Privacy policy FRAMEN GmbH

We are very pleased about your interest in FRAMEN. With this privacy policy, we inform you about the nature, scope, and purpose of the personal data processed by us and your rights as a data subject.


I. GENERAL

§1 Person in charge

Responsible for data processing pursuant to Art. 4 No. 7 DSGVO is FRAMEN GmbH, Charlottenstraße 79/80, 10117 Berlin, Germany, phone: +49 30 2591 0, e-mail: info@framen.io (hereinafter also referred to as "we" or "us"), unless otherwise stated in this Privacy Policy.

We are jointly responsible with Facebook for the information collected subject to your

via so-called Facebook Business Tools of Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"). You can find more information about data processing at the appropriate place in this privacy policy. Information about Facebook and the contact details of the data protection officer, as well as further information about how Facebook processes personal data, including the legal basis and the options for exercising your rights as a data subject vis-à-vis Facebook, can be found in Facebook's data policy. We have entered into a Shared Responsibility Agreement (Article 26 GDPR) with Facebook, which sets out our respective responsibilities for fulfilling our obligations under the GDPR with respect to joint processing. Thereafter, we are required to provide the above information and Facebook has assumed responsibility for the other data subject rights under Art. 15-20 of the GDPR.

§2 Call the website

When you use our offer, we automatically collect and process various data, such as:

  • Information about the accessing terminal device and the software used

  • Date and time of access

  • Cookies and pseudonymous IDs (special category Absolutely necessary)

  • Websites from which the user accesses our website or which the user accesses via our website

  • IP address

The at least temporary storage of the IP address is technically necessary to enable delivery of the website to the user's computer. The legal basis for data processing is Art. 6 para. 1 lit. b DSGVO. Our servers also store your IP address for up to 14 days for our own security purposes (Art. 6 para. 1 lit. f DSGVO).

If you download our app from an app store of a third-party provider (such as iTunes, Google, etc.) and, according to the applicable terms of use of such provider, we become your contractual partner for the purchase of the app, we process the data provided to us by the third-party provider to enable you to use the app. The legal basis for the data processing is Art. 6 para. 1 lit. b DSGVO.

If you downloaded our app from an app store of a third-party provider (such as iTunes, Google, etc.) and, according to the applicable terms of use of such provider, we are your contractual partner for the purchase of the app, we process the data provided to us by the third-party provider to enable you to use the app. The legal basis for the data processing is Art. 6 para. 1 lit. b DSGVO.

§3 Access permissions

Subject to your consent, our app uses the following permissions for the purposes listed behind them, which give it access to certain features of your mobile device:

  • Album / Photos - Upload your own content for display on your own screens

  • Camera - To connect a screen to the software

  • Location - To check the localization when creating the screen.

  • Memory - Temporary App Settings

The legal basis for data processing is Art. 6 para. 1 lit. a DSGVO. You can revoke your consent at any time with effect for the future in the app settings.

§4 Registration

For the use of certain services a login by means of an existing user account is required. A corresponding registration is necessary for the user account. The data collected during registration is processed for the purpose of providing the requested service. The legal basis for the data processing is Art. 6 para. 1 lit. b DSGVO.

§5 Services subject to payment

When you subscribe to a service that requires payment, we process the personal data you provide, including contact data, for the execution and fulfillment of the contract, as well as for the enforcement of legal claims or receivables. The legal basis for the data processing is Art. 6 (1) lit. b DSGVO or - if you are not a contractual partner yourself, but act as a contact person for the contractual partner - Art. 6 (1) lit. f DSGVO. The same applies to such processing operations that are necessary for the implementation of pre-contractual measures, for example in cases of inquiries about our products or services. In addition, we are required to process certain data that we have received from you in connection with the conclusion of a contract in order to fulfill obligations under tax law. The legal basis for data processing is Art. 6 (1) lit. c DSGVO. For VAT reasons, this also includes the storage of the IP address of the device from which you accessed our website when concluding the contract.

