Privacy Policy

We are pleased that you are visiting our website. The protection and security of your personal information when using our website is very important to us. We would therefore like to inform you at this point which of your personal data we collect when you visit our website and for what purposes it is used.

This privacy policy applies to the Internet offering of GGC wellplayd UG (i.G.), which is accessible under the domain wellplayd.org and its various subdomains ("our website").

Who is responsible and how can I reach you?

Controller

for the processing of personal data within the meaning of the EU General Data Protection Regulation (GDPR)

GGC wellplayd UG
Lippmannstr. 8a
22769 Hamburg
Germany

Data Protection Officer

Datenschutz Ruhr GmbH
Hauptstr. 2
45219 Essen
Germany
Tim Schabio
schabio@datenschutz-ruhr.de

What is this about?

This privacy policy fulfills the legal requirements for transparency in the processing of personal data. This is all information that relates to an identified or identifiable natural person. This includes, for example, information such as your name, your age, your address, your telephone number, your date of birth, your email address, your IP address or user behavior when visiting a website. Information for which we cannot (or only with disproportionate effort) establish a connection to you, e.g. through anonymization, is not personal data. The processing of personal data (e.g. collection, querying, use, storage or transmission) always requires a legal basis and a defined purpose.

Stored personal data will be deleted as soon as the purpose of processing has been achieved and there are no legitimate reasons for further storage of the data. We inform you in the individual processing operations about the specific storage periods or criteria for storage. Regardless of this, we store your personal data in individual cases for the assertion, exercise or defense of legal claims and in the presence of statutory retention obligations.

Who receives my data?

We only pass on your personal data that we process on our website to third parties if this is necessary for the fulfillment of the purposes and is covered in individual cases by the legal basis (e.g. consent or safeguarding of legitimate interests). In addition, we pass on personal data to third parties in individual cases if this serves the assertion, exercise or defense of legal claims. Possible recipients can then be, for example, law enforcement agencies, lawyers, auditors, courts, etc.

Insofar as we use service providers to operate our website who process personal data on our behalf as part of order processing in accordance with Art. 28 GDPR, they may be recipients of your personal data. You can find more detailed information on the use of processors and web services in the overview of the individual processing operations.

Do you use cookies?

Cookies are small text files that are sent by us to your device's browser and stored there when you visit our websites. As an alternative to the use of cookies, information can also be stored in the local storage of your browser. Some functions of our website cannot be offered without the use of cookies or local storage (technically necessary cookies). Other cookies, on the other hand, enable us to carry out various analyses, so that we are able, for example, to recognize the browser you are using when you visit our website again and to transmit various information to us (non-necessary cookies). With the help of cookies, we can, among other things, make our website more user-friendly and effective for you by tracking your use of our website and determining your preferred settings (e.g. country and language settings). If third parties process information via cookies, they collect the information directly via your browser. Cookies do not cause any damage to your device. They cannot execute programs and do not contain viruses.

We inform you about the respective services for which we use cookies in the individual processing operations. Detailed information on the cookies used can be found in the cookie settings or in the consent manager of this website.

What rights do I have?

Under the conditions of the statutory provisions of the General Data Protection Regulation (GDPR), you as a data subject have the following rights:

