Privacy policy

1) Introduction and Contact Details of the Controller

1.1 We are pleased that you are visiting our website and thank you for your interest. In the following, we inform you about the handling of your personal data when using our website. Personal data are all data with which you can be personally identified.

1.2 The controller responsible for data processing on this website within the meaning of the General Data Protection Regulation (GDPR) is subtel GmbH, Mainzer Str. 3, 10247 Berlin, Germany, E-Mail: info@subtel.at. The controller responsible for the processing of personal data is the natural or legal person who alone or jointly with others decides on the purposes and means of the processing of personal data.

1.3 The controller has appointed a Data Protection Officer, who can be reached as follows: "Jan Eichelmann, Mainzer Str. 3, 10247 Berlin"

2) Data Collection When Visiting Our Website

2.1 When using our website purely for informational purposes, that is, if you do not register or otherwise provide us with information, we only collect data that your browser transmits to our server (so-called "server log files"). When you access our website, we collect the following data that are technically necessary for us to display the website to you:

Our visited website
Date and time at the moment of access
Amount of data sent in bytes
Source/reference from which you came to the page
Used browser
Used operating system
Used IP address (if applicable: in anonymized form)
The processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR based on our legitimate interest in improving the stability and functionality of our website. The data will not be passed on or used in any other way. However, we reserve the right to check the server log files retrospectively if concrete indications point to unlawful use.

2.2 This website uses SSL or TLS encryption for security reasons and to protect the transmission of personal data and other confidential content (e.g., orders or inquiries to the controller). You can recognize an encrypted connection by the string "https://" and the lock symbol in your browser line.

3) Hosting & Content Delivery Network

Cloudinary

We use a Content Delivery Network of the following provider: Cloudinary Ltd., 3400 Central Expressway, Suite 110, Santa Clara, CA 95051, USA

This service enables us to deliver large media files like graphics, page content, or scripts more quickly through a network of regionally distributed servers. The processing is carried out to safeguard our legitimate interests in improving the stability and functionality of our website in accordance with Art. 6 para. 1 lit. f GDPR. We have concluded a Data Processing Agreement with the provider, which ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties.

For the transfer of data to the USA, the provider relies on standard contractual clauses of the European Commission, which are intended to ensure compliance with the European level of data protection.

4) Cookies

To make the visit to our website attractive and to enable the use of certain functions, we use cookies, i.e., small text files that are stored on your end device. Some of these cookies are automatically deleted after closing the browser (so-called "session cookies"), while others remain longer on your end device and enable saving of page settings (so-called "persistent cookies"). In the latter case, you can find the storage duration in the overview of the cookie settings of your web browser.

If personal data are also processed by individual cookies we use, the processing is carried out either in accordance with Art. 6 para. 1 lit. b GDPR for contract execution, in accordance with Art. 6 para. 1 lit. a GDPR in the case of consent given, or in accordance with Art. 6 para. 1 lit. f GDPR to safeguard our legitimate interests in the best possible functionality of the website as well as a customer-friendly and effective design of the site visit.

You can set your browser so that you are informed about the setting of cookies and decide individually about their acceptance or exclude the acceptance of cookies for certain cases or in general.

Please note that the functionality of our website may be limited if cookies are not accepted.

5) Contacting Us

5.1 Trustpilot

For review reminders, we use the services of the following provider: Trustpilot A/S, Pilestræde 58, 1112 Copenhagen, Denmark

Exclusively on the basis of your express consent in accordance with Art. 6 para. 1 lit. a GDPR, we transmit your email address and, if applicable, other customer data to the provider so that they can contact you with a review reminder via email.

You can revoke your consent at any time with effect for the future towards us or the provider.

We have concluded a Data Processing Agreement with the provider, which ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties.

5.2 In the context of contacting us (e.g., via contact form or email), personal data are processed exclusively for the purpose of processing and answering your request and only to the extent necessary.

The legal basis for processing these data is our legitimate interest in responding to your request in accordance with Art. 6 para. 1 lit. f GDPR. If your contact aims at concluding a contract, an additional legal basis for processing is Art. 6 para. 1 lit. b GDPR. Your data will be deleted if it can be inferred from the circumstances that the matter concerned has been conclusively clarified and provided that there are no statutory retention obligations to the contrary.

6) Data Processing When Opening a Customer Account

In accordance with Art. 6 para. 1 lit. b GDPR, personal data are collected and processed to the necessary extent when you provide them to us during the opening of a customer account. Which data are required for the account opening can be seen from the input mask of the corresponding form on our website.

