Knowunity Privacy Policy
1. Introduction
Below we inform you about the processing of personal data when using
- our website https://knowunity.de
- our app "Knowunity"
- our profiles on social media.
Personal data is any data relating to an identified or identifiable natural person, e.g. their name or IP address.
1.1. Controller
The controller pursuant to Art. 4 para. 7 EU General Data Protection Regulation (GDPR) is
Knowunity GmbH
Rosenstr. 16
10178 Berlin
Germany
Legally represented by Benedict Kurz.
Data Protection Officer
Contact details for our company data protection officer are:
Knowunity GmbH
Philipp Stoeppke
Rosenstr. 16
10178 Berlin, Germany
E-Mail: [email protected]
For encrypted PGP communication
1.2. Scope of Data Processing, Purposes of Processing and Legal Bases
We set out the scope of data processing, purposes of processing and legal bases in detail further below. The following legal bases generally apply to data processing:
- Art. 6 para. 1 sentence 1 lit. a GDPR
serves as the legal basis for processing operations for which we obtain consent. - Art. 6 para. 1 sentence 1 lit. b GDPR
is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. when a website visitor purchases a product from us or we provide a service for them. This legal basis also applies to processing required for pre-contractual measures, such as inquiries about our products or services. - Art. 6 para. 1 sentence 1 lit. c GDPR applies when we process personal data to fulfil a legal obligation, as may be the case under tax law.
- Art. 6 para. 1 sentence 1 lit. f GDPR serves as the legal basis when we rely on legitimate interests for the processing of personal data, e.g. for cookies necessary for the technical operation of our website.
1.3. Data Processing Outside the EEA
If we transfer data to service providers or other third parties outside the EEA, we guarantee the security of the data during transfer, insofar as (e.g. for the United Kingdom, Canada and Israel) adequacy decisions of the EU Commission exist (Art. 45 para. 3 GDPR).
If no adequacy decision exists (e.g. for the USA), the legal basis for data transfer is generally, unless otherwise stated, standard contractual clauses. These are a set of rules adopted by the EU Commission and form part of the contract with the respective third party. According to Art. 46 para. 2 lit. b GDPR, they ensure the security of data transfer. Many providers have given contractual guarantees beyond the standard contractual clauses, which protect the data beyond the standard contractual clauses. These include, for example, guarantees regarding the encryption of data or an obligation on the third party to notify data subjects if law enforcement authorities wish to access data.
1.4. Storage Period
Unless expressly stated otherwise in this privacy policy, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and there are no statutory retention obligations preventing deletion. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted, i.e. the data will be blocked and not processed for other purposes. This applies, for example, to data that we must retain for commercial or tax law reasons.
1.5. Rights of Data Subjects
Data subjects have the following rights vis-à-vis us with regard to their personal data:
- Right of access,
- Right to rectification or erasure,
- Right to restriction of processing,
- Right to object to processing,
- Right to data portability,
- Right to withdraw consent at any time.
Data subjects also have the right to lodge a complaint with a data protection supervisory authority regarding the processing of their personal data. Contact details of the data protection supervisory authorities can be found at this link.
1.6. Obligation to Provide Data
Customers, interested parties or third parties are only required to provide us with the personal data that is necessary for the establishment, execution and termination of the business relationship or other relationship, or which we are legally obliged to collect. Without this data, we will generally have to refuse to conclude a contract or provide a service, or we will no longer be able to execute an existing contract or other relationship.
Mandatory fields are marked as such.
1.7. No Automated Individual Decision-Making
We do not use fully automated individual decision-making in accordance with Article 22 GDPR for the establishment and execution of a business relationship or other relationship. Should we use such procedures in individual cases, we will inform you separately if required by law.
1.8. Contact
When you contact us, e.g. by email or telephone, the data you provide (e.g. names and email addresses) will be stored by us in order to answer your inquiries. The legal basis for processing is our legitimate interest (Art. 6 para. 1 sentence 1 lit. f GDPR) in responding to inquiries addressed to us. We delete the data arising in this context once storage is no longer necessary, or restrict processing if statutory retention obligations exist.