Information pursuant to Art. 15 GDPR about the data stored about you in the form of meaningful information about the details of the processing and a copy of your data;
Correction pursuant to Art. 16 GDPR of incorrect or incomplete data stored with us;
Deletion pursuant to Art. 17 GDPR of the data stored with us, insofar as the processing is not necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the assertion, exercise or defense of legal claims;
Restriction of processing pursuant to Art. 18 GDPR, insofar as the accuracy of the data is disputed, the processing is unlawful, we no longer need the data and you refuse their deletion because you need them for the assertion, exercise or defense of legal claims or you have objected to the processing pursuant to Art. 21 GDPR.
Data portability pursuant to Art. 20 GDPR, insofar as you have provided us with personal data within the framework of consent pursuant to Art. 6 para. 1 lit. a GDPR or on the basis of a contract pursuant to Art. 6 para. 1 lit. b GDPR and these have been processed by us using automated procedures. You will receive your data in a structured, common and machine-readable format or we will transmit the data directly to another controller, insofar as this is technically feasible.
Objection pursuant to Art. 21 GDPR to the processing of your personal data, insofar as this is based on Art. 6 para. 1 lit. e, f GDPR and there are reasons for this arising from your particular situation or the objection is directed against direct marketing. The right to object does not exist if overriding, compelling legitimate reasons for the processing can be demonstrated or the processing serves the assertion, exercise or defense of legal claims. Insofar as the right to object does not exist for individual processing operations, this is indicated there.
Revocation pursuant to Art. 7 para. 3 GDPR of your given consent with effect for the future.
Complaint pursuant to Art. 77 GDPR to a supervisory authority if you are of the opinion that the processing of your personal data violates the GDPR. As a rule, you can contact the supervisory authority of your usual place of residence, your place of work or our company headquarters.

How is my data processed in detail?

Below we inform you about the individual processing operations, the scope and purpose of data processing, the legal basis, the obligation to provide your data and the respective storage period. Automated decision-making in individual cases, including profiling, does not take place.

Provision of the website

Type and scope of processing

When you access and use our website, we collect the personal data that your browser automatically transmits to our server. The following information is temporarily stored in a so-called log file:

IP address of the requesting computer
Date and time of access
Name and URL of the retrieved file
Website from which access is made (referrer URL)
Browser used and, if applicable, the operating system of your computer, as well as the name of your access provider

Our website is not hosted by us ourselves, but by a service provider who processes the aforementioned data on our behalf in accordance with Art. 28 GDPR for this purpose.

Purpose and legal basis

The processing is carried out to safeguard our overriding legitimate interest in displaying our website and ensuring security and stability on the basis of Art. 6 para. lit. f GDPR. The collection of data and storage in log files is absolutely necessary for the operation of the website. A right to object to the processing does not exist due to the exception according to Art. 21 para. 1 GDPR. Insofar as the further storage of log files is legally prescribed, the processing is carried out on the basis of Art. 6 para. 1 lit. c GDPR. There is no legal or contractual obligation to provide the data, but accessing our website is technically impossible without providing the data.

Storage period

The aforementioned data is stored for the duration of the display of the website and for technical reasons beyond that for a maximum of 7 days.

Contact form

Type and scope of processing

On our website, we offer you the opportunity to contact us via a provided form. The information collected via mandatory fields is required to be able to process the request. In addition, you can voluntarily provide additional information that you consider necessary for processing the contact request.

When using the contact form, your personal data is not passed on to third parties.

Purpose and legal basis

The processing of your data by using our contact form is carried out for the purpose of communication and processing your request on the basis of your consent pursuant to Art. 6 para. 1 lit. a GDPR. Insofar as your request relates to an existing contractual relationship with us, the processing is carried out for the purpose of contract fulfillment on the basis of Art. 6 para. 1 lit. b GDPR. There is no legal or contractual obligation to provide your data, but processing your request is not possible without providing the information in the mandatory fields. If you do not wish to provide this data, please contact us by other means.

Storage period

Insofar as you use the contact form on the basis of your consent, we store the collected data of each request for a period of three years, starting with the completion of your request or until you revoke your consent.

If you use the contact form within the framework of a contractual relationship, we store the collected data of each request for a period of three years from the end of the contractual relationship.

Type and scope of processing

If you register to receive our newsletter on our website, we collect your email address and your name and store this information together with the date of registration and your IP address. You will then receive an email in which you must confirm your registration for the newsletter (double opt-in). If you do not confirm the registration, it will automatically expire and the data will not be processed for newsletter dispatch.

To send the newsletter, we may use an external service that processes your personal data on our behalf in accordance with Art. 28 GDPR. Your data is not passed on to third parties.

We may also integrate analysis services into our newsletter to evaluate your click behavior in the newsletter.

