Privacy Policy
WiConnect LLC (hereinafter “WiConnect”, “We” or “Us”) welcomes you to our internet pages and mobile applications (together also referred to as “online offers”). We thank you for your interest in our company and our products.
1 WiConnect respects your privacy
The protection of your privacy throughout the course of processing personal data as well as the security of all business data are important concerns to us. We process personal data that was gathered during your visit of our Online Offers confidentially and only in accordance with statutory regulations.
Data protection and information security are included in our corporate policy.
2 Controller
WiConnect LLC is the controller responsible for the processing of your data; exceptions are outlined in this data protection notice.
Our contact details are as follows:
WiConnect LLC,
c/o 825 Eighth Avenue, Suite 29000
New York, NY 10019
USA
E-mail: info@wiconnect.com
3 Collection, processing, and usage of personal data
3.1 Processed data categories
Communication data (e.g., name, telephone number, e-mail address, address, IP address) are processed.
3.2 Principles
Personal data consists of all information related to an identified or identifiable natural person, this includes, e.g., names, addresses, phone numbers, email addresses, contractual master data, contract accounting, and payment data, which is an expression of a person’s identity.
We collect, process, and use personal data (including IP addresses) only when there is either a statutory legal basis to do so or if you have given your consent to the processing or use of personal data concerning this matter, e.g., by means of registration.
3.3 Processing purposes and legal basis
We as well as the service providers commissioned by us, process your personal data for the following processing purposes:
3.3.1 Provision of these online offers
- Legal basis: Predominantly, legitimate interest on our part in direct marketing as long as this occurs in accordance with data protection and competition law.
3.3.2 In reply to user inquiries in the framework of a contact form
- Legal basis: Predominantly, legitimate interest in direct marketing on our part and in the enhancement of our products and services, as long as this is carried out in compliance with data protection regulations and competition law regulations.
3.3.3 Resolving service disruptions as well as for security reasons
- Legal basis: Fulfillment of our legal obligations within the scope of data security and predominantly, legitimate interest in resolving service disruptions as well as in the protection of our offers.
3.3.4 Self-promotion and promotion by others as well as market research and reach analysis done within the scope statutorily permitted or based on consent
- Legal basis: Consent or predominantly, legitimate interest on our part in direct marketing if in accordance with data protection and competition law.
3.3.5 Safeguarding and defending our rights
- Legal basis: Legitimate interest on our part in the assertion and defense of our rights.
3.4 Log files
Each time you use the internet, your browser is transmitting certain information which we store in so-called log files.
We store log files to determine service disruptions and for security reasons (e.g., to investigate attack attempts) for a period of 7 days and delete them afterwards. Log files which need to be maintained for evidence purposes are excluded from deletion until the respective incident is resolved and may, on a case-by-case basis, be passed on to investigating authorities.
Log files are also used for analysis purposes (without the IP address or without the complete IP address) see Section 3.3.4, “Self-promotion and promotion by others as well as market research and reach analysis done within the scope statutorily permitted or based on consent”.
In log files, the following information is saved:
- IP address (internet protocol address) of the terminal device used to access the online offer;
- MAC address (media access control address) of the terminal device used to access the online offer;
- Internet address of the website from which the online offer is accessed (so-called URL of origin or referrer URL);
- Name of the service provider which was used to access the online offer;
- Name of the files or information accessed;
- Date and time as well as duration of recalling the data;
- Amount of data transferred;
- Operating system and information on the internet browser used, including add-ons installed;
- http status code (e.g., “Request successful” or “File requested not found”).
3.5 Data transfer
3.5.1 Data transfer to other controllers
Principally, your personal data is forwarded to other controllers only if required for the fulfillment of a contractual obligation, or if we ourselves, or a third party, have a legitimate interest in the data transfer, or if you have given your consent. Particulars on the legal basis and the recipients or categories of recipients can be found in the section 3.3, “Processing purposes and legal basis”.
Additionally, data may be transferred to other controllers when we are obliged to do so due to statutory regulations or enforceable administrative or judicial orders.
3.5.2 Service providers (general)
We involve external service providers with tasks such as sales and marketing services, contract management, payment handling, programming, data hosting, and hotline services. We have chosen those service providers carefully and monitor them on a regular basis, especially regarding their diligent handling of and protection of the data that they store. All service providers are obliged to maintain confidentiality and to comply with the statutory provisions.
3.5.3 Transfer to recipients outside the country of origin
We might transfer personal data to recipients located outside the county the data originate into so-called third countries. In such cases, prior to the transfer we ensure that either the data recipient provides an appropriate level of data protection or that you have consented to the transfer.
You are entitled to receive an overview of third country recipients and a copy of the specifically agreed provisions securing an appropriate level of data protection. For this purpose, please use the statements made in the Section 9, “Contacts”.
3.6 Duration of storage, retention periods
Principally, we store your data for as long as it is necessary to render our online offers and connected services or for as long as we have a legitimate interest in storing the data (e.g., we might still have a legitimate interest in postal mail marketing after fulfillment of our contractual obligations). In all other cases we delete your personal data with the exception of data we are obliged to store for the fulfillment of legal obligations (e.g., due to retention periods under the tax and commercial codes we are obliged to have documents such as contracts and invoices available for a certain period of time).
4 Usage of cookies
In the context of our online service, cookies and tracking mechanisms may be used. Cookies are small text files that may be stored on your device when visiting our online service.
Tracking is possible using different technologies. In particular, we process information using pixel technology and/or during log file analysis.
4.1 Categories
We distinguish between cookies that are mandatorily required for the technical functions of the online service and such cookies and tracking mechanisms that are not mandatorily required for the technical function of the online service.
It is generally possible to use the online service without any cookies that serve non-technical purposes.