You can delete your customer account at any time, and this can be done by sending a message to the above address of the controller. After deletion of your customer account, your data will be deleted, provided that all contracts concluded via it have been fully processed, there are no statutory retention periods to the contrary, and there is no legitimate interest on our part in further storage.

7) Data Processing for Order Handling

7.1 Insofar as necessary for contract execution for delivery and payment purposes, the personal data collected by us will be passed on to the commissioned transport company and the commissioned credit institution in accordance with Art. 6 para. 1 lit. b GDPR.

If we owe you updates for goods with digital elements or for digital products based on a corresponding contract, we process the contact data you provided when placing the order (name, address, email address) to personally inform you via suitable communication channels (e.g., by post or email) within the legally prescribed period about upcoming updates. Your contact data will be used strictly for the purpose of notifications about updates owed by us and will only be processed by us to the extent necessary for this purpose.

To process your order, we also work with the following service provider(s) who support us wholly or partially in the execution of concluded contracts. Certain personal data are transmitted to these service providers in accordance with the following information.

7.2 Transfer of Personal Data to Shipping Service Providers

- Deutsche Post

We use the following provider as a transport service provider: Deutsche Post AG, Charles-de-Gaulle-Straße 20, 53113 Bonn, Germany

We forward your email address and/or telephone number to the provider prior to delivery of the goods for the purpose of coordinating a delivery date or delivery notification in accordance with Art. 6 para. 1 lit. a GDPR, provided that you have given your express consent for this during the ordering process. Otherwise, we only forward the name of the recipient and the delivery address to the provider for the purpose of delivery in accordance with Art. 6 para. 1 lit. b GDPR. The transfer only takes place to the extent necessary for the delivery of the goods. In this case, prior coordination of the delivery date with the provider or delivery notification is not possible.

You can revoke your consent at any time with effect for the future towards the above-named controller or towards the provider.
- DHL

We use the following provider as a transport service provider: DHL Paket GmbH, Sträßchensweg 10, 53113 Bonn, Germany

You can revoke your consent at any time with effect for the future towards the above-named controller or towards the provider.
- DPD

We use the following provider as a transport service provider: DPD Deutschland GmbH, Wailandtstraße 1, 63741 Aschaffenburg, Germany

You can revoke your consent at any time with effect for the future towards the above-named controller or towards the provider.

7.3 Use of Payment Service Providers

- Adyen

One or more online payment methods of the following provider are available on this website: Adyen, Simon Carmiggeltstraat 6 - 50, 1011 DJ Amsterdam, Netherlands

If you select a payment method from the provider where you make an advance payment (e.g., credit card payment), your payment data communicated during the order process (including name, address, bank and card information, currency, and transaction number) as well as information about the content of your order are transmitted to the provider in accordance with Art. 6 para. 1 lit. b GDPR. The transfer of your data in this case is solely for the purpose of payment processing with the provider and only to the extent necessary for this.

8) Web Analysis Services

Google Analytics 4

This website uses Google Analytics 4, a web analytics service provided by Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google"), which enables an analysis of your use of our website.

By default, when visiting the website, Google Analytics 4 sets cookies, which are small text files stored on your end device and collect certain information. This includes your IP address, which, however, is truncated by Google by the last digits to exclude direct personal reference.

The information is transmitted to Google's servers and processed there. This may also involve transmission to Google LLC servers located in the USA.

Google uses the information collected on our behalf to evaluate your use of the website, compile reports on website activity, and provide other services related to website and internet usage. The IP address transmitted by your browser within the scope of Google Analytics is not merged with other Google data. The data collected during the use of Google Analytics 4 are stored for a period of two months and then deleted.

All the processing described above, particularly the setting of cookies on the end device used, is only carried out if you have given us your express consent in accordance with Art. 6 para. 1 lit. a GDPR.
Without your consent, Google Analytics 4 will not be used during your site visit. You can revoke your consent at any time with effect for the future. To exercise your revocation right, please deactivate this service via the "Cookie Consent Tool" provided on the website.

We have concluded a Data Processing Agreement with Google, which ensures the protection of our site visitors' data and prohibits unauthorized disclosure to third parties.

Further legal notices regarding Google Analytics 4 can be found at https://business.safety.google/intl/en/privacy/, https://policies.google.com/privacy?hl=en, and at https://policies.google.com/technologies/partner-sites

Demographics
Google Analytics 4 uses the special "demographic characteristics" function and can thus create statistics that make statements about the age, gender, and interests of site visitors. This is done through the analysis of advertising and information from third-party providers. This can identify target groups for marketing activities. However, the collected data cannot be assigned to a specific person and are deleted after being stored for a period of two months.