Purpose and legal basis

We process your data for the purpose of sending newsletters on the basis of your consent pursuant to Art. 6 para. 1 lit. a GDPR. By unsubscribing from the newsletter, you can declare your revocation pursuant to Art. 7 para. 3 GDPR at any time with effect for the future. There is no legal or contractual obligation to provide your data, but sending the newsletter is not possible without providing your data.

The legal basis for evaluating your click behavior in the newsletter is also your consent pursuant to Art. 6 para. 1 lit. s GDPR. You can revoke your consent to the newsletter dispatch and the associated evaluation of your user behavior at any time with effect for the future. In this case, you will no longer receive a newsletter and no evaluation of user behavior will take place. Receiving the newsletter without such an evaluation is not possible.

Storage period

After registering for the newsletter, we initially store the data until the registration is confirmed. After successful confirmation, we store your data until you revoke your consent (unsubscribe from the newsletter) and for technical reasons beyond that for a maximum of 7 days.

Presence on social media platforms

We maintain so-called fan pages or accounts or channels on the networks mentioned below in order to provide you with information and offers within social networks and to offer you additional ways to contact us and inform yourself about our offers. In the following, we inform you about which data we or the respective social network process from you in connection with accessing and using our fan pages/accounts.

Data that we process from you

If you would like to contact us via messenger or direct message via the respective social network, we usually process your username via which you contact us and, if necessary, store other data you provide insofar as this is necessary for processing/answering your request.

The legal basis is Art. 6 para. 1 sentence 1 f) GDPR (processing is necessary to safeguard the legitimate interests of the controller).

(Static) usage data that we receive from social networks

We receive statistics automatically provided via insights functionalities regarding our accounts. The statistics contain, among other things, the total number of page views, likes, information on page activities and post interactions, reach, video views/views and information on the proportion of men/women among our fans/followers.

The statistics only contain aggregated data that cannot be related to individual persons. You are not identifiable to us via this.

What data do social networks process from you

To view the content of our fan pages or accounts, you do not have to be a member of the respective social network and no user account is required for the respective social network in this respect.

However, please note that the social networks also collect and store data from website visitors without a user account when accessing the respective social network (e.g. technical data to display the website to you) and use cookies and similar technologies, over which we have no influence whatsoever. Details can be found in the privacy policies of the respective social network (see the corresponding links above)

Insofar as you want to interact with the content on our fan pages/accounts, e.g. comment, share or like our postings/posts and/or would like to contact us via messenger functions, prior registration with the respective social network and the provision of personal data is required.

We have no influence on the data processing by the social networks in the context of your use. To our knowledge, your data is stored and processed in particular in connection with the provision of the services of the respective social network, and also for the analysis of user behavior (using cookies, pixels/web beacons and similar technologies) on the basis of which advertising based on your interests is played both within and outside the respective social network. It cannot be ruled out that your data is also stored outside the EU/EEA by the social networks and passed on to third parties.

Information on, among other things, the exact scope and purposes of processing your personal data, the storage period/deletion as well as guidelines on the use of cookies and similar technologies in the context of registration and use of social networks can be found in the privacy policies/cookie policies of the social networks. There you will also find information on your rights and objection options.

Instagram page

When you visit our Instagram page, Instagram (Meta) collects, among other things, your IP address and other information that is present on your PC in the form of cookies. This information is used to provide us as the operator of the Instagram pages with statistical information about the use of the Instagram page. Further information on this is provided by Instagram at the following link (note: by clicking on the following link you will be taken to the website of the social network Facebook, also part of the Meta group. The information provided via the link also applies to the social network Instagram): https://facebook.com/help/pages/insights.

By means of the transmitted statistical information, it is not possible for us to draw conclusions about individual users. We only access this in order to be able to respond to the interests of our users and to continuously improve our online presence and ensure its quality.

We only collect your data via our fan page in order to enable possible provision for communication and interaction with us. This collection usually includes your name, message content, comment content and the profile information you have made "public".

The processing of your personal data for our above-mentioned purposes is based on our legitimate business and communication interest in offering an information and communication channel pursuant to Art. 6 para. 1 f) GDPR. If you as a user have given consent to data processing to the respective provider of the social network, the legal basis of the processing extends to Art. 6 para. 1 a), Art. 7 GDPR.

