PRIVACY POLICY

Thank you for visiting our website available under http://www.cultureshifts.net (hereinafter “Website“) and using our services provided on it (hereinafter “Services“). The protection of personal data in the context of the use of the Website and the Services is very important to us. We respect your privacy. This is why we only collect and process your personal data in accordance with the applicable statutory provisions.

1 CONTROLLER

The controller within the scope of the General Data Protection Regulation (Art. 4 no. 7 GDPR) is Culture Shifts Moritz Gaudlitz (hereinafter “Culture Shifts,” “we,” “our,” “us” etc.),

Nymphenburger Straße 23,

80335 Munich, Germany,

phone: +49 1727377 023,

email: info@cultureshifts.net.

2 WHAT IS PERSONAL DATA

Personal data is all information that can be associated with you individually (cf. Art. 4 no. 1 GDPR). This includes e.g. your name, your address, your phone number and your email address. On the other hand, general information by means of which you cannot be identified does not constitute personal data. Such information includes e.g. the number of users of the Website.

3 WHAT TYPES OF PERSONAL DATA DO WE COLLECT AND PROCESS FOR WHICH PURPOSES

3.1 WEBSERVER PROTOCOLS (INCLUDING THE IP ADDRESS)

When you visit our Website, due to technical requirements, our web server will automatically record your full IP address, the date and the time at which you are visiting the Website, the sections you access on the Website, the website you visited before accessing the Website, the browser you use (e.g. Mozilla Firefox, Google Chrome etc.), the operating system you use (e.g. Windows 10, MacOS etc.), and the domain name and address of your Internet provider (e.g. Deutsche Telekom). This information is required for the technical transmission of the Website and the secure operation of the server. This information is not merged with other data sources.

We process this information in order to observe and monitor the stability, functionality, and technical performance of the Website and the Services and in order to detect, identify, eliminate and solve any potential problems and errors on the Website and within the Services. The legal basis for the processing of this information is our legitimate interests (Art. 6 (1) lit. f GDPR), which consist in ensuring and improving the integrity, stability, and functionality of the Website and the Services – as far as this is technically possible and reasonable.

Furthermore, for reasons of technical security, in particular, to ward off attempted attacks or other abuse of the Website, the Services and/or our web server, this information is stored for a short period of time. We are not able to directly associate this information with individual persons. After seven days at the latest, this information will be anonymized through the shortening of the IP address to the domain level, so that it will no longer be possible to connect this information to an individual person. However, in the period of time until the shortening of the IP address, we may process this information in case of a security incident (attempted attack or abuse etc.) in cooperation with your internet provider and/or the local authorities in order to identify the party that caused the security incident. The legal basis for this is our legitimate interests (Art. 6 (1) lit. f GDPR) which consist in protecting the integrity of the Website, the Services, our system and of our users.

This information will only be processed for statistical, market research and/or advertising purposes in anonymized form, i.e. after the IP address has been shortened to the domain level.

3.2 PERSONAL DATA THAT YOU PROVIDE IN THE CONTEXT OF YOUR USE OF THE SERVICES ON THE WEBSITE

(a) Contacting us

If you wish to contact us, e.g. by using the contact form or email, the data you provide when doing so will be used to process your request and to get in contact with you. Providing that data is necessary to handle and answer your request; without those data, we cannot answer your request completely or at all.

The legal basis for the processing of your personal data is the fulfilment of our contractual obligations (Art. 6 (1) lit. b GDPR) as well as safeguarding our legitimate interests, which include, but are not limited to, contacting you and communicating with you about any concerns you have contacted us about (Art. 6 (1) lit. f GDPR).

(b) Newsletter

If you have provided your consent, we also collect your name and email address when registering for our newsletter. We process this personal data in order to send you our newsletter. The legal basis for this is the consent provided by you (Art. 6 (1) lit. a GDPR).

We use the service provider MailChimp for sending our newsletters. More information on MailChimp is available in section 4.2.

We use the so-called double opt-in procedure for the registration of our newsletter, i.e. once you have registered for the newsletter, we will first of all send you an email that includes a confirmation link. Only once you have clicked on the confirmation link and we have received the confirmation, will we activate the delivery of the newsletter.

You may withdraw your consent at any time with future effect. You can declare such a withdrawal of consent at any time by following our withdrawal instructions that are included in each newsletter or by sending your withdrawal request to the contact details specified in section 1.

4 DISCLOSURE OF PERSONAL DATA

4.1 GENERAL INFORMATION

We do not disclose any personal data to third parties unless such disclosure is required for contractual performance or otherwise allowed by applicable statutory provisions or unless you have given us your consent.