Google Signals
As an extension to Google Analytics 4, Google Signals can be used on this website to create cross-device reports. If you have enabled personalized ads and linked your devices to your Google account, Google can, subject to your consent to the use of Google Analytics in accordance with Art. 6 para. 1 lit. a GDPR, analyze your usage behavior across devices and create database models, including cross-device conversions. We do not receive any personal data from Google, only statistics. If you want to stop the cross-device analysis, you can deactivate the "Personalized advertising" function in your Google account settings. Follow the instructions on this page: https://support.google.com/ads/answer/2662922?hl=en For more information about Google Signals, see the following link: https://support.google.com/analytics/answer/7532985?hl=en

User IDs
As an extension to Google Analytics 4, the "User IDs" function can be used on this website. If you have consented to the use of Google Analytics 4 in accordance with Art. 6 para. 1 lit. a GDPR, have set up an account on this website, and log in with this account on different devices, your activities, including conversions, can be analyzed across devices.

For data transfers to the USA, the provider has joined the EU-US Data Privacy Framework, which, based on an adequacy decision by the European Commission, ensures compliance with the European level of data protection.

9) Retargeting/Remarketing and Conversion Tracking

Google Ads Conversion Tracking

This website uses the online advertising program "Google Ads" and, within Google Ads, the conversion tracking of Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland ("Google").

We use Google Ads to draw attention to our attractive offers on external websites using advertising materials (so-called Google Adwords). We can determine how successful the individual advertising measures are in relation to the data of the advertising campaigns. We pursue the interest of showing you advertising that is of interest to you, making our website more interesting for you, and achieving a fair calculation of advertising costs.

The conversion tracking cookie is set when a user clicks on a Google Ads ad. Cookies are small text files that are stored on your end device. These cookies usually lose their validity after 30 days and are not used for personal identification. If the user visits certain pages of this website and the cookie has not yet expired, Google and we can recognize that the user clicked on the ad and was redirected to this page. Each Google Ads customer receives a different cookie. Cookies cannot therefore be tracked across Google Ads customers' websites. The information obtained using the conversion cookie is used to create conversion statistics for Google Ads customers who have opted for conversion tracking. Customers learn the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they do not receive information that personally identifies users.

Within the use of Google Ads, personal data may also be transmitted to the servers of Google LLC in the USA.

Details about the processing initiated by Google Ads Conversion Tracking and Google's handling of data from websites can be found here: https://policies.google.com/technologies/partner-sites

All the processing described above, especially the setting of cookies for reading information on the end device used, is only carried out if you have given us your express consent in accordance with Art. 6 para. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future by deactivating this service in the "Cookie Consent Tool" provided on the website.

You can also permanently object to the setting of cookies by Google Ads Conversion Tracking by downloading and installing the browser plug-in available under the following link:
https://www.google.com/settings/ads/plugin?hl=en

To address users whose data we have received as part of business or business-like relationships in a more interest-based advertising manner, we use a customer matching function within Google Ads. For this purpose, we transmit one or more files with aggregated customer data (primarily email addresses and telephone numbers) to Google electronically. Google does not gain access to plain data but encrypts the information in the customer files automatically using a special algorithm during the transmission process. The encrypted information can then only be used by Google to assign it to existing Google accounts that the data subjects have set up. This allows personalized advertising to be displayed via all Google services linked to the respective Google account.

The transmission of customer data to Google only occurs if you have given us your express consent in accordance with Art. 6 para. 1 lit. a GDPR. You can revoke this consent at any time with effect for the future. Further information on Google's data protection measures regarding the customer matching function can be found here: https://support.google.com/google-ads/answer/6334160?hl=en&ref_topic=10550182
Google's privacy policy can be viewed here: https://business.safety.google/intl/en/privacy/ and https://www.google.com/policies/privacy/

We provide a Single Sign-On function of the following provider on our website: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

In addition to a data transfer to the above-mentioned provider location, data may also be transferred to: Google LLC, USA

If you have an account with the provider, you can log in with these account data to create a user account or register on our website.

When you visit this page, a direct connection between your browser and the provider's servers can be established via this login function, even if you do not have an account with the provider or are not logged into such an account. The provider thereby receives the information that you have visited our site. The information collected in this way (possibly including your IP address) is transmitted directly from your browser to a server of the provider and stored there. However, the information is not used to personally identify you and is not passed on to third parties.

These data processing operations are carried out in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in a user-friendly and interactive design of our online presence.