Due to the fact that the actual data processing is carried out by the provider of the social network, our access options to your data are limited. Only the provider of the social network is authorized to have full access to your data. Because of this, only the provider can directly take appropriate measures to fulfill your user rights (request for information, deletion request, objection, etc.) and implement them. The assertion of corresponding rights is therefore most effective directly against the respective provider.

We are jointly responsible with Instagram for the personal content of the fan page. Data subject rights can be asserted against Meta Platforms Ireland Ltd. as well as against us.

The primary responsibility for the processing of insights data lies with Instagram in accordance with the GDPR and Instagram fulfills all obligations under the GDPR with regard to the processing of insights data, Meta Platforms Ireland Ltd. makes the essentials of the page insights supplement available to data subjects.

We do not make any decisions regarding the processing of insights data and the storage period of cookies on user devices.

Further information can be found directly at Instagram (supplementary agreement with Facebook): https://www.facebook.com/legal/terms/page_controller_addendum.

More detailed information on, among other things, the exact scope and purposes of processing your personal data, the storage period/deletion as well as guidelines on the use of cookies and similar technologies in the context of registration and use can be found in the privacy policies/cookie policies of Instagram:

LinkedIn page

LinkedIn is a social network of LinkedIn Inc. based in Sunnyvale, California, USA, which enables the creation of private and professional profiles of natural persons and company profiles. Users can maintain their existing contacts within the social network and make new ones. Companies and other organizations can create profiles on which photos and other company information are uploaded to present themselves as employers and hire employees. Other LinkedIn users have access to this information and can write their own articles and share this content with others. The focus of the network is on professional exchange on specialist topics with people who have the same professional interests.

When using or visiting the network, LinkedIn automatically collects data from users or visitors during use or visit, for example username, job title and IP address. This is done with the help of various tracking technologies. LinkedIn provides users with information, offers and recommendations based on the data collected in this way.

We only collect your data via our company profile in order to enable possible provision for communication and interaction with us. This collection usually includes your name, message content, comment content and the profile information you have made "public".

The processing of your personal data for our above-mentioned purposes is based on our legitimate business and communication interest in offering an information and communication channel pursuant to Art. 6 para. 1 f GDPR. If you as a user have given consent to data processing to the respective provider of the social network, the legal basis of the processing extends to Art. 6 para. 1 a, Art. 7 GDPR.

We are jointly responsible with LinkedIn for the personal content of our company profile. Data subject rights can be asserted against LinkedIn Inc. as well as against us.

We do not make any decisions regarding the data collected on LinkedIn's site using tracking technologies.

Further information on LinkedIn:

General information on data processing outside our website

Contact / Visitors

You can contact us. The data processed for this purpose (e.g. email data, your name) is necessary to enable communication and to process your request. Other data that you provide to us makes it easier for us to address you personally or to process things better or more quickly.

These processes are based on Art. 6 para. 1 lit. b GDPR, insofar as this is necessary for the initiation or execution of a contract. Otherwise, the processing is based on our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR. Our legitimate interest is to respond to your request.

Suppliers, service providers & business partners

We use contact and communication data and other relevant personal data from our suppliers, service providers and business partners, insofar as these or their employees are natural persons. We process this data to conduct business relationships, communicate and maintain contacts. The provision of data is regularly required for the initiation, execution and billing of contracts, otherwise a contract cannot be concluded.

The processing is based on Art. 6 para. 1 lit. b GDPR, insofar as this is necessary for the initiation or execution of a contract. Insofar as it does not concern the initiation or fulfillment of a contract, the processing is based on our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR. Our legitimate interest is the handling of business cooperation and contact maintenance.

The storage period is based on the general limitation rules or the tax retention obligations.

Applications

You can apply to us by sending us your documents. We process the personal data provided in this context exclusively to process your application. The processing is necessary for the initiation of an employment relationship, furthermore to enable the relevant communication and to process your request.

In individual cases, we process - insofar as necessary for the initiation of the employment relationship - personal data that we have lawfully received from third parties (e.g. recruitment agencies) or obtained from publicly accessible sources (e.g. social networks or internet search engines).

