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Privacy policy

Introduction

With the following data protection declaration we would like to inform you which types of your personal data (hereinafter also referred to as “data”) we process for which purposes and to what extent. The data protection declaration applies to all processing of personal data carried out by us, both within the framework of the provision of our services and in particular on our websites, in mobile applications and within external online presences, such as our social media profiles (hereinafter collectively referred to as “online offer”).

Status: September 30, 2019

Responsible

Eva Schubert
Avd Principes de Espana 12, edf. Avenue V-7
38612 El Medano
Spain, Tenerife

E-Mail-address: hello@sunnyworkation.com

Overview of the processing

The following table summarises the types of data processed and the purposes of their processing and refers to the data subjects.

Types of data processed

    • Environmental data (e.g. names, addresses).
    • content data (e.g. text entries, photographs, videos).
    • Contact details (e.g. e-mail, telephone numbers).
    • Meta/communication data (e.g. device information, IP addresses).

Change and update of the privacy policy

We ask you to inform yourself regularly about the content of our data protection declaration. We will adapt the data protection declaration as soon as the changes to the data processing carried out by us make this necessary. We will inform you as soon as the changes require your cooperation (e.g. consent) or other individual notification.

Rights of the persons affected

Under the DSGVO, they are entitled to various rights as affected parties, which result in particular from Articles 15 to 18 and 21 of the DS Block Exemption Regulation:

      • Right of objection: You have the right, for reasons arising from your particular situation, to object at any time to the processing of personal data concerning you on the basis of Art. 6 Para. 1 lit. e or f DSGVO; this also applies to profiling based on these provisions. If the personal data concerning you are processed for the purpose of direct advertising, you have the right at any time to object to the processing of the personal data concerning you for the purpose of such advertising; this also applies to profiling to the extent that it is connected with such direct advertising.
      • Right of revocation for consents: You have the right to revoke consents granted at any time.
      • Right of access: You have the right to request confirmation as to whether the data concerned will be processed and to request access to this data as well as further information and a copy of the data in accordance with the legal provisions.
      • Right of rectification: You have the right, in accordance with the provisions of the law, to request the completion of the data concerning you or the rectification of the incorrect data concerning you.
      • Right to deletion and limitation of processing: In accordance with the statutory provisions, you have the right to demand that data concerning you be deleted immediately or, alternatively, in accordance with the statutory provisions, to demand that the processing of the data be limited.
      • Right to data transfer: You have the right to receive data concerning you which you have provided to us in a structured, common and machine-readable format in accordance with the legal requirements, or to demand its transfer to another person responsible.
      • Complaint to the supervisory authority: You also have the right, in accordance with the statutory provisions, to complain to a supervisory authority, in particular in the Member State of your habitual residence, workplace or place of presumed infringement, if you are of the opinion that the processing of your personal data violates the DSGVO.

Created with Datenschutz-Generator.de by Dr. jur. Thomas Schwenke

  • Usage data (e.g. websites visited, interest in content, access times).
  • contract data (for example, contract object, term, customer category).
  • Payment data (for example, bank details, invoices, payment history).

Categories of persons concerned

  • Business and contractual partners.
  • Interested parties.
  • Communication partner.
  • Customers.
  • users (e.g. website visitors, users of online services).

Purposes of processing

  • Provision of our online services and user friendliness.
  • visit action evaluation.
  • Office and organisational procedures.
  • Interest-based and behavioral marketing.
  • Contact requests and communication.
  • Conversion measurement (measurement of the effectiveness of marketing measures).
  • Profiling (creating user profiles).
  • Remarketing.
  • Range measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures.
  • Tracking (e.g. interest/behaviour-related profiling, use of cookies).
  • Contractual services and support.
  • Administration and answering of inquiries.

Legal bases

In the following we inform you about the legal basis of the Data Protection Ordinance (DSGVO), on the basis of which we process personal data. Please note that, in addition to the provisions of the DSGVO, the national data protection regulations in your or our country of residence and domicile may also apply.