1.9. Customer Surveys
From time to time, we conduct customer surveys to get to know our customers and their wishes better. We collect the data requested in each case. It is our legitimate interest to get to know our customers and their wishes better, so the legal basis for the associated data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. We delete the data once the results of the surveys have been evaluated.
2. Newsletter
We reserve the right to inform customers who have already used our services or purchased goods from us from time to time by email or other electronic means about our offers, unless they have objected. The legal basis for this data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. Our legitimate interest lies in direct marketing (Recital 47 GDPR). Customers can object to the use of their email address for advertising purposes at any time without incurring additional costs, for example via the link at the end of each email or by emailing us at the above-mentioned email address.
3. Data Processing on Our Website
3.1. Informational Use of the Website
When using the website for informational purposes only, i.e. if visitors do not otherwise transmit information to us, we collect the personal data that the browser transmits to our server to ensure the stability and security of our website. This constitutes our legitimate interest, so the legal basis is Art. 6 para. 1 sentence 1 lit. f GDPR.
This data includes:
- IP address
- Date and time of the request
- Time zone difference to Greenwich Mean Time (GMT)
- Content of the request (specific page)
- Access status/HTTP status code
- Amount of data transferred in each case
- Website from which the request comes
- Browser
- Operating system and its interface
- Language and version of the browser software.
This data is also stored in log files. It is deleted when storage is no longer necessary, at the latest after 14 days.
3.2. Web Hosting and Provision of the Website
Our website is provided by Amazon AWS. The provider is Amazon Web Services EMEA Sarl, 38 avenue John F. Kennedy, L-1855, Luxembourg. The provider processes personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data, in the EU. Further information can be found in the provider's privacy policy at https://aws.amazon.com/de/privacy/?nc1=f_pr.
It is our legitimate interest to provide a website, so the legal basis for the described data processing is Art. 6 para. 1 sentence 1 lit. f GDPR.
We use a content delivery network to help provide our website. The provider is Cloudflare Inc., 106 East 6th Street, Suites 350 and 400, Austin, TX 78701, USA (Privacy Policy: https://www.cloudflare.com/en-gb/privacypolicy/). The provider processes personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data. It is our legitimate interest to provide a website, so the legal basis for data processing is Art. 6 para. 1 sentence 1 lit. f GDPR.
We use a content delivery network to help provide our website. The provider is Amazon Web Services, Inc., 410 Terry Avenue North, Seattle WA 98109, USA, (Privacy Policy: https://aws.amazon.com/de/privacy/). The provider processes personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data. It is our legitimate interest to provide a website, so the legal basis for data processing is Art. 6 para. 1 sentence 1 lit. f GDPR.
We use a content management system to help provide our website. The provider is Prismic.io Inc, 185 Alewife Brook Parkway, Suite 210 Cambridge Massachusetts 02138, USA, (Privacy Policy: https://prismic.io/legal/privacy). The provider processes personal data transmitted via the website, e.g. content, usage, meta/communication data or contact data. It is our legitimate interest to provide a website, so the legal basis for data processing is Art. 6 para. 1 sentence 1 lit. f GDPR.
3.3. Contact Form
When contacting us via the contact form on our website, we store the data requested there and the content of the message. The legal basis for processing is our legitimate interest in responding to inquiries addressed to us. The legal basis for processing is therefore Art. 6 para. 1 sentence 1 lit. f GDPR. We delete the data arising in this context once storage is no longer necessary, or restrict processing if statutory retention obligations exist.
3.4. Job Advertisements
We publish vacancies in our company on our website, on pages linked to the website or on third-party websites. The processing of data provided as part of the application is carried out for the purpose of conducting the application process. Insofar as this is necessary for our decision to establish an employment relationship, the legal basis is Art. 88 para. 1 GDPR in conjunction with § 26 para. 1 BDSG. The data required to carry out the application process is marked accordingly or we point it out. If applicants do not provide this data, we cannot process the application. Other data is voluntary and not required for an application. If applicants provide additional information, the basis is their consent (Art. 6 para. 1 sentence 1 lit. a GDPR).
