Contact us
Circunomics GmbH
Große Bleiche 15
55116 Mainz
Represented by: Felix Wagner
E-mail: hello@circunomics.com
Court of registration: Amtsgericht Mainz 14,
Registernummer: HRB 49006
VAT ID according to the German Value Added Tax Act (UStG) §27a: DE 325339590
Privacy Policy:
Thank you for visiting our website https://www.trade.circunomics.com/ (“website”) and for your interest in our company. On the occasion of your visit to our website, we also process personal data within the meaning of Art. 4 (1) GDPR (“data”) from you. We are aware of the importance of the data entrusted to us. The protection of your privacy when processing your data is an important concern for us, which we take into account in our business processes. The handling of your data is in accordance with the legal requirements for data protection.
1. Controller
The controller according to Art. 4 (7) GDPR for the processing of your data in connection with this website is:
Circunomics GmbH. (“Circunomics” or “we”)
Große Bleiche 15
55-116, Mainz
Germany
E-mail: hello@circunomics.com
You can reach the Circunomics data protection officer as follows:
MELCHERS Rechtsanwälte Partnerschaftsgesellschaft mbB
Johannes Fischer
Solmsstraße 71
60-486, Frankfurt am Main
Germany
Email: j.fischer@melchers-law.com
Phone: 0049 69 653000659
2. Purpose of data processing, legal grounds, storage period, recipients, and third-country transfer
Depending on the purpose of processing, your data may be processed on different legal grounds. When operating our website, we are partly supported by processors who process your data on our behalf and our instructions and are thus recipients of your data (“service providers”).
In the following, we name the different purposes for which your data may be processed on our website, stating the relevant legal grounds as well as an indication of the storage period. We will also tell you whether your data is disclosed to service providers or other companies and whether a transfer of your data outside the European Economic Area (“EEA”) takes place.
a. Accessing our website and server logfile
To display our website on your terminal device, it is technically necessary for our web server, on which our website is hosted, to process data from you. For this purpose, we process your IP address together with information about your browser type and the version used, your operating system, your internet service provider, the date and time of your access, the website from which you accessed our website and the sub-websites you accessed in a server logfile.
The processing of your data is carried out under Art. 6 (1)(f) GDPR. The processing of your IP address is necessary to protect our legitimate interests in the retrievability and correct presentation of our website. The additional storage of your data in a server logfile serves to protect our legitimate interests in operating our website securely and error-free and to be able to detect, limit and eliminate malfunctions and errors.
Your data in our server logfile will be automatically deleted 30 days after visiting our website.
b. Contact
On our website, we give you the opportunity to contact us on various topics.
Ifyou contact us using our contact form, the mandatory information you must provide is marked as such. This information is required to process yourrequest. All other information is voluntary and only serves to answer your inquiry more precisely. In addition, you can contact us by telephone, e-mail ,mail or fax. The data we process from you in this context may vary depending on the communication channel, but will regularly include your first and last name ,address, telephone number, e-mail address and fax number. If your contact is directed towards the conclusion of a contract or is related to a contract, we process your data based on Art. 6 (1)(b) GDPR. If your contact is of a general nature, we process your data according to Art. 6 (1)(f) GDPR based on our legitimate interests in answering your inquiry about our company and/or our offers individually and as best as possible. We delete your data connected to a contractual relationship, only after the expiry of commercial or tax retention periods if necessary, which can be up to 6 years. These periods regularly begin at the end of the year in which you contacted us. We delete all other data when your inquiry has finally clarified, and we are not subject to any legal obligation to retain the corresponding data.We use the SendGrid service of Twilio Ireland Limited, 25-28North Wall Quay, North Wall, Dublin 1, D01 H104, Ireland (“Sendgrid”) for the automated sending of transactional and marketing emails. The use of Sendgrid may result in a transfer of your data to the USA.