  • A Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO) – The data subject has given his consent to the processing of his personal data for one or more specific purposes.
  • Contractual performance and pre-contractual enquiries (Art. 6 para. 1 sentence 1 lit. b. DSGVO) – Processing is necessary for the performance of a contract to which the data subject is a party or for the implementation of pre-contractual measures taken at the request of the data subject.
  • Legal obligation (Art. 6 Para. 1 S. 1 lit. c. DSGVO) – The processing is necessary to fulfil a legal obligation to which the controller is subject.
  • Goodful interests (Art. 6 Par. 1 S. 1 lit. 1 f. DSGVO) – Processing is necessary to safeguard theoodoodoodful interests of the data controller or of a third party, unless the interests or fundamental rights and freedoms of the data subject which require the protection of personal data predominate.

Spain

Security measures

We shall take appropriate technical and organisational measures in accordance with the statutory requirements, taking into account the state of the art, the implementation costs and the nature, extent, circumstances and purposes of the processing as well as the different probabilities of occurrence and the extent of the threat to the rights and freedoms of natural persons, in order to ensure a level of protection appropriate to the risk.

Such measures shall include, in particular, ensuring the confidentiality, integrity and availability of data by controlling physical and electronic access to, and access to, input, transmission, securing and separation of data. In addition, we have established procedures to ensure the exercise of data subjects’ rights, the deletion of data and responses to data threats. Furthermore, we take the protection of personal data into account as early as the development or selection of hardware, software and procedures in accordance with the principle of data protection, through technology design and through data protection-friendly default settings.

SSL encryption (https): We use SSL encryption to protect your data transmitted via our online service. You can recognize such encrypted connections by the prefix https:// in the address bar of your browser.

Data processing in third countries

If we process data in a third country (i.e. outside the European Union (EU), the European Economic Area (EEA)) or the processing takes place in the context of the use of services of third parties or the disclosure or transfer of data to other persons, bodies or companies, this is only done in accordance with the legal requirements.

Subject to express consent or contractual or statutory transfer, we will only process or have the data processed in third countries with a recognised level of data protection, including US processors certified under the Privacy Shield, or on the basis of special guarantees such as contractual obligation through so-called standard protection clauses of the EU Commission, the existence of certifications or binding internal data protection regulations (Art. 44 to 49 DSGVO, information page of the EU Commission: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection_de ).

Use of cookies

Cookies” are small files that are stored on the user’s devices. Cookies can be used to store various data. This information can include, for example, the language settings on a website, the login status, a shopping basket or the location where a video was viewed.

As a rule, cookies are also used if a user’s interests or behaviour (e.g. viewing of certain content, use of functions, etc.) on individual websites are stored in a user profile. Such profiles are used, for example, to display content to users that corresponds to their potential interests. This procedure is also referred to as “tracking”, i.e. tracking the potential interests of users. The term cookies also includes other technologies that perform the same functions as cookies (e.g. when user information is stored using pseudonymous online identifiers, also referred to as “user IDs”).

If we use cookies or tracking technologies, we will inform you separately in our privacy policy.

Information on legal bases: The legal basis on which we process your personal data with the aid of cookies depends on whether we ask you for your consent. If this applies and you consent to the use of cookies, the legal basis for processing your data is your declared consent. Otherwise, the data processed with the help of cookies will be processed on the basis of our legitimate interests (e.g. in a business operation of our online service and its improvement) or, if the use of cookies is necessary to fulfill our contractual obligations.

Withdrawal and objection (Opt-Out): Irrespective of whether processing is based on consent or legal permission, you have the possibility at any time to revoke a consent given or to object to the processing of your data using cookie technologies (collectively referred to as “Opt-Out”).

You can initially explain your objection by means of your browser settings, e.g. by deactivating the use of cookies (which may also restrict the functionality of our online service).

An objection to the use of cookies for online marketing purposes can be raised through a variety of services, in particular in the case of tracking, via the US website http://www.aboutads.info/choices/ or the EU website http://www.youronlinechoices.com/ or generally on http://optout.aboutads.info

Processing of cookie data on the basis of a consent : Before we process or have processed data within the framework of the use of cookies, we ask the user for a consent that can be revoked at any time. Before the consent has not been given, we may use cookies that are necessary for the operation of our online service. Their use is based on our interest and the user’s interest in the expected functionality of our online service.