We ask applicants to refrain from providing information on political opinions, religious beliefs and similarly sensitive data in their CV and cover letter. This information is not required for an application. If applicants nevertheless provide such information, we cannot prevent its processing as part of processing the CV or cover letter. Its processing is then also based on the applicant's consent (Art. 9 para. 2 lit. a GDPR).
Finally, we process applicants' data for further application procedures if they have given us their consent to do so. In this case, the legal basis is Art. 6 para. 1 sentence 1 lit. a GDPR.
We pass on applicants' data to the responsible employees in the HR department, to our processors in the area of recruiting and to other employees involved in the application process.
If, following the application process, we enter into an employment relationship with the applicant, we only delete the data after the employment relationship has ended. Otherwise, we delete the data at the latest six months after rejection of an application.
If applicants have given us their consent to use their data for further application procedures, we only delete their data one year after receipt of the application.
3.5. Booking Appointments
Visitors to our website can book appointments with us. For this purpose, we process, in addition to the data entered, meta or communication data. We have a legitimate interest in offering interested parties a user-friendly way to arrange appointments. Therefore, the legal basis for data processing is Art. 6 para. 1 sentence 1 lit. f GDPR. If we use a third-party tool for scheduling, information on this can be found under "Third-party providers".
3.6. Customer Area
Visitors to our website can open a customer account. The data requested in this context is processed by us for the performance of the respective user contract for the account, so the legal basis for processing is Art. 6 para. 1 sentence 1 lit. b GDPR.
In addition to the data entered during registration, we process page views.
3.7. Single Sign-On Procedure Apple
Visitors to our website can log in using a single sign-on procedure. They use login data already created for another provider. The prerequisite is that the visitor is already registered with the respective provider. When a person logs in using the single sign-on procedure, we receive information from the provider that the visitor is logged in with the provider and the provider receives information that the visitor is using the single sign-on procedure on our website. Depending on the visitor's settings in their account with the provider, it may be that additional information is provided to us by the provider. The legal basis for this processing is the consent of the visitor who logs in with their account (Art. 6 para. 1 sentence 1 lit. a GDPR). Provider of the procedure is Apple Inc., Infinite Loop, Cupertino, CA 95014, USA .
3.8. Single Sign-On Procedure Google
Visitors to our website can log in using a single sign-on procedure. They use login data already created for another provider. The prerequisite is that the visitor is already registered with the respective provider. When a person logs in using the single sign-on procedure, we receive information from the provider that the visitor is logged in with the provider and the provider receives information that the visitor is using the single sign-on procedure on our website. Depending on the visitor's settings in their account with the provider, it may be that additional information is provided to us by the provider. The legal basis for this processing is the consent of the visitor who logs in with their account (Art. 6 para. 1 sentence 1 lit. a GDPR). Provider of the procedure is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland .
3.9. Payment Service Providers
To process payments, we use payment processors who are themselves data controllers within the meaning of Art. 4 no. 7 GDPR. Insofar as they receive data entered by us in the order process and payment data, we thereby fulfil the contract concluded with our customers (Art. 6 para. 1 sentence 1 lit. b GDPR).
These payment service providers are:
- Apple Inc., USA (for Apple Pay)
- Google Ireland Limited, Ireland (for Google Pay)
- Klarna Bank AB (publ), Sweden ("Klarna Sofort")
- Mastercard Europe SA, Belgium
- PayPal (Europe) S.à r.l. et Cie, S.C.A., Luxembourg
- Shopify Inc., Canada (for Shop Pay)
- Stripe Payments Europe, Ltd., Ireland
- RevenueCat Inc., USA
3.10. Third-Party Providers
We use the following technologies and services from third-party providers on the basis of users' consent within the meaning of § 25 para. 1 sentence 1 TDDDG.
3.10.1. AppsFlyer
We use AppsFlyer for analytics. The provider is AppsFlyer Ltd., 14 Maskit st. Herziliya, Israel. The provider processes usage data (e.g. visited websites, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the EU.
