Effective Date: 01. June 2023
INFORMATION ON THE PROCESSING OF PERSONAL DATA PURSUANT TO ART. 13 OF EU REGULATION 679/2016 (GDPR)
This Privacy Policy (hereinafter referred to as the “Policy”) is provided, pursuant to Article 13 of the EU Regulation No. 679/2016 concerning the protection of individuals with regard to the processing of personal data and the free circulation of such data (hereinafter “GDPR”), to inform users (hereinafter “Users”) of how INVEST.IN.TEK GmbH, the owner of the website edevelup.com (hereinafter the “Website” or “We”), located in Hamburg, Germany, will process their personal data. This Policy aims to comply with principles of correctness, lawfulness, transparency, protection of confidentiality, and the rights of the User. This Policy is exclusively applicable to Users who visit the website edevelup.com and interact with its services and does not apply to other websites or sections/pages/spaces owned by third parties that may be accessed through specific links, which have their own privacy policies.
- Data Controller: The Data Controller is INVEST.IN.TEK GmbH, located in Hamburg, Germany. You can contact us at the following Email: [contact@edevelup.com]
- Data Protection Officer INVEST.IN.TEK GmbH has appointed a Data Protection Officer (DPO) who can be contacted at the following email address: [contact@edevelup.com].
- Type of Personal Data Processed a) Navigation Data: The Website’s computer systems and software procedures may collect, during regular operation and only for the duration of the connection, specific data that is implicitly transmitted through the use of Internet communication protocols (such as IP address and timestamp). This information is not processed for the purpose of directly associating it with Users, and it will not be possible to directly identify the User through edevelup.com’s processes and website. However, by their very nature, these data could indirectly allow the identification of the User through processing and association with data held by third parties. This data may be used to ascertain responsibility in the event of hypothetical computer crimes against the Website. b) Voluntarily Provided Data: Personal data provided directly and voluntarily by Users of the Website may be processed, including but not limited to name, surname, telephone number, province, and email address. If the User provides personal data of third parties, they assume full responsibility and must ensure that the communication of such data to the Data Controller and the subsequent processing by the Data Controller is done in compliance with the GDPR. Prior to providing the personal data of third parties, the User must inform them and obtain their consent for the processing, if required. c) Cookies: The Website uses cookies, which are information packages sent by the web server (in this case, from edevelup.com) to the User’s browser and automatically stored by the User’s device (such as personal computer, tablet, mobile phone, etc.). These cookies are automatically sent back to the server each time the User accesses the Website. Please refer to our Cookie Policy for more information regarding the use of cookies on our Website.
- Methods of Data Processing Personal data may be provided voluntarily by the User or collected automatically while browsing the Website. Failure to provide certain personal data may prevent the Data Controller from providing the requested services. The processing of data, for the purposes referred to in paragraph 6, may be carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the indicated purposes. We adopt all technical and procedural security measures considered appropriate to prevent unauthorized access, disclosure, modification, or destruction of personal data, in accordance with the requirements of Article 32 of the GDPR.
- Parties Involved in the Processing In addition to the Data Controller, certain categories of authorized persons involved in the development and execution of the services provided by the Data Controller through the Website, as well as related activities (such as administrative staff, commercial staff, system administrators), may have access to the data. External parties, such as third-party technical service providers, hosting providers, and consultants, may also have access to the data. Personal data provided by Users will only be disclosed to third parties if necessary to fulfill the purposes referred to in paragraph 6. All employees or suppliers used by the Data Controller for the processing of User’s personal data are appropriately authorized and made responsible for the methods and purposes of the processing assigned to them. They will act in compliance with and in accordance with this Policy. An updated list of these individuals and entities is available at the Data Controller’s office.
- Purpose and Legal Basis of the Processing The User’s personal data is processed by the Data Controller for the following purposes:
- a) To provide the services offered by the Website and respond to User requests. The legal basis for this processing is the need to fulfill User requests, perform a contract, and/or take pre-contractual measures at the User’s request. The provision of personal data is necessary for this purpose, and failure to provide them may result in the Data Controller being unable to provide the requested services to the User.
- b) To send the User communications for marketing activities regarding our services/products through automated (email, text message, autoresponders) and non-automated (ordinary mail, telephone with operator) tools. The legal basis for this processing is the free and optional consent of the User. The User has the option to withdraw consent and object to the sending of such communications at any time.
- c) To fulfill any obligations derived from applicable legislation or orders from authorities, as well as for administrative, accounting, and tax activities. The legal basis for this processing is the fulfillment of a legal obligation.
- d) To ensure that the Website is updated and meets the needs of Users, to analyze, review, and improve the Website’s services, and, if necessary, to exercise legal rights and defend against legal claims. The legal basis for this processing is the legitimate interest of the Data Controller in protecting its assets, business, and rights.
- Data Retention Periods: The processed data will be retained for the period strictly necessary to fulfill the purposes mentioned above and/or for different periods as prescribed by law. The data processed for the purposes specified in paragraph 6(b) will be retained for a maximum of 5 (five) years from the moment consent is given. The User can revoke consent at any time. The User may also request the interruption of the service provision and exercise their rights described in paragraph 9 below.
- Transfers Outside the EEA The User’s personal data will not be transferred outside the European Economic Area (EEA). If the Data Controller needs to transfer personal data outside the EEA, such transfers will be subject to adequate safeguards and protection measures.
- User Rights As a data subject, the User has specific rights under the GDPR. The User has the right to:
- Obtain confirmation as to whether or not personal data concerning them is being processed and, if so, access to that data (Article 15 “right of access”).
- Request the correction of inaccurate personal data or the integration of incomplete personal data (Article 16 “right of rectification”).
- Request the erasure of personal data under certain conditions provided by the GDPR (Article 17 “right to erasure”), where applicable.
- Request the restriction of processing of their personal data under certain conditions provided by the GDPR (Article 18 “right to restriction of processing”).
- Receive the personal data provided in a structured, commonly used, and machine-readable format and have the right to transmit those data to another data controller, where applicable (Article 20 “right to data portability”).
- Object to decisions based solely on automated processing, including profiling, which produces legal effects concerning the User or significantly affects them (Article 22 “right to object”).
To exercise their rights, the User can contact the Data Controller in writing at the addresses mentioned in paragraph 1. In addition to the right to lodge a complaint with a Supervisory Authority, the User has the right to seek judicial remedies if they believe that the processing of their personal data violates the GDPR. In Germany, the competent authority for personal data protection is the Federal Commissioner for Data Protection and Freedom of Information (Bundesbeauftragte für den Datenschutz und die Informationsfreiheit, or BfDI). They are responsible for overseeing and enforcing data protection laws in Germany. Website: https://www.bfdi.bund.de/
- Changes to the Privacy Policy: This Privacy Policy may be subject to changes over time, including new sector regulations, updates or provision of new services by the Data Controller, or technological innovations. Users are encouraged to periodically review this policy by visiting this page.
Last updated: 01. June 2023