These processes are based on Art. 6 para. 1 lit. b GDPR in conjunction with § 26 para. 1 BDSG.

We regularly store this data for a period of up to 6 months after completion of the application process. Storage beyond this only takes place if you have expressly consented to this pursuant to Art. 6 para. 1 lit. a GDPR.

There is no legal or contractual obligation to provide your data, but processing your application is not possible without providing the information.

Recipients of the above data

Within the scope of our above-mentioned activities, we work together with service providers, partners, authorities and other third parties who may receive personal data, including:

Service providers for hosting services
IT and telecommunications service providers
Logistics and delivery service providers
Service providers for file storage and disposal
Authorities and institutions

We only transmit your data to these recipients insofar as this is necessary for the fulfillment of a contract with you, we are subject to a legal obligation to do so or we have a legitimate interest in passing on your data. The legitimate interest can primarily consist in maintaining the operational organization or in asserting, exercising or defending legal claims. If you have any further questions, please contact the responsible body.

We generally do not pass on any personal data to recipients who are based outside the EEA in so-called third countries. Should such transfers take place in individual cases, we guarantee a secure level of protection pursuant to Chapter 5 of the GDPR, among other things, by concluding the contractual supplements currently recommended by the authorities and by agreeing on special protection mechanisms for your data; such data processing and its effects are documented and regularly subjected to a risk assessment.

Storage period

If we store your personal data, this is only done for a limited period of time and not longer than necessary. As a rule, we delete your data when it is no longer necessary for the processing purpose for which it was collected or there are other legal reasons that require deletion.

Insofar as we are subject to legal retention obligations that require longer retention, we store the data for this period, in particular to fulfill commercial and tax retention periods, which are between 2 and 10 years.

Other legal reasons for retention may consist in the fact that we must retain data for evidentiary purposes for the duration of the applicable limitation provisions. These periods are usually between 2 and 30 years.

If you have any further questions, please contact the above-mentioned responsible body.

Obligation to provide

Insofar as the personal data is required for the establishment and execution of the contractual relationship and the associated contractual or legal obligations, you must provide this data so that we can fulfill our performance obligations or legal obligations. Without the provision of the data, we may not be able to provide the service properly or completely.

Processing within our platform

Type and scope of processing

When you register for our platform, we process various personal data from you. You can see which data this is in the input fields during registration and later in your user account.

Purpose and legal basis

The processing of this data is based on Art. 6 para. 1 lit. b) GDPR, insofar as this data is necessary for contract execution. In addition, processing can be based on your consent pursuant to Art. 6 para. 1 lit. a) GDPR, insofar as you voluntarily store this data in your user account.

Storage period

We only store this data for as long as necessary for the respective purpose or until you revoke your consent. For specific information on the respective storage period, please contact us.

HubSpot API

Type and scope of processing

We use HubSpot API from HubSpot, Inc., Cambridge, Massachusetts, US, to access further services and data from HubSpot, Inc. This involves a transfer of your IP address to HubSpot, Inc. Please note that there is a separate section in this privacy policy for each additional service we use from HubSpot, Inc.

Purpose and legal basis

The use of HubSpot API is based on our legitimate interests, i.e. interest in optimizing our online offering pursuant to Art. 6 para. 1 lit. f. GDPR.

Storage period

The specific storage period of the processed data cannot be influenced by us, but is determined by HubSpot, Inc. Further information can be found in the privacy policy for HubSpot API: https://legal.hubspot.com/privacy-policy.

HubSpot Analytics

Type and scope of processing

We use HubSpot Analytics from HubSpot, Inc., Cambridge, Massachusetts, US, as an analysis service for statistical evaluation of our online offering. This includes, for example, the number of calls to our online offering, visited subpages and the length of stay of visitors.

HubSpot Analytics uses cookies and other browser technologies to evaluate user behavior and recognize users.

This information is used, among other things, to compile reports on the activity of the website.

Purpose and legal basis

The use of HubSpot Analytics is based on your consent pursuant to Art. 6 para. 1 lit. a. GDPR and § 25 para. 1 TDDDG.