The legal basis for processing is Art. 6 para. 1 sentence 1 lit. a GDPR. Processing is based on consent. Data subjects can withdraw their consent at any time, for example by contacting us using the contact details provided in our privacy policy. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
Data is deleted when the purpose for which it was collected no longer applies and there is no retention obligation. Further information can be found in the provider's privacy policy at https://www.appsflyer.com/legal/privacy-policy/
3.10.2. SNAP PIXEL
We use Snap Pixel for analytics. The provider is Snap Group Limited, 7-11 Lexington Street, London W1F 9AF, United Kingdom. The provider processes usage data (e.g. visited websites, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.
The legal basis for processing is Art. 6 para. 1 sentence 1 lit. a GDPR. Processing is based on consent. Data subjects can withdraw their consent at any time, for example by contacting us using the contact details provided in our privacy policy. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
The legal basis for transfer to a country outside the EEA is standard contractual clauses. The security of data transferred to the third country (i.e. a country outside the EEA) is ensured by standard data protection clauses adopted in accordance with the review procedure under Art. 93 para. 2 GDPR (Art. 46 para. 2 lit. c GDPR), which we have agreed with the provider.
Data is deleted when the purpose for which it was collected no longer applies and there is no retention obligation. Further information can be found in the provider's privacy policy at https://snap.com/de-DE/privacy/privacy-policy
3.10.3. FACEBOOK CONVERSION API
We use Facebook Conversion API for analytics. The provider is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes usage data (e.g. visited websites, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.
The legal basis for processing is Art. 6 para. 1 sentence 1 lit. a GDPR. Processing is based on consent. Data subjects can withdraw their consent at any time, for example by contacting us using the contact details provided in our privacy policy. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
The legal basis for transfer to a country outside the EEA is standard contractual clauses. The security of data transferred to the third country (i.e. a country outside the EEA) is ensured by standard data protection clauses adopted in accordance with the review procedure under Art. 93 para. 2 GDPR (Art. 46 para. 2 lit. c GDPR), which we have agreed with the provider.
Data is deleted when the purpose for which it was collected no longer applies and there is no retention obligation. Further information can be found in the provider's privacy policy at https://www.facebook.com/policy.php
3.10.4. CAPTCHA
We use hCaptcha for authentication management. The provider is Intuition Machines, Inc., 350 Alabama Street, San Francisco, CA 94110, USA. The provider processes usage data (e.g. visited websites, interest in content, access times) and meta/communication data (e.g. device information, IP addresses) in the USA.
The legal basis for processing is Art. 6 para. 1 sentence 1 lit. a GDPR. Processing is based on consent. Data subjects can withdraw their consent at any time, for example by contacting us using the contact details provided in our privacy policy. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
The legal basis for transfer to a country outside the EEA is standard contractual clauses. The security of data transferred to the third country (i.e. a country outside the EEA) is ensured by standard data protection clauses adopted in accordance with the review procedure under Art. 93 para. 2 GDPR (Art. 46 para. 2 lit. c GDPR), which we have agreed with the provider.
Data is deleted when the purpose for which it was collected no longer applies and there is no retention obligation. Further information can be found in the provider's privacy policy at https://www.hcaptcha.com/privacy
3.10.5. SMARTLOOK
We use, pursuant to Art. 6 para. 1 lit. f GDPR, the analytics software Smartlook from smartlook.com s.r.o., Milady Horakove 13, 602 00 Brno, Czech Republic.
This tool records movement data in the app. This allows us to anonymously see where visitors click and how far they scroll. This enables us to make our offering better and more user-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.
The privacy policy of Smartlook can be found here: https://help.smartlook.com/en/articles/3244452-privacy
3.10.6. GOOGLE ADMOB
We provide Google with advertising space within our app via the Google AdMob service. To avoid displaying irrelevant and disruptive advertising, we also use direct advertising. To determine which advertising is relevant to the respective users, AdMob collects and processes personal data and may also carry out profiling.