If you choose the payment method purchase on account when concluding a contract with costs, we will perform a credit check based on your consent and our legitimate interest to avoid the risk of unpaid receivables, in order to check the creditworthiness. The legal basis for data processing is Art. 6 (1) a DSGVO in the case of consent given and Art. 6 (1) f DSGVO in all other cases. We use the services of Schufa Holding AG to assess the risk associated with the advance payment. Details about how the score is calculated can be found here: https://www.schufa.de/de/datenschutz-dsgvo/.

In this regard, we always take reasonable steps to safeguard your rights and freedoms as well as your legitimate interests, which include at least the right to obtain the intervention of a person on the part of the controller, to express your point of view and to contest the decision. You have the right to request information about the logic involved and the consequences of the processing that can be expected for you.

In the event that you use a service that requires payment, we also offer various payment methods from the following providers, each of which is responsible for data processing pursuant to Art. 4 No. 7 DSGVO:

Klarna

We have integrated Klarna (Klarna AB, Sveavägen 46, 111 34 Stockholm, Sweden) on this website. Klarna is an online payment service provider that enables purchase on account or flexible installment payment. Furthermore, Klarna offers additional services, such as buyer protection or an identity and credit check. If the data subject selects either "purchase on account" or "installment purchase" as a payment option during the ordering process in our online store, data of the data subject is automatically transmitted to Klarna. By selecting one of these payment options, the data subject consents to this transmission of personal data, which is necessary for the processing of the purchase on account or installment purchase or for identity and credit checks.

The personal data transmitted to Klarna is usually the first name, last name, address, date of birth, gender, e-mail address, IP address, telephone number, cell phone number and other data necessary for the processing of an invoice or installment purchase. Also necessary for the processing of the purchase contract are such personal data that are related to the respective order. In particular, there may be a mutual exchange of payment information, such as bank details, card number, validity date and CVC code, number of items, item number, data on goods and services, prices and tax levies, information on previous purchasing behavior or other information on the financial situation of the person concerned.

The transfer of data is intended in particular for identity verification, payment administration and fraud prevention. We will transfer personal data to Klarna in particular if there is a legitimate interest for the transfer. The personal data exchanged between Klarna and us will be transmitted by Klarna to credit reporting agencies. The purpose of this transmission is to check identity and creditworthiness. Klarna also discloses the personal data to affiliated companies (Klarna Group) and service providers or subcontractors to the extent necessary to fulfill contractual obligations or to process the data on behalf. In order to decide on the establishment, implementation or termination of a contractual relationship, Klarna collects and uses data and information about the past payment behavior of the data subject as well as probability values for his behavior in the future (so-called scoring). The scoring is calculated on the basis of scientifically recognized mathematical-statistical methods.

The data subject has the option to revoke the consent to the handling of personal data at any time vis-à-vis Klarna. A revocation does not affect personal data that must necessarily be processed, used or transmitted for (contractual) payment processing.

Klarna's applicable privacy policy can be found at https://cdn.klarna.com/1.0/shared/content/policy/data/de_de/data_protection.pdf.

PayPal

We have integrated the payment option PayPal on this website. PayPal is an online payment service provider of PayPal (Europe) S.à.r.l. & Cie. S.C.A., 22-24 Boulevard Royal, 2449 Luxembourg, Luxembourg. Payments are processed via so-called PayPal accounts, which represent virtual private or business accounts. In addition, PayPal offers the possibility to process virtual payments via credit cards if a user does not maintain a PayPal account. A PayPal account is managed via an email address, which is why there is no classic account number. PayPal makes it possible to initiate online payments to third parties or to receive payments as well. PayPal also assumes trustee functions and offers buyer protection services.

If the data subject selects "PayPal" as a payment option during the ordering process in our online store, data of the data subject will be automatically transmitted to PayPal. By selecting this payment option, the data subject consents to the transmission of personal data required for payment processing. The personal data transmitted to PayPal are usually first name, last name, address, e-mail address, IP address, telephone number, cell phone number or other data necessary for payment processing. Also necessary for the processing of the purchase contract are such personal data that are related to the respective order. The purpose of transmitting the data is payment processing and fraud prevention. We will transmit personal data to PayPal in particular if there is a legitimate interest for the transmission. The personal data exchanged between PayPal and the for us may be transmitted by PayPal to credit reporting agencies. This transmission is for the purpose of checking identity and creditworthiness. PayPal may pass on the personal data to affiliated companies and service providers or subcontractors, insofar as this is necessary for the fulfillment of contractual obligations or the data is to be processed on behalf. The data subject has the possibility to revoke the consent to the handling of personal data at any time vis-à-vis PayPal. A revocation does not affect personal data that must be processed, used or transmitted mandatorily for (contractual) payment processing.

