1. INTRODUCTION
Impalement (“Impalement” or “We”, “Our” or “Us”) care about Your privacy and We always handle Your personal information as set out in the European Union’s General Data Protection Regulation (”GDPR”). We are obliged to collect and process personal data in accordance with the GDPR, regardless whether Our users are based within the EU or not. We take Our obligations seriously and always collects personal data responsibly and with Your privacy in mind.
This privacy policy explains how We process information that can be used to directly or indirectly identify an individual (”Personal Data”) collected through the use of Our website impalement.ch (“Website”).
Personal Data is defined in Article 4 (1) of the GDPR:
‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
2. COLLECTION OF DATA
The Website only collects, by itself or through third parties, Personal Data which has been voluntarily submitted by You (e-mail address) or collected through cookies or Your use of the Website.
With your consent we collect Personal Data and Usage Data and use it for the purposes set out in the policy, see section 3.
The term “Usage Data” shall mean information collected automatically through the use of the Website (or third-party services employed on this Website), which can include: the IP addresses or domain names of the computers utilized by the person who use the Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by You, the various time details per visit (e.g., the time spent on each page within the Website) and the details about the path followed within the Website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or Your IT environment.
3. PURPOSE OF AND LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
The purposes of processing
We use Usage Data and Personal Data for the following purposes:
– managing contacts
– sending newsletters and messages
– analytics and
– remarketing and behavioral targeting (i.e. market Us to You in other channels through the use of pixels or cookies etc.)
For more detailed information about such purposes and information of the specific Personal Data and Usage Data used for each purpose, see the relevant section below.
Legal basis of processing
Our legal basis of processing Usage Data and Personal Data for the purposes set out in this document and sharing such data with any third-party service providers listed below, is Your consent.
3.1. Managing contacts and sending newsletters and messages
We use Your email address to send You newsletters/messages and market Our products.
We use Roundcube to administrate and send newsletter to the email addresses We collect.
Roundcubeis an email address management and message sending service
3.2. Remarketing and behavioral targeting
This type of service allows Us and Our partners to inform, optimize and serve advertising based on past use of the Website by You.
The above activity is performed by tracking Your Usage data and by using cookies. The collected information is transferred to the partners (listed below) that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists. The service providers listed below may use cookies, web beacons, and other storage technologies to collect or receive information from Our Website and elsewhere on the internet and use that information to provide measurement services and target ads.
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of Our Website with the Facebook advertising network.
Personal Data collected: cookies and email address.
Place of processing: United States – Privacy Policy
3.3. Analytics
The services contained in this section enable Us to monitor and analyze web traffic and can be used to keep track of a user’s behavior.
Google AdWords conversion tracking (Google Inc.)
Google AdWords conversion tracking is an analytics service provided by Google Inc. (“Google”) that connects data from the Google AdWords advertising network with actions performed on Our Website.
Personal Data collected: cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google. Google utilizes the Personal Data and Usage Data collected to track and examine the use of our Website, to prepare reports on its activities and share them with other Google services.
Google may use the Personal Data and Usage Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Facebook Ads conversion tracking (Facebook, Inc.)
Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on Our Website.
Personal Data collected: cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Twitter Ads conversion tracking (Twitter, Inc.)
Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on Our Website.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
3.4. Cookies
We use information collected through cookies to:
– to customize content
– improve website functionality and
– for the purposes set out above in this section 3.
As we mentioned above, We use third party service providers, listed in this section 3, who may place cookies, webbeacons etc on Your device.
By accepting this Privacy Policy You agree to Our use of cookies. For further, and more detailed, information about cookies and Our use of cookies see Our cookie policy.
4. SHARING AND TRANSFER OF PERSONAL DATA
We may only disclose Usage Data and Personal Data insofar as reasonably necessary for the purposes set out above in this Privacy Policy.
In some cases, the Usage Data and Personal Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers within the EU, IT companies, communications agencies) appointed, if necessary, as data processors by Us.
We do NOT sell Personal Data to any third party without Your prior consent.
5. HOW LONG DO WE KEEP PERSONAL DATA?
In general, Personal Data shall be processed and stored for as long as required by the purpose it has been collected for.
We may be allowed to retain Personal Data for a longer period if You have given consent to such processing, as long as such consent is not withdrawn. Furthermore, We may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
For the specific retention periods for the Personal Data collected about You, see below.
E-mail address (for sending newsletters and marketing/remarketing)
We will hold Your e-mail address for a period of six (6) years.
You have the opportunity to opt out from receiving newsletters and marketing e-mails from Us.
Cookies
We keep cookies and information collected through the use of cookies in accordance with what is stated in Our cookie policy.
6. RECTIFICATION, ACCESS AND ERASURE OF PERSONAL DATA
You may request access to and a copy of the Personal Data that We process in relation to You if You would like to know and verify the information We have on You.
You have the right to correct inaccurate and/or incomplete information about Yourself. You have the right to be forgotten, which means You may request the deletion of Your Personal Data insofar as this Personal Data is no longer necessary for the purpose it was collected, or We have a legitimate interest to hold it. At Your request all our Personal Data will be erased as required by applicable law. You also have a right to withdraw any consent You have given, as well as ask Us to cease Our marketing efforts towards You.
7. DATA PORTABILITY
It is also Your right to receive the Personal Data which You have given to Us, in a structured, commonly used and machine-readable format and You have the right to transmit such Personal Data to another controller. This provision is applicable provided that the data is processed by automated means and that the processing is based on the Your consent.
8. CHANGES TO THIS PRIVACY POLICY
Please note that this Privacy Policy may change from time to time. If We change this Privacy Policy in ways that affect how We use Your personal information, We will advise You of the choices You may have as a result of those changes. We will also inform You of that this Policy Privacy has changed.
9. CONTACT INFORMATION AND COMPLAINTS
If You have any questions regarding this Privacy Policy or if You wish to exercise Your rights, please contact Us at:
Impalement
Represented by: Jens Förster
AMP Studio, Niersstr. 19, 47169 Duisburg, Germany
Phone: +49 203 8059760
Telefax +49 203 8059762
Email: office@ampstudio.de
If You have any complaints regarding this Privacy Policy or in the way We handle Your Personal Data You may always contact Your national security authority on data processing.