3.10.7. MICROSOFT CLARITY
This website and app use Microsoft Clarity, an analytics tool from Microsoft Corporation . For this purpose, Microsoft Clarity uses cookies that enable analysis of your use of our website (e.g. page views, navigation, scroll and click behaviour). According to § 25 para. 1 TDDDG, these are only set with your express consent. The information generated by the cookies is transmitted to and stored on a Microsoft Clarity server (possibly in the USA) to enable session recording and the creation of so-called heatmaps. We use Microsoft Clarity in the default settings, so the data transmitted to Microsoft does not contain sensitive input data such as names or addresses, to exclude a direct personal reference. Microsoft will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website and internet usage to the website operator, including the creation of user profiles for advertising purposes. Microsoft may also transfer this information to third parties if required by law or if these third parties process the information on behalf of Microsoft. You can refuse the use of cookies by selecting the appropriate settings in your browser. However, please note that if you do this you may not be able to use the full functionality of this website.
Further information about Microsoft Clarity can be found here: https://clarity.microsoft.com/
The legal basis for processing your personal data is Art. 6 para. 1 lit. a GDPR.
3.10.8. Disclosure of Data When Clicking on Advertisements
When you click on one of our advertisements, certain data may be transmitted to third-party providers. This includes information such as your IP address, the browser used, the operating system, the time of the click and the referrer URL. This transfer is carried out in order to analyse and optimise the effectiveness of advertising and to display personalised content. The processing of this data is carried out in accordance with the privacy policies of the respective third-party providers. Further information on their privacy practices can be found in the privacy policies of the respective partners.
4. Data Processing on Social Media Platforms
We are present on social media networks to present our company and our services there. The operators of these networks regularly process their users' data for advertising purposes. Among other things, they create user profiles based on their online behaviour, which are used, for example, to display advertising on the network pages and elsewhere on the internet that matches the interests of the users. To this end, the operators of the networks store information about usage behaviour in cookies on the users' computers. It is also possible that the operators combine this information with other data. Further information and instructions on how users can object to processing by the site operators can be found in the privacy policies of the respective operators listed below. It is also possible that the operators or their servers are located in non-EU countries, so that they process data there. This may pose risks for users, e.g. because it is more difficult to enforce their rights or because government agencies may access the data.
When users of the networks contact us via our profiles, we process the data provided to us in order to respond to the inquiries. This constitutes our legitimate interest, so the legal basis is Art. 6 para. 1 sentence 1 lit. f GDPR.
4.1. Facebook
We maintain a profile on Facebook. Operator is Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy can be found here: https://www.facebook.com/policy.php. You can object to data processing via ad settings: https://www.facebook.com/settings?tab=ads. We are jointly responsible with Facebook for the processing of data of visitors to our profile on the basis of an agreement within the meaning of Art. 26 GDPR. Facebook explains which data is processed at https://www.facebook.com/legal/terms/information_about_page_insights_data. Data subjects can exercise their rights both against us and against Facebook. According to our agreement with Facebook, however, we are obliged to forward requests to Facebook. Data subjects will therefore receive a quicker response if they contact Facebook directly.
4.2. Instagram
We maintain a profile on Instagram. Operator is Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The privacy policy can be found here: https://help.instagram.com/519522125107875.
4.3. Snapchat
We maintain a profile on Snapchat. Operator is Snap Inc., 3000 31st Street, Santa Monica, California 90405, USA. The privacy policy can be found here: https://snap.com/de-DE/privacy/privacy-policy.
4.4. TikTok
We maintain a profile on TikTok. Operator is musical.ly Inc., 10351 Santa Monica Blvd #310, Los Angeles, CA 90025 USA. The privacy policy can be found here: https://www.tiktok.com/de/privacy-policy.
4.5. YouTube
We maintain a profile on YouTube. Operator is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The privacy policy can be found here: https://policies.google.com/privacy?hl=de.
4.6. Twitter
We maintain a profile on Twitter. Operator is Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA. The privacy policy can be found here: https://twitter.com/de/privacy. You can object to data processing via ad settings: https://twitter.com/personalization.
4.7. LinkedIn
We maintain a profile on LinkedIn. Operator is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. The privacy policy can be found here: https://www.linkedin.com/legal/privacy-policy?_l=de_DE. You can object to data processing via ad settings: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out.
5. Changes to This Privacy Policy
We reserve the right to change this privacy policy with effect for the future. A current version is always available here.
6. Questions and Comments
If you have any questions or comments regarding this privacy policy, please feel free to contact us using the contact details provided above.