PayPal's applicable privacy policy can be found at https://www.paypal.com/de/webapps/mpp/ua/privacy-full.

Stripe

If you choose a payment method of the payment service provider Stripe, the payment will be processed by the payment service provider Stripe Payments Europe Ltd, Block 4, Harcourt Centre, Harcourt Road, Dublin 2, Ireland, to whom we pass on your information provided during the ordering process, together with information about your order (name, address, account number, bank code, credit card number, if applicable, invoice amount, currency and transaction number). The transfer of your data takes place exclusively for the purpose of payment processing with the payment service provider Stripe Payments Europe Ltd. For more information about the data protection of Stripe, please visit: https://stripe.com/de/terms.

§6 Media

As a logged-in user, you have the option of uploading content in the Media area. If personal data is part of the uploaded content, we will process it on your behalf and according to your instructions within the scope of the contractual service provision. In this case, you are responsible for the processing of personal data pursuant to Art. 4 No. 7 DSGVO. You have the option to delete the content in the media area at any time.

§7 Newsletter

We also use your e-mail address collected in the course of registration or in the course of contract performance to inform you by e-mail about our own similar goods or services, provided that we pointed this out to you when collecting the e-mail address and you have not objected to this. In this case, the processing of the e-mail address is based on our legitimate interest in advertising our offers. The legal basis is Art. 6 para. 1 lit. f DSGVO. You have the option to object to the sending of this information about further offers at any time, e.g. by clicking on the unsubscribe link provided for this purpose in each of these emails.

If you have ordered our newsletter, we will also use your email address to send you the newsletter you ordered. The legal basis for the data processing is Art. 6 para. 1 lit. a DSGVO. You can revoke your consent at any time with effect for the future or unsubscribe from the ordered newsletter, e.g. by clicking on the unsubscribe link provided for this purpose in each newsletter.

So-called tracking pixels are integrated into the e-mails for the purpose and in our interest of being able to optimize our newsletter. This provides us with information about which browser and operating system is being used, which IP address is currently being accessed and, at the same time, who the provider is. Furthermore, it is recognized whether the e-mail was read and whether the link integrated in the e-mail was subsequently clicked and the respective website was visited via this IP address. In addition, the number of times the website is accessed is counted and the corresponding time of day when the e-mail was retrieved and the access was made is recorded. The approximate location of the user is also transmitted. If you do not wish this, you can unsubscribe from the newsletter at any time as described above. The legal basis for the data processing is Art. 6 para. 1 lit. a or Art. 6 para. 1 lit. f DSGVO.

§8 Geo-localization

For the purpose and in the interest of displaying content with a regional reference to your location, we process your IP address shortened to the geographical level of the federal states / regions. The geographical information obtained in this way can in no way be used to draw conclusions about the specific location of a user. The legal basis for the data processing is Art. 6 para. 1 lit. f DSGVO.

§9 Your contact

When you contact us, e.g. via one of our contact forms or by e-mail, the data you provide (your e-mail address, your name, and your telephone number, if applicable) will be processed by us in order to deal with your inquiry. We delete the data accruing in this context when it is no longer required for the aforementioned purpose, provided that the deletion does not conflict with any statutory retention obligations. The legal basis for data processing is Art. 6 (1) sentence 1 lit. f DSGVO.

§10 Place of processing

We also process personal data in countries outside the European Economic Area ("EEA"), including the USA. In order to ensure an adequate level of data protection, we use the standard contractual clauses of the EU Commission pursuant to Art. 46 (2) (c) of the GDPR for the contractual relationships with the services used in third countries, unless an adequacy decision of the European Commission exists for the respective third country:

Standard contractual clauses

§11 Storage period

We process personal data only as long as this is necessary for the respective purpose stated in this data protection declaration. The personal data will then be deleted, provided that no legal retention periods conflict with data deletion.