  • Processed data types: Usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).

Commercial and business services

We process data of our contractual and business partners, e.g. customers and interested parties (collectively referred to as “contractual partners”) within the framework of contractual and comparable legal relationships as well as associated measures and within the framework of communication with the contractual partners (or pre-contractual), e.g. in order to answer inquiries.

We process this data to fulfil our contractual obligations, to safeguard our rights and for the purposes of the administrative tasks associated with this information and the corporate organisation. Within the framework of applicable law, we only pass on the data of the contractual partners to third parties insofar as this is necessary for the aforementioned purposes or for the fulfilment of statutory obligations or is carried out with the consent of the contractual partners (e.g. to involved telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities). The contractual partners will be informed about further forms of processing, e.g. for marketing purposes, within the framework of this data protection declaration.

Which data are necessary for the aforementioned purposes, we inform the contractual partners before or in the context of the data collection, e.g. in on-line forms, by special marking (e.g. colors) and/or symbols (e.g. asterisks or the like), or personally.
We delete the data after expiry of statutory warranty and comparable obligations, i.e., in principle after expiry of 4 years, unless the data are stored in a customer account, e.g., as long as they must be kept for legal reasons of archiving (e.g. for tax purposes usually 10 years). Data disclosed to us by the contractual partner within the scope of an order will be deleted in accordance with the specifications of the order, in principle after the end of the order.

If we use third-party providers or platforms to provide our services, the terms and conditions and data protection notices of the respective third-party providers or platforms shall apply in the relationship between the users and the providers.

Events and Events: We process the data of the participants of the events, events and similar activities offered or hosted by us (hereinafter uniformly referred to as “participants” and “events”) in order to enable them to participate in the events and make use of the services or actions associated with participation.

Insofar as we process health-related data, religious, political or other special categories of data in this context, this is done within the framework of disclosure (e.g. for thematically oriented events or serves health care, security or is done with the consent of those affected).

The necessary information is identified as such in the context of the conclusion of the order, order or comparable contract and includes the information required for the provision of services and billing as well as contact information in order to be able to hold any consultations. Insofar as we gain access to information of end customers, employees or other persons, we process this in accordance with the legal and contractual requirements.

  • Processed data types: Inventory data (e.g. names, addresses), payment data (e.g. bank details, invoices, payment history), contact data (e.g. e-mail, telephone numbers), contract data (e.g. subject of contract, term, customer category).
  • Affected persons: Interested parties, business and contractual partners, customers.
  • Purposes of processing: Contractual services, contact enquiries and communication, office and organisational procedures, management and answering of enquiries.
  • Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b. DSGVO), Legal obligation (Art. 6 Para. 1 S. 1 lit. c. DSGVO), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. DSGVO).

Contacting

When contacting us (e.g. via contact form, e-mail, telephone or via social media), the data of the inquiring persons are processed insofar as this is necessary to answer the contact enquiries and any requested measures.

Contact enquiries within the framework of contractual or pre-contractual relationships are answered in order to fulfil our contractual obligations or to answer (pre)contractual enquiries and otherwise on the basis of legitimate interests in answering the enquiries.

  • Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text entries, photographs, videos).
  • Affected individuals: Communication partners.
  • Purposes of processing: Contact requests and communication.
  • Legal basis: Performance of contract and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b. DSGVO), Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. DSGVO).

Provision of the online service and web hosting

In order to provide our online services securely and efficiently, we use the services of one or more web hosting providers from whose servers (or servers they manage) the online services can be accessed. For these purposes, we may use infrastructure and platform services, computing capacity, storage space and database services, as well as security and technical maintenance services.

The data processed within the framework of the provision of the hosting offer may include all information relating to the users of our online offer that is collected within the scope of use and communication. This regularly includes the IP address, which is necessary to be able to deliver the contents of online offers to browsers, and all entries made within our online offer or from websites.

E-mail dispatch and -hosting: The web hosting services used by us also include the dispatch, receipt and storage of e-mails. For these purposes, the addresses of the recipients and senders as well as further information regarding the sending of e-mails (e.g. the providers involved) and the contents of the respective e-mails are processed. The aforementioned data may also be processed for SPAM detection purposes. Please note that e-mails on the Internet are generally not sent in encrypted form. As a rule, e-mails are encrypted during transport, but not on the servers from which they are sent and received (unless a so-called end-to-end encryption method is used). Therefore, we cannot assume any responsibility for the transmission path of the e-mails between the sender and the reception on our server.