We intend to transfer personal data to third countries outside the European Economic Area, in particular the USA. The data transfer to the USA is based on Art. 45 para. 1 GDPR on the basis of the adequacy decision of the European Commission. The participating US companies and/or their US subcontractors are certified under the EU-U.S. Data Privacy Framework (EU-U.S. DPF).

In cases where no adequacy decision of the European Commission exists (including US companies that are not certified under EU-U.S. DPF), we have agreed on other appropriate safeguards within the meaning of Art. 44 ff. GDPR with the recipients of the data. Unless otherwise stated, these are standard contractual clauses of the EU Commission pursuant to implementing decision (EU) 2021/914 of 4 June 2021. You can view a copy of these standard contractual clauses at https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32021D0914&from=EN.

In addition, we obtain your consent for such a third country transfer pursuant to Art. 49 para. 1 sentence 1 lit. a. GDPR, which you give via the consent in the consent manager (or other forms, registrations, etc.). We would like to point out that risks that are unknown in detail (e.g. data processing by security authorities of the third country, the exact scope and consequences of which we do not know, over which we have no influence and of which you may not become aware) may exist in the case of third country transfers.

Storage period

HubSpot Forms

Type and scope of processing

We have integrated HubSpot Forms on our website. HubSpot Forms is a service of HubSpot, Inc. and offers marketing automation software for marketing services and products, including SEO and content creation, lead management, email marketing and web analytics.

HubSpot Forms is used to store data entered in forms, e.g. when contacting us via a contact form. The data provided can be stored in our Customer Relationship Management System (CRM system).

In this case, your data is passed on to the operator of HubSpot Forms, HubSpot, Inc., Cambridge, Massachusetts, US.

Purpose and legal basis

We process your data with the help of HubSpot Forms for the purpose of processing the contact request and its handling pursuant to Art. 6 para. 1 lit. b. GDPR.

The use of HubSpot Forms and the integrated services is subject to our legitimate interest pursuant to Art. 6 para. 1 lit. f. GDPR, the optimization of our marketing measures and the improvement of our service quality on the website.

Storage period

HubSpot Pixel

Type and scope of processing

We use HubSpot Pixel from HubSpot, Inc., Cambridge, Massachusetts, US, to create so-called custom audiences, i.e. to segment visitor groups of our online offering, determine conversion rates and then optimize them. This happens in particular when you interact with advertisements that we have placed with HubSpot, Inc.

Purpose and legal basis

The use of HubSpot Pixel is based on your consent pursuant to Art. 6 para. 1 lit. a. GDPR and § 25 para. 1 TDDDG.

Storage period

Plausible Analytics

Web analytics

Type and scope of processing

We use Plausible Analytics CE from Plausible Insights OÜ, Västriku tn 2, 50403, Tartu, Estonia, as an analysis service for statistical evaluation of our online offering. This includes, for example, the number of calls to our online offering, visited subpages and the length of stay of visitors. This information is used, among other things, to compile reports on the activity of the website.

Plausible Analytics CE does not set cookies, does not store information in the browser and does not collect personal data from visitors.

Purpose and legal basis

The use of Plausible Analytics is based on legitimate interest pursuant to Art. 6 para. 1 lit. f. GDPR and § 25 para. 2 TTDSG.

Plausible Analytics CE is operated by our processor uscreen GmbH (Moritzstr. 14, 42117 Wuppertal) in a data center in Germany.

Storage period

Only anonymized data is stored.

Privacy Policy

Who is responsible and how can I reach you?

Controller

Data Protection Officer

What is this about?

Who receives my data?

Do you use cookies?

What rights do I have?

How is my data processed in detail?

Provision of the website

Contact form

Newsletter

Presence on social media platforms

Instagram page

LinkedIn page

General information on data processing outside our website

Contact / Visitors

Suppliers, service providers & business partners

Applications

Recipients of the above data

Storage period

Obligation to provide

Processing within our platform

HubSpot API

HubSpot Analytics

HubSpot Forms

HubSpot Pixel

Plausible Analytics