Please note that we are entitled to outsource the processing of personal data in the context of data protection law provisions fully or partially to external service providers working on our behalf as data processors (Art. 4 no. 8 GDPR). If these service providers are domiciled outside the European Union (EU) or the signatory states of the Agreement on the European Economic Area (EEA), we will take appropriate security measures in accordance with the provisions of the applicable laws and the supervisory authorities in order to ensure the security of your personal data.

A list of these external service providers including descriptions of their respective services and of the appropriate data protection level provided is presented in the following table:

Service provider and, if applicable, name of the service Description of the service Place of processing; Measures for ensuring the existence of an appropriate level of protection
One.com, Company no: 19958, Dubai Internet City, Building 9 – P.O. Box 500401, phone: +49 201 48793511, email: support@de.one.com Hosting of the Website and hosting, support and administration of the server systems

(cf. also section 3.1)

[xxx]
MailChimp

Rocket Science Group LLC, 675 Ponce De Leon Ave. NE #5000, Atlanta, GA 30308, United States of America, phone: +1 404 806 5843, email: dpo@mailchimp.com

 

Newsletter service for the administration, delivery, and evaluation of our newsletter

(cf. also section 4.2)

USA

EU-US Privacy Shield certification (https://www.privacyshield.gov/participant?id=a2zt0000000TOWQAA4&status=Active)

Google Analytics

Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States of America

 

Analysis of user behavior of visitors of the website

(cf. also section 6.2.)

USA

 

EU-US Privacy Shield certification (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active)

 

4.2 USE OF THE NEWSLETTER DELIVERY SERVICE PROVIDER MAILCHIMP

For the delivery of our newsletter, we use the service “MailChimp” of the US provider Rocket Science Group LLC, 675 Ponce De Leon Ave. NE #5000, Atlanta, GA 30308, United States of America, which works as a data processor (Art. 4 no.8 GDPR) on behalf of Culture Shifts.

If you have signed up for our newsletter, your name and email address will be stored on the servers of MailChimp in the United States of America in the context of the use of the services. MailChimp processes and uses this personal data on our behalf for the delivery and evaluation of our newsletter. Furthermore, MailChimp processes this personal data in order to optimize and improve its services.

To this end, the newsletters are provided with a so-called tracking pixel from MailChimp. Said tracking pixel is a pixel-sized file that is accessed by the MailChimp server when our newsletter is opened and via which the technical browser and system information (including your IP address) is collected in order to make technical improvements to the Services. Furthermore, information is collected on whether and when you have opened the newsletter and which links in the newsletter you clicked on. This serves the purpose of evaluating the reading habits of our newsletter recipients in general in order to allow us to customize and optimize our content accordingly.

Please note: If you use the link in the newsletter to access the newsletter online, e.g. for having it properly displayed, you will reach the MailChimp website. In this context, we would like to point out that the MailChimp website might use cookies, tracing pixels, or other technologies beyond our control. Further information is included in the MailChimp Privacy Policy at https://mailchimp.com/legal/privacy.

In addition to your consent (cf. in this regard section 3.2 lit. b and section 7 lit. f, the legitimate interests of Culture Shifts and MailChimp (Art. 6 (1) lit. f GDPR) form the legal basis for the processing of personal data through MailChimp. Said legitimate interests consists in our goal to provide a user-friendly newsletter system to you that meets your expectations and needs and serves our business interests.

If you do not consent to the delivery of the newsletter by MailChimp or the statistical evaluation of the newsletter by MailChimp, you can only withdraw your consent to the receipt of our newsletter in its entirety (cf. section 3.2 lit b). Unfortunately, the withdrawal of individual components is not possible.

5 STORAGE PERIOD

We will only store your personal data for as long as its storage is required for the achievement of the purposes for which it was collected or for the duration of the statutory retention periods, if the law dictates longer retention periods (e.g. Sec. 147 AO [German Fiscal Code] and Sec. 257 HGB [German Commercial Code]). Afterwards, your personal data will be deleted.

6 COOKIES AND WEB ANALYTICS

6.1 COOKIES

We use cookies on the Website and in the context of the Services in order (a) to provide and maintain, as far as technically possible and reasonable, a stable, secure, functioning, and flawlessly running Website; and (b) to allow and to provide to you an optimal and meaningful user experience.

Cookies help us to make your visit to the Website and your use of the Services more comfortable, efficient, and meaningful.

Cookies are text information files that our web server sends to and places on your computer when you are visiting the Website. Most browsers accept cookies automatically but can be