II. PRIVACY

We have also integrated third-party services into our website or app, but these are only loaded and activated if you [BP1] allow this through corresponding

Cookies and similar technologies, by means of which information is retrieved or stored in your terminal device, require your prior consent.

Exceptions to this are a few cookies or comparable technologies that are absolutely necessary so that we can provide you with our website or our app and its content as intended (special category "absolutely necessary"), as well as certain data processing that is based on certain legitimate interests pursuant to Art. 6 (1) f DSGVO. The setting of cookies or data processing in these constellations does not require consent, but we give you the opportunity to object to the data processing that we base on Art. 6 (1) (f) DSGVO.

In order to map this process for you in a user-friendly way with all legal requirements but also all necessary information, a window ("Privacy") opens during your first visit to our website or app in which you have the option, through appropriate settings, to give your consent to third party providers to store and/or retrieve information in your device as well as to process personal data for specific purposes, to refuse this in each case or - insofar as the processing of personal data is based on the legal basis of legitimate interests (Art. 6 para. 1 lit. f DSGVO) - to object. The privacy settings you have made will be stored in a cookie (special category Absolutely necessary) on your terminal device. You have the option at any time to change your privacy settings with effect for the future, i.e. to revoke consent given or to object to data processing on the basis of legitimate interests.

In the following, we will inform you about the use of cookies or comparable technologies and the processing of personal data by the third-party providers we use, which may take place depending on the privacy settings you have made. You can also find more information about privacy and how it works in our FAQ.

§12 Third-party

The third-party providers whose services we integrate help us to improve our website. An overview of all possible third-party providers can be found at the appropriate place in the privacy policy. There you also have the option to refuse the data transfer to all or individual third-party providers as such (i.e. regardless of the purpose) or to give or revoke your consent for this. The term "third-party provider" is not to be understood in the sense of Art. 4 No. 10 DSGVO (third party). Rather, among the third-party providers listed in the privacy are also our processors within the meaning of Art. 28 DSGVO, which are not named in this privacy policy, as we remain responsible for data processing in these cases in accordance with Art. 4 No. 7 DSGVO. You can recognize our processors by marking them accordingly in the Privacy Policy under the link Third Party Providers. For these reasons, more third-party providers are regularly listed by name in the Privacy Policy than in this Privacy Policy.

§13 Store and/or retrieve information on a device/special category Absolutely required

Cookies are small files that your browser stores on your device in a designated directory. Among other things, they can be used to determine whether you have visited a website before. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a string of characters by which websites and servers can be assigned to the specific Internet browser in which the cookie was stored. This enables the websites and servers visited to distinguish the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified via the unique cookie ID. Cookies cannot identify you as a person without additional information.

When using apps, a technology comparable in function is used instead of the cookie, such as the operating system-specific advertising ID, vendor ID or a randomly generated user ID.

In order to be able to offer our services and third-party services integrated into our website and requested by you, the use of certain cookies and similar technologies by us or by third-party providers is necessary (special category "absolutely necessary"). Furthermore, the settings made by you in the privacy or given consents and objections are stored in cookies on your terminal device. The use of these cookies is necessary for the service you have requested. You can find more information about the special category "absolutely necessary" and the third-party providers in the privacy policy.

Unless otherwise specified, other cookies and similar technologies are set only subject to your consent to store and/or retrieve information on a device.

Cookies and similar technologies are also sometimes required to collect personal data or to store personal data on your terminal device in order to subsequently process personal data, among other purposes,

  • Select simple displays,

  • Create a personalized ad profile,

  • select personalized ads,

  • Create a personalized content profile

  • select personalized content,

  • Measure display performance,

  • Measure content performance,

  • use market research to gain insights into target groups, and

  • Develop and improve products

(so-called "IAB processing purposes"). However, as explained above, this only takes place if you have given us or the respective third-party provider your consent in the privacy settings a) to the storage and/or retrieval of information in the terminal device (except for processing without cookies or comparable technologies and except for the special category of absolutely necessary) and b) to the processing of personal data for one of the aforementioned purposes or have not objected to the data processing.

