrastructure: We maintain secure infrastructure and use industry-standard encryption protocols to safeguard your data. Our systems are regularly updated and audited to ensure compliance with the latest security standards.

- Confidentiality Agreements: Our employees, contractors, and partners are bound by confidentiality agreements to protect the confidentiality of your information. These agreements emphasize the legal and ethical implications of breaching confidentiality.

- Data Minimization: We collect and retain only the information necessary to provide our services. Any collected data is handled with the utmost care and in accordance with applicable data protection laws.

- Third-Party Vendor Evaluation: When partnering with third-party vendors or cloud service providers, we conduct thorough evaluations to ensure their commitment to data protection and confidentiality.

- Compliance with Regulations: We adhere to relevant data protection and privacy regulations, such as the General Data Protection Regulation (GDPR).

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