Collection of access data and log files: We ourselves (or our web hosting provider) collect data on each access to the server (so-called server log files). The server log files can include the address and name of the websites and files accessed, the date and time of access, the amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited page) and, as a rule, IP addresses and the requesting provider.

The server log files can be used for security purposes, e.g. to avoid overloading the server (especially in the case of abusive attacks, so-called DDoS attacks) and to ensure server utilization and stability.

  • Processed data types: Content data (e.g. text input, photographs, videos), usage data (e.g. visited websites, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 1 f. DSGVO).

Online marketing

We process personal data for the purposes of online marketing, which includes in particular the presentation of advertising and other content (collectively referred to as “Content”) based on the potential interests of users and the measurement of their effectiveness.

For these purposes, so-called user profiles are created and stored in a file (so-called “cookie”) or similar procedures are used, by means of which the user information relevant for the presentation of the aforementioned content is stored. This information may include, for example, content viewed, websites visited, online networks used, but also communication partners and technical information such as the browser used, the computer system used and information on times of use. If users have consented to the collection of their location data, these can also be processed.

The IP addresses of the users are also stored. However, we use IP masking procedures (i.e. pseudonymisation by shortening the IP address) to protect the user. In general, the online marketing process does not store any user data (such as e-mail addresses or names), but pseudonyms. This means that we as well as the providers of online marketing procedures do not know the actual identity of the users, but only the information stored in their profiles.

The information in the profiles is usually stored in the cookies or by means of similar procedures. These cookies can later generally be used on other websites that use the same online marketing process, read out and analyzed for content presentation purposes and supplemented with further data and stored on the server of the online marketing process provider.

Exceptionally, plain data can be assigned to the profiles. This is the case, for example, if the users are members of a social network whose online marketing process we use and the network links the profiles of the users in the aforementioned information. We kindly ask you to note that users can make additional agreements with the providers, e.g. by giving their consent during registration.

As a matter of principle, we only receive access to summarised information about the success of our advertisements. However, within the framework of so-called conversion measurements, we can check which of our online marketing procedures have led to a so-called conversion, i.e. to the conclusion of a contract with us, for example. The conversion measurement is used solely to analyze the success of our marketing measures.
Information on legal bases: If we ask the users for their consent to the use of third party providers, the legal basis for the processing of data is consent. Otherwise the data of the users will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and receiver-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.

  • Processed data types: Usage data (e.g. web pages visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Users (e.g. website visitors, users of online services), interested parties.
  • Purposes of processing: Tracking (e.g. interest/behavioral profiling, use of cookies), remarketing, visitor action evaluation, interest-based and behavioral marketing, profiling (creation of user profiles), conversion measurement (measurement of the effectiveness of marketing measures), range measurement (e.g. access statistics, recognition of returning visitors).
  • Security measures: IP masking (pseudonymization of the IP address).
  • Legal basis: Consent (Art. 6 para. 1 sentence 1 lit. a DSGVO), Legitimate interests (Art. 6 para. 1 sentence 1 lit. f. DSGVO).
  • Opposition possibility (Opt-Out): We refer to the data protection references of the respective providers and the opposition possibilities indicated to the providers (so-called “Opt-Out”). If no explicit opt-out option has been specified, it is possible to deactivate cookies in the settings of your browser. However, this may restrict the functions of our online offer. We therefore recommend the following additional opt-out options, which are offered in summary to the respective areas: a) Europe: https://www.youronlinechoices.eu. b) Canada: https://www.youradchoices.ca/choices. c) USA: https://www.aboutads.info/choices. d) Cross-area: http://optout.aboutads.info.

Services and service providers in use:

Presences in social networks

We maintain online presences within social networks in order to communicate with the users active there or to offer information about us there.