You can find more information about the IAB processing purposes, the individual third-party providers and the legal basis of the data processing below at the appropriate place in this privacy policy or in the privacy policy.

Without your consent to the storage and/or retrieval of information on your device, not all functions of our website may be fully usable. Processing of personal data for the IAB processing purposes, which are collected or processed by means of cookies or comparable technologies, is always only possible with consent to the storage / retrieval of information in the terminal device (except for special category Absolutely necessary), regardless of whether you have given your consent to the processing for the respective IAB processing purpose or have not objected to it.

You can revoke your consent to the storage and/or retrieval of information on a device at any time in your privacy settings.

Cookies that have already been set can also be deleted by you at any time via an Internet browser or other software programs. This is possible in all common Internet browsers. Please note that in this case, the privacy settings you have made will also be deleted and would have to be made again when you visit our website again. The duration of the cookies used is limited to a maximum of one year, unless otherwise specified.

§14 Create a personalized ad profile

If you have given your privacy consent for this, we use services for the purpose of tailoring the ads served to your interests based on your usage behavior. For this purpose, a profile of your usage is created with information about your activities, interests, visits to websites or use of applications, demographic information or location. The legal basis for the data processing is Art. 6 para. 1 lit. a DSGVO. You have the option to revoke any consent given at any time in the privacy settings. For the aforementioned purposes, we also use the services of third parties listed below, who are responsible for the data processing taking place via the service in accordance with Art. 4 No. 7 DSGVO. Further information on data processing by these providers and your rights as a data subject can be found in the privacy statements of the providers linked below:

§15 Select personalized ads

If you have given your consent for this in your privacy, we use services for the purpose of being able to play ads that are interesting for you on the basis of a personalized ad profile that you have created, subject to your consent. The legal basis for the data processing is Art. 6 para. 1 lit. a DSGVO. You have the option to revoke your consent in the privacy settings at any time. In this context, we also use the services of third parties listed below, who are responsible for the data processing taking place via the service in accordance with Art. 4 No. 7 DSGVO. Further information on data processing by the providers used and your rights as a data subject can be found in the privacy statements of these providers linked below:

In order to display the personalized ads on our website or in our app in the correct size and in a format supported by your device and to be able to forward you to the corresponding target page when you click on the ad, your IP address and information about your device type are also processed by the respective third-party provider. This is the special category of "providing ads or content technically".

§16 Сreate a personalized content profile

For the purpose and in our interest to align the selection of content (not advertising) in our offer to your usage behavior and consequently to your presumed interests, we create a profile of your usage with information about the activities, interests and visits to websites or the use of applications, demographic information or location. The legal basis for the data processing is Art. 6 (1) lit. f DSGVO. You have the option at any time to refuse the creation of personalized content profiles in the privacy settings and thus object to data processing for this purpose. For this purpose, we use the services of third-party providers who act on our behalf and according to our instructions (so-called order processors). We remain responsible in accordance with Art. 4 No. 7 DSGVO. You can recognize our processors by the corresponding marking in the privacy policy.

In addition, we make use of the services of the third-party providers listed below, which are responsible for the data processing via the service in accordance with Art. 4 No. 7 DSGVO, provided that you have given your consent in the privacy policy. The legal basis for data processing in these cases is Art. 6 para. 1 lit. a DSGVO. You have the option to revoke any consent you have given in the privacy settings at any time. For more information about data processing by the third party providers responsible for their own data and about your rights as a data subject, please refer to the privacy statements of these providers linked below:

§17 Selecting personalized content

For the purpose and in our interest to make our offer more interesting for you, we process information about your usage behavior or other historical usage data, including previous activities, interests, visits to websites or the use of applications, location or demographic information, in order to be able to play you selected content according to this information. The legal basis for the data processing is Art. 6 para. 1 lit. f DSGVO. You have the option to object to data processing for these purposes at any time in the privacy settings.