If you click the login button to register on our website using your account data with the provider, the provider transmits your general and publicly accessible information (user ID, name, address, email address, age, and gender) stored in your account to us solely on the basis of your express consent in accordance with Art. 6 para. 1 lit. a GDPR.

We store and use the data transmitted by the provider to create a user account with the necessary data (salutation, first name, last name, address data, country, email address, date of birth), provided that you have released them to the provider. Conversely, data (e.g., information about your surfing or purchasing behavior) can be transferred from us to your account with the provider on the basis of your consent.

You can revoke the consent granted at any time with effect for the future towards us.

Further information on Google's privacy policy can be found here: https://business.safety.google/intl/en/privacy/

10.2 Google Web Fonts

This site uses so-called web fonts provided by the following provider for the uniform display of fonts: Google Ireland Limited, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland

When you call up a page, your browser loads the required web fonts into your browser cache to display texts and fonts correctly and establishes a direct connection to the provider's servers. In doing so, certain browser information, including your IP address, is transmitted to the provider.

Data may also be transferred to: Google LLC, USA

The processing of personal data in the context of the connection to the provider of the fonts is only carried out if you have given us your express consent in accordance with Art. 6 para. 1 lit. a GDPR. You can revoke your consent at any time with effect for the future by deactivating this service via the "Cookie Consent Tool" provided on the website. If your browser does not support web fonts, a standard font from your computer will be used.

Further information on Google's privacy policy can be found here: https://business.safety.google/intl/en/privacy/

11) Rights of the Data Subject

11.1 The applicable data protection law grants you the following data subject rights (rights to information and intervention) vis-à-vis the controller regarding the processing of your personal data, whereby reference is made to the stated legal basis for the respective exercise requirements:

Right of access according to Art. 15 GDPR;
Right to rectification according to Art. 16 GDPR;
Right to erasure according to Art. 17 GDPR;
Right to restriction of processing according to Art. 18 GDPR;
Right to notification according to Art. 19 GDPR;
Right to data portability according to Art. 20 GDPR;
Right to withdraw consent given according to Art. 7 para. 3 GDPR;
Right to lodge a complaint according to Art. 77 GDPR.

11.2 RIGHT TO OBJECT

IF WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF OUR OVERRIDING LEGITIMATE INTEREST WITHIN THE FRAMEWORK OF A BALANCING OF INTERESTS, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT TO THIS PROCESSING WITH EFFECT FOR THE FUTURE ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED. HOWEVER, FURTHER PROCESSING IS RESERVED IF WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING THAT OVERRIDE YOUR INTERESTS, FUNDAMENTAL RIGHTS, AND FREEDOMS, OR IF THE PROCESSING SERVES THE ASSERTION, EXERCISE, OR DEFENSE OF LEGAL CLAIMS.

IF YOUR PERSONAL DATA ARE PROCESSED BY US FOR DIRECT MARKETING PURPOSES, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR SUCH MARKETING PURPOSES. YOU CAN EXERCISE THE RIGHT TO OBJECT AS DESCRIBED ABOVE.

IF YOU EXERCISE YOUR RIGHT TO OBJECT, WE WILL STOP PROCESSING THE DATA CONCERNED FOR DIRECT MARKETING PURPOSES.

12) Duration of Storage of Personal Data

The duration of the storage of personal data is determined based on the respective legal basis, the processing purpose, and—if relevant—additionally based on the respective statutory retention period (e.g., commercial and tax retention periods).

When processing personal data on the basis of explicit consent in accordance with Art. 6 para. 1 lit. a GDPR, these data are stored until you revoke your consent.

If there are statutory retention periods for data that are processed within the framework of legal or quasi-legal obligations on the basis of Art. 6 para. 1 lit. b GDPR, these data are routinely deleted after the expiry of the retention periods, provided that they are no longer required for contract fulfillment or contract initiation and/or there is no legitimate interest on our part in further storage.

When processing personal data on the basis of Art. 6 para. 1 lit. f GDPR, these data are stored until you exercise your right to object in accordance with Art. 21 para. 1 GDPR, unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or the processing serves the assertion, exercise, or defense of legal claims.

When processing personal data for the purpose of direct marketing on the basis of Art. 6 para. 1 lit. f GDPR, these data are stored until you exercise your right to object in accordance with Art. 21 para. 2 GDPR.

Unless otherwise stated in the other information of this declaration about specific processing situations, stored personal data are otherwise deleted when they are no longer necessary for the purposes for which they were collected or otherwise processed.

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