4.1.1 Technically required cookies
By technically required cookies we mean cookies without those the technical provision of the online service cannot be ensured. These include, e.g., cookies that store data to ensure smooth reproduction of video or audio footage. Such cookies will be deleted when you leave the website.
4.1.2 Cookies and tracking mechanisms that are technically not required
We use marketing cookies and tracking mechanisms. We only use such cookies and tracking mechanisms if you have given us your prior consent in each case. With the exception of the cookie that saves the current status of your privacy settings (selection cookie). This cookie is set based on legitimate interest.
General
By using marketing cookies and tracking mechanisms we and our partners are able to show you offerings based on your interests, resulting from an analysis of your user behavior:
- Statistics:
By using statistical tools, we measure e.g., the number of your page views.
- Conversion tracking:
Our conversion tracking partners place a cookie on your computer (“conversion cookie”) if you accessed our website via an advertisement of the respective partner. Normally these cookies are no longer valid after 30 days. If you visit certain pages of our website and the cookie has not yet expired, we and the relevant conversion partner can recognize that a certain user clicked on the advertisement and thereby was redirected to our website. This can also be done across multiple devices. The information obtained by means of the conversion cookie serves the purpose of compiling conversion statistics and recording the total number of users who clicked on the respective advertisement and were redirected to a website with a conversion tracking tag.
Please note that using the tools might include transfer of your data to recipients outside of the country of origin where there is no adequate level of data protection pursuant to the GDPR or similar legislation. For more details in this respect please refer to the following description of the individual marketing tools:
- Name: Google Analytics
Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Function: Analysis of user behavior (page retrievals, number of visitors and visits, downloads), creation of pseudonymous user profiles based on cross-device information of logged-in Google users (cross-device tracking), enrichment of pseudonymous user data with target group-specific information provided by Google, retargeting, UX testing, conversion tracking, and retargeting in conjunction with Google Ads.
- Name: Google Tag Manager
Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Function: Administration of website tags via a user interface, integration of program codes on our websites.
- Name: Google Ads
Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
Function: Placement of advertisements, remarketing, conversion tracking
Further information is available at: https://adssettings.google.com/authenticated
4.2 Management of cookies and tracking mechanisms
You can manage your cookie and tracking mechanism settings in the browser and/or our privacy settings.
Note: The settings you have made refer only to the browser used in each case.
4.2.1 Deactivation of all cookies
If you wish to deactivate all cookies, please deactivate cookies in your browser settings. Please note that this may affect the functionality of the website.
4.2.2 Management of your settings with regard to cookies and tracking mechanisms not required technically
When visiting our websites, you will be asked in a cookie layer whether you consent to our using of any marketing cookies or tracking mechanisms, respectively.
In our privacy settings, you may withdraw the consent with effect for the future or grant your consent at a later point in time.
5 External links
Our online offers may contain links to internet pages of third parties, in particular providers who are not related to us. Upon clicking on the link, we have no influence on the collecting, processing, and use of personal data possibly transmitted by clicking on the link to the third party (such as the IP address or the URL of the site on which the link is located) as the conduct of third parties is naturally beyond our control. We do not assume responsibility for the processing of personal data by third parties.
6 Security
Our employees and the companies providing services on our behalf, are obliged to confidentiality and to compliance with the applicable data protection laws. We take all necessary technical and organizational measures to ensure an appropriate level of security and to protect your data that are administrated by us especially from the risks of unintended or unlawful destruction, manipulation, loss, change, or unauthorized disclosure or unauthorized access. Our security measures are, pursuant to technological progress, constantly being improved.
7 User rights
To enforce your rights, please use the details provided in the Section 9, “Contact”. In doing so, please ensure that an unambiguous identification of your person is possible.
7.1 Right to information and access
You have the right to obtain confirmation from us about whether or not your personal data is being processed, and, if this is the case, access to your personal data.
7.2 Right to correction and deletion
You have the right to obtain the rectification of inaccurate personal data. As far as statutory requirements are fulfilled, you have the right to obtain the completion or deletion of your data.
This does not apply to data which is necessary for billing or accounting purposes, or which is subject to a statutory retention period. If access to such data is not required, however, its processing is restricted (see the following).
7.3 Restriction of processing
As far as statutory requirements are fulfilled you have the right to demand for restriction of the processing of your data.
7.4 Data portability
As far as statutory requirements are fulfilled you may request to receive data that you have provided to us in a structured, commonly used and machine-readable format or – if technically feasible – that we transfer those data to a third party.
7.5 Right of objection
7.5.1 Objection to direct marketing
Additionally, you may object to the processing of your personal data for direct marketing purposes at any time. Please take into account that due to organizational reasons, there might be an overlap between your objection and the usage of your data within the scope of a campaign which is already running.
7.5.2 Objection to data processing based on the legal basis of “legitimate interest”
In addition, you have the right to object to the processing of your personal data at any time, insofar as this is based on “legitimate interest”. We will then terminate the processing of your data, unless we demonstrate compelling legitimate grounds according to legal requirements which override your rights.
7.6 Withdrawal of consent
In case you consented to the processing of your data, you have the right to revoke this consent at any time with effect for the future. The lawfulness of data processing prior to your withdrawal remains unchanged.
8 Change of the data protection notice
We reserve the right to change our security and data protection measures. In such cases, we will amend our data protection notice accordingly. Please, therefore, refer to the current version of our data protection notice, as this is subject to changes.
9 Contact
If you wish to contact us, please find us at the address stated in the Section 2.
For suggestions and complaints regarding the processing of your personal data we recommend that you contact our data protection officer:
Data Protection Officer
WiConnect LLC,
c/o 825 Eighth Avenue, Suite 29000
New York, NY 10019
USA
or e-mail: dpo@wiconnect.com