In addition, we use the services of the following third party providers, which are responsible for the data processing via the service in accordance with Art. 4 No. 7 DSGVO, provided that you have given your consent in the privacy policy. The legal basis for data processing in these cases is Art. 6 para. 1 lit. a DSGVO. You have the option to revoke any consent you have given in the privacy settings at any time. For more information about data processing by the third party providers responsible for their own data and your rights as a data subject, please refer to the privacy statements of the providers linked below:

In order to be able to display the personalized content on our website or in our app in the correct size and in a format supported by your device, the respective third-party provider also processes your IP address and information about your device type. This is a special category of "providing ads or content technically".

§18 Measure display performance

Assuming your privacy consent, we use services for the purpose of measuring ad performance. These services measure, among other things, whether and how ads were displayed to a user and how the user interacted with them, whether an ad is displayed in an inappropriate editorial environment (brand-unsafe), and determine the percentage of time the ad could have been seen, including the duration (ad-perception chance). They also generate reports on ads, including their effectiveness and performance, on the interaction of users with ads, based on data measured in the course of the user's interaction with that ad. The legal basis for the data processing is Art. 6 (1) lit. a DSGVO. You have the option to revoke your consent in the privacy settings at any time.

We also use the services of third parties listed below, who are responsible for the data processing taking place via the service in accordance with Art. 4 No. 7 DSGVO. Further information on data processing by these providers and your rights as a data subject can be found in the privacy statements of these providers linked below:

* Using the example of Facebook Conversion Tracking: If we have received your consent, we use the "Custom Audiences" pixel of the social network Facebook within our website. So-called tracking pixels are integrated on our pages. When you visit our pages, a direct connection is established between your browser and the Facebook server via the tracking pixel. Facebook thereby receives from your browser, among other things, the information that our page was called up from your end device. If you are a Facebook user, Facebook can assign the visit to our pages to your user account. Facebook can then measure the performance of content and ads, as well as target ads on Facebook. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Facebook. We can only select which segments of Facebook users (such as age, interests) should be shown our ads. This is not the service "Facebook Custom Audiences via the customer list". We do not transmit any customer data to Facebook, in particular no email addresses - neither encrypted nor unencrypted. The "advanced matching" function is deactivated. The use of "Facebook Cus-tom Audiences via the pixel method" also requires your additional privacy consent to retrieve and/or store information on a device for the third-party provider "Facebook Conversion Tracking".

§19 Measure content performance

Subject to your consent, we use services for the purpose of measuring the performance of content on our website. This involves measuring and presenting in a report how content is delivered to users and how they have interacted with it. The legal basis for the data processing is Art. 6 para. 1 lit. a DSGVO. You have the option to revoke your consent in the privacy settings at any time. We also use the services of third parties listed below, who are responsible for the data processing taking place via the service in accordance with Art. 4 No. 7 DSGVO. For more information on data processing by these providers and your rights as a data subject, please refer to the privacy statements of the providers linked below:

* Using the example of Facebook Conversion Tracking: If we have received your consent, we use the "Custom Audiences" pixel of the social network Facebook within our website. So-called tracking pixels are integrated on our pages. When you visit our pages, a direct connection is established between your browser and the Facebook server via the tracking pixel. Facebook thereby receives from your browser, among other things, the information that our page was called up from your end device. If you are a Facebook user, Facebook can assign the visit to our pages to your user account. Facebook can then measure the performance of content and ads, as well as target ads on Facebook. We would like to point out that we, as the provider of the pages, have no knowledge of the content of the transmitted data or its use by Facebook. We can only select which segments of Facebook users (such as age, interests) should be shown our ads. This is not the service "Facebook Custom Audiences via the customer list". We do not transmit any customer data to Facebook, in particular no e-mail addresses - neither encrypted nor unencrypted. The "advanced matching" function is deactivated. The use of "Facebook Cus-tom Audiences via the pixel method" also requires your additional privacy consent to retrieve and/or store information on a device for the third-party provider "Facebook Conversion Tracking".