The data transfer to the USA is based on the EU-US Data Privacy Framework. Further information on how Sendgrid handles your data can be found here: https://www.twilio.com/en-us/legal/privacy.
c. Newsletter
If you register for our newsletter on our website, we process your e-mail address as the only mandatory data. We need this for sending the newsletter. The provision of further data is voluntary. The legal grounds for the data processing associated with the dispatch of the newsletter is Art. 6 (1)(a)GDPR. In addition, we analyse your reading behaviour with regard to the newsletter, therefore we need to process your IP address and information about the browser and your system. By using this specific technology, we are able to know whether you have opened the newsletter, when you opened it, and which links you clicked. The analysis of your usage behaviour of our newsletter is based on Art. 6 (1)(a) GDPR. We delete your data processed by us in connection with the sending of our newsletter upon revocation of your consent to receive the newsletter, but not before the expiry of statutory limitation periods in connection with the sending of the newsletter. In order to be able to offer you our e-mail newsletter we rely on the support of HubSpot Inc, 25 First Street, 2nd Floor, Cambridge, MA 02141, USA (“HubSpot”)who process your Data exclusively on our behalf and according to our instructions. The use of Hubspot results in a transfer of your data to the USA. Data is transferred to the USA on the basis of the EU-US DataPrivacy Framework.
Furtherinformation on data processing by Hubspot can be found at https://legal.hubspot.com/de/privacy-policy.
d. Technically necessary cookies
Cookies are small files that are sent by us to the browser of your terminal device during your visit to our website and stored there. We use technically necessary cookies to ensure the basic functions of our website. The cookies contain a so-called “session ID”, with which various requests of your terminal device during your visit to our website can be assigned. The legal ground for the associated processing of your data is Art. 6 (1)(f) GDPR. The use of technically necessary cookies is essential to protect our legitimate interests in the retrievability, correct display, and ensuring the full functionality of our website. Technically necessary cookies are deleted at the latest after you have closed the browser you are using. If you do not wish cookies to be set on your terminal device, you can control this centrally via the browser you use.You can also delete cookies via your browser. However, blocking or deleting cookies may result in a noticeably restricted usability of our website for you.
e. Consent management
We also use technically non-essential cookies on our website. When you first visit our website, we ask for your consent concerning the use of such cookies. To manage your consent, i.e. whether you have given or refused it, we store corresponding data in a cookie on your terminal device to recognize you when you visit our website again and not ask for consent again. In doing so, we process your IP address, the time of your visit to our website, information about your browser and your terminal device. The associated processing of your data is based on Art. 6 (1)(f) GDPR and serves our legitimate interest in enabling you to use our website as comfortably as possible. The cookie has a lifespan of 12 months unless you delete it in your browser beforehand.
f. Webflow
We use the website building system of Webflow, Inc. (“Webflow”) for the purpose of hosting and displaying the website on the basis of processing on our behalf.All data collected on our website is processed on Webflow's servers. Webflow takes physical, electronic, and procedural safeguards to protect the personal data of its users and website visitors. You can find Webflow's privacy policy at https://webflow.com/legal/privacy. Webflow is a service provider, and therefore ,we have concluded a data processing agreement with them. You can access this agreement at https://webflow.com/legal/dpa. The processing of Webflow takes place in the territory of the EEA, the US, or other third countries. For the transfer of your data to third countries for which there is no adequacy decision, we have concluded the so-called standard contractual clauses with Webflow. The Transfer to the USA is based on theEU-US Data Privacy Framework.
g. Google reCAPTCHA
We use Google reCAPTCHA of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google Ireland") on our website.
The use of Google reCAPTCHA enables us to recognize visitors to our site as natural persons and thus prevent misuse of our site by automated bots. For this purpose, your interaction with our site is analyzed automatically and in the background (e.g. mouse movements).
The use of Google reCAPTCHA is based on Art. 6 para. 1 lit. f) DSGVO and serves our legitimate interests in ensuring the trouble-free operation of our website.
By using Google reCAPTCHA, Google Ireland collects data about you and sets cookies on your terminal device. Further details on how Google reCAPTCHA works can be found on the following page: https://www.google.com/recaptcha/about/.
We do not know how Google Ireland handles your data, in particular whether there is a transfer of your data to a country outside the EEA. General information about the processing of your data by Google Ireland can be found in the Google privacy policy: https://policies.google.com/privacy.
h. FriendlyCaptcha
We use the Friendly Captcha service of Friendly Captcha GmbH, Am Anger 3-5, 82237 Wörthsee, Germany (“Friendly Captcha”) on our website.Friendly Captcha is a protection solution to make it more difficult for automated programs and scripts (so-called “bots”) to use our website.We have integrated Friendly Captcha into our website, for example for contact forms. Friendly Captcha presents you with a calculation task that you have to solve in order to be able to send the contact form, for example.The result is sent to Friendly-Captcha via an interface and receives a response as to whether the puzzle has been solved correctly by the end device. WhenFriendly Captcha is called up, we process the following data of you
· the request headersUser-Agent, Origin and Referer;
· the puzzle itself, which contains information about the account and the website key to which the puzzle relates;
· the version of the widget;
· a timestamp.