We would like to point out that user data may be processed outside the European Union. This can result in risks for users, as it could, for example, make it more difficult to enforce the rights of users. With regard to US providers that are certified under the Privacy Shield or offer comparable guarantees of a secure level of data protection, we would like to point out that by doing so they undertake to comply with EU data protection standards.

In addition, user data is usually processed within social networks for market research and advertising purposes. For example, user profiles can be created on the basis of user behaviour and the resulting interests of users. The usage profiles can also be used, for example, to place advertisements within and outside the networks that are presumed to correspond to the interests of the users. For these purposes, cookies are usually stored on the user’s computer in which the user’s usage behaviour and interests are stored. Furthermore, data can also be stored in the user profiles independently of the devices used by the users (especially if the users are members of the respective platforms and are logged in to them).

For a detailed description of the respective forms of processing and the opt-out options, please refer to the data protection declarations and information provided by the operators of the respective networks.

We also point out that in the case of requests for information and the assertion of rights of data subjects, these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. Should you nevertheless need help, you can contact us.

  • Processed data types: Inventory data (e.g. names, addresses), contact data (e.g. e-mail, phone numbers), content data (e.g. text input, photographs, videos), usage data (e.g. websites visited, interest in content, access times), meta/communication data (e.g. device information, IP addresses).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Contact requests and communication, tracking (e.g. interest/behavioural profiling, use of cookies), remarketing, measurement of reach (e.g. access statistics, recognition of returning visitors).
  • Legal basis: Legitimate interests (Art. 6 para. 1 sentence 1 lit. 1 f. DSGVO).

Services and service providers in use:

Plugins and embedded functions as well as content

We include in our online offer functional and content elements that are obtained from the servers of their respective providers (hereinafter referred to as “third-party providers”). These may be, for example, graphics, videos or social media buttons as well as contributions (hereinafter uniformly referred to as “content”).
The integration always presupposes that the third party providers of this content process the IP address of the user, since they could not send the content to their browser without the IP address. The IP address is therefore required for the presentation of these contents or functions. We make every effort to use only those contents whose respective providers only use the IP address to deliver the contents. Third party providers may also use so-called pixel tags (invisible graphics, also known as “web beacons”) for statistical or marketing purposes. Pixel tags” can be used to evaluate information such as visitor traffic on the pages of this website. The pseudonymous information may also be stored in cookies on the user’s device and may contain technical information on the browser and operating system, websites to be referred to, visiting times and other information on the use of our online services as well as may be linked to such information from other sources.

Information on legal bases: If we ask users for their consent to the use of third-party providers, the legal basis for the processing of data is consent. Otherwise, user data will be processed on the basis of our legitimate interests (i.e. interest in efficient, economic and recipient-friendly services). In this context, we would also like to draw your attention to the information on the use of cookies in this data protection declaration.

  • Processed data types: Usage data (e.g. visited websites, interest in content, access times), meta/communication data (e.g. device information, IP addresses), inventory data (e.g. names, addresses), contact data (e.g. e-mail, telephone numbers), content data (e.g. text input, photographs, videos).
  • Affected persons: Users (e.g. website visitors, users of online services).
  • Purposes of processing: Provision of our online services and user friendliness, contractual services and service, security measures, administration and response to inquiries.
  • Legal basis: Legitimate interests (Art. 6 Para. 1 S. 1 lit. f. DSGVO), consent (Art. 6 Para. 1 S. 1 lit. a DSGVO), fulfilment of contract and pre-contractual enquiries (Art. 6 Para. 1 S. 1 lit. b. DSGVO).

Services and service providers in use:

Deletion of data

The data processed by us will be deleted in accordance with the statutory provisions as soon as their consent permitted for processing is revoked or other permissions lapse (e.g. if the purpose of processing this data has lapsed or it is not necessary for the purpose).

If the data are not deleted because they are required for other and legally permissible purposes, their processing will be limited to these purposes. This means that the data will be blocked and not processed for other purposes. This applies, for example, to data that must be stored for commercial or tax reasons or whose storage is necessary to assert, exercise or defend legal claims or to protect the rights of another natural or legal person.

Further information on the deletion of personal data can also be found in the individual data protection notices of this data protection declaration.

Created with Datenschutz-Generator.de by Dr. jur. Thomas Schwenke

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