§20 Use market research to gain insights into target groups

Subject to your consent, we use services for the purpose of gaining insights about audiences for advertising and content. This involves aggregated reports for advertisers or their representatives about the audiences reached by their ads, which are obtained on the basis of survey panels or similar methods. Furthermore, aggregated reports are created for service providers about the target groups that were reached by or interacted with the content and/or ads on their services and which were obtained on the basis of survey panels or similar methods. The reports do not allow any conclusions to be drawn about a specific or identifiable person. However, information about your usage behavior is processed in order to create these reports. In addition, offline data is assigned to an online user for market research purposes in order to gain insights into target groups, insofar as providers have declared that they will match and merge offline data sources. The legal basis for the data processing is Art. 6 para. 1 lit. a DSGVO. You have the option to revoke your consent in the privacy settings at any time.

We also use the services of third parties listed below, who are responsible for the data processing taking place via the service in accordance with Art. 4 No. 7 DSGVO. Further information on data processing by these providers and your rights as a data subject can be found in the privacy statements of the providers linked below:

§21 Develop and improve products

Subject to your consent, we also use services for the purpose of developing and improving products, e.g. by adding new functions. For this purpose, information about your usage behavior is processed. The legal basis for the data processing is Art. 6 para. 1 lit. a DSGVO. You have the option to revoke your consent in the privacy settings at any time.

We also use the services of third parties listed below, who are responsible for the data processing taking place via the service in accordance with Art. 4 No. 7 DSGVO. Further information on data processing by these providers and your rights as a data subject can be found in the privacy statements of the providers linked below:

§22 Ensuring security, preventing fraud, and correcting errors (special category)

For the purposes of ensuring security, preventing fraud and rectifying errors, the third-party providers listed in the privacy under the relevant special category process information that they use to ensure that data is transmitted securely, to detect and prevent harmful, fraudulent, invalid or illegal activities, and to ensure the correct and efficient operation of systems and processes - including monitoring and improving the performance of systems and processes - within the scope of the permitted processing purposes. This is necessary to ensure the security of the respective data processing, to prevent fraud and to be able to correct errors. The information processed for this purpose may include automatically sent device properties for identification, precise geolocation data and data obtained by reading device properties for identification without separate disclosure and/or opt-in. This assumes, of course, as far as processing for the purposes of ensuring security, preventing fraud and fixing bugs by third party providers for their own purposes is concerned, that you have given your consent to the respective third party provider to process personal data for a specific purpose in the first place or have not objected to the data processing.

§23 Affiliate marketing

If you have accessed our website via an advertising banner from an external website, we receive information from the operator of the external website ("affiliate") that a user has accessed our offer via the external site. This is the product ID assigned to the advertised offer as well as the identification number of the affiliate (affiliate ID) and a user ID created from any sequence of numbers. This information is stored by us subject to your consent to the storage and/or retrieval of information in the terminal device in the privacy in a cookie on your terminal device. Should you order the offer on our website within 30 days, this information will be transmitted automatically and encrypted to the affiliate upon completion of the ordering process. Upon completion of the ordering process, but no later than after 30 days, the cookie is automatically deleted. The affiliate can only recognize from the information that a user has reached our website from the external website via the advertising banner and has ordered the advertised product there. This does not result in the processing of personal data. For information on the processing of personal data by the affiliate, please refer to the affiliate's privacy policy on its website.



III. SOCIAL MEDIA AND THIRD-PARTY CONTENT (SOCIAL NETWORKS, VIDEOS)
§24 Facebook fan pages

We use Facebook Fanpages under the following links, for which we are jointly responsible with Facebook Ireland Limited: https://www.facebook.com/framen.io.

In joint responsibility with Facebook, we analyze how you use our Fanpage (Page Insights). You can obtain the information required by the GDPR on data processing in the context of Page Insights from Facebook; currently by name in Facebook's privacy policy at https://www.facebook.com/legal/terms/information_about_page_insights_data.

Facebook also provides you with the relevant contents of the joint responsibility processing agreement concluded between Facebook and us pursuant to Article 26 of the GDPR; currently at the following link: https://www.facebook.com/legal/terms/page_controller_addendum. You may exercise your right to lodge a complaint with any competent supervisory authority and seek redress there.

According to the GDPR, you have the right to object to the processing of your data. You can learn more about this and other data subject rights in the Facebook privacy notices linked above.