In addition, we only process your IP address in hashed form. If we process personal data, it will be deleted within 30 days.
The legal basis for the processing is our legitimate interests in protecting our website from abusive access by bots, i.e. spam protection and protectionagainst attacks such as mass requests) is Article 6 (1)(f) GDPR.
Further information on how Friendly Captcha handles your data can be found here: https://friendlycaptcha.com/de/privacy/.
i. Matomo
We use the web analysis tool Matomo (formerly Piwik) from InnoCraft Ltd, 150Willis St, 6011 Wellington, New Zealand, NZBN 6106769 (“Matomo”) on our website.
Matomo is an open source tool for web analysis. We use information provided to us by the device you are using. Each time your web browser sends a request to our web server, technical data is automatically transmitted. This is necessary so that our web server can provide the content you have requested int he best possible way for the device you are using. We can use the technica ldata to differentiate between the devices used by different users. The following data is collected and stored using Matomo
· the IP address of the user, shortened by the last three bytes (anonymized);
· the subpage accessed and the time of access;
· the page from which the user came to our website (referrer);
· which browser with which plugins, which operating system and which screen resolution is used;
· the time spent on the website;
· the pages that are accessed from the accessed subpage.
The IP address is shortened immediately after collection and before it is stored.Returning users are recognized with the help of a so-called config_id. This isa random character string that is calculated using the first 2 bytes of the IP address, as well as the browser plugins, the operating system and the selected browser language of the user and then hashed. The ID is deleted and recreated after 24 hours so that the user cannot be recognized by the website on subsequent visits.
The legal basis for the associated processing of your data is Art. 6 (1)(f)GDPR. Our legitimate interests lie in the need to continually optimize our website and in market research purposes.
You can find Matomo's privacy policy at the following link:
https://matomo.org/docs/privacy/.
j.Zapier
To integrate different databases and tools, we use Zapier, a service provided by Zapier Inc, 548 Market St #62411, San Francisco, California 94104, UnitedStates (“Zapier”). With Zapier, we can automate actions between different web apps. We use Zapier and Hubspot to integrate. Your newsletter data is therefore also processed by Zapier. The legal basis for the use of Zapier is Art. 6(1)(f) GDPR. Our legitimate interest lies in the efficient design of our website. The use of Zapier results in a transfer of your data to the USA. Data is transferred to the USA on the basis of the EU-US Data Privacy Framework.
Further information on data processing by Zapier can be found at: https://zapier.com/privacy/.
3. Recipients of the data
The service providers and companies named above are initially the only recipients of your data when visiting our website. In addition, service providers engaged by us support us in the maintenance, care and further development of our website, who process your data only on our instructions and on our behalf. Your data may also be made available to other companies associated with us for internal administrative purposes. Beyond this, your data will only be passed on following a legal obligation, such as to authorities or for the defence, establishment, exercise or protection of legal claims.
4. Third country transfer
The involvement of the companies mentioned under 2. b), c), f) and j) may result in a transfer of your data to a third country and thus outside the EEA. Detail scan be found in the respective description.
5. Necessity of data collection
You are neither contractually nor legally obliged to provide us with the data described in this privacy policy.
6. Your rights
Under the provisions of the GDPR, you may assert the following rights against us:
Right to access (Art. 15GDPR),
Right to rectification (Art. 16 GDPR),
Right to erasure (Art. 17 GDPR),
Right to restriction of processing (Art. 18 GDPR),
Right to data portability (Art. 20 GDPR).
You have the right torevoke any consent given to us at any time with effect for the future.
Also, you may object to the processing of your data described here to safeguardlegitimate interests at any time with effect for the future under Art. 21 GDPR.
If the processing is not carried out for direct marketing purposes, the right to object only exists for reasons arising from your particular situation.
In addition, you can complain to a supervisory authority at any time. The supervisory authority responsible for us is:
Der Landesbeauftragte für den Datenschutz und dieInformationsfreiheit Rheinland-Pfalz
Prof. Dr. Dieter Kugelmann
Hintere Bleiche 34
55116 Mainz
Telefon: +49 (0) 6131 8920-0
Telefax: +49 (0) 6131 8920-299
Webseite: https://www.datenschutz.rlp.de/
E-Mail: poststelle@datenschutz.rlp.de