For Page Insights on our Facebook Fanpages, Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland acts as the common point of contact and processes all requests to assert data subject rights.

As part of the Page Insights, we ourselves only receive anonymized statistics - we do not have access to personal data processed by Facebook. The processing of anonymized data by us is based on legal requirements that allow us to process personal data because we have an overriding legitimate interest in gaining a better understanding of the interests of visitors to our Fanpage (Art. 6 (1) lit. f DSGVO).

Facebook offers various community functions on the fan pages with which you can interact with other users, for example by posting articles, leaving comments, or liking or sharing articles. We would like to point out that these areas are publicly accessible and all personal information that you post there or provide when registering can be viewed by others. We cannot control how other users of the fan pages use this information. In particular, we cannot prevent unsolicited messages from being sent to you.

§25 Display third-party content (social networks, videos)

For the purpose of enhancing the user experience in our offer, we also embed services of the providers listed below, who are responsible for the data processing according to Art. 4 No. 7 DSGVO. Subject to your privacy consent, your browser establishes a direct connection to the server of the respective provider. In doing so, the provider always processes your IP address, which is necessary for establishing the connection to the provider's server and playing out the content. The legal basis for the integration of these services is Art. 6 para. 1 lit. a DSGVO. You can revoke your consent at any time with effect for the future in the privacy settings. If you have not given consent to "Show third-party content (social networks, videos)" in the privacy settings or have revoked consent given, you will see a placeholder instead of the third-party content with a note and the option to give your consent by clicking on the placeholder and to have the third-party content displayed. If you make use of this option, your consent will be stored in your privacy. You have the option to revoke your consent in the privacy at any time.

Information on data processing by the respective provider can be found in the privacy policy of the respective provider.

 
 
IV. YOUR RIGHTS

§26 contact details

Please contact our data protection officer at any time if you have any questions or suggestions regarding data protection or if you wish to assert your rights as a data subject:

FRAMEN GmbH

Privacy

Charlottenstrasse 79/80

10117 Berlin

privacy@framen.com

As far as data processing in connection with Page Insights on our Facebook Fanpage (https://www.facebook.com/framen.io) is concerned, Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland acts as a common point of contact and processes all requests to assert the aforementioned rights. Further information on

and answers to frequently asked questions can also be found in our FAQ.

§27 Your rights as a data subject

Information and rectification

You can obtain information from us at any time and free of charge about whether personal data about you is being processed by us and also specifically which data about you is being stored, as well as request a copy of the stored data. You can also have incorrect data corrected and completed.

Deletion, restriction, and the right to be forgotten

You can request the deletion and restriction of your personal data. Insofar as the deletion of your personal data is contrary to statutory retention obligations, your data will be marked with the aim of restricting its future processing.

Data portability

Where applicable, you also have the right to have the personal data concerning you transferred to you or to another controller in a structured, commonly used and machine-readable format, provided that the processing is based on consent or a contract and is carried out with the help of automated processes. However, this does not apply if the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. You also have the right to obtain that the personal data be transferred directly from one controller to another controller, insofar as this is technically feasible and insofar as this does not adversely affect the rights and freedoms of other persons.

Revocation / Objection

You can revoke your consent at any time with effect for the future at the above-mentioned contact address. Contact address.Furthermore, you have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out on the basis of a legitimate interest. This also applies to profiling based on these provisions. We shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the assertion, exercise or defense of legal claims.If we process personal data for the purpose of direct marketing, you have the right to object at any time to the processing of personal data for such marketing by contacting us at the above address. Contact address. This also applies to profiling, insofar as it is related to such direct marketing. In addition, you have the right, on grounds arising from your particular situation, to object to the processing of personal data concerning you which is carried out by us for scientific or historical research purposes or for statistical purposes, unless such processing is necessary for the performance of a task in the public interest.

Right of appeal

Furthermore, you have the right to lodge a complaint with the competent supervisory authority and the possibility of legal remedies. The supervisory authority to which the complaint has been submitted will inform the complainant of the status and outcome of the complaint, including the possibility of a judicial remedy.

Status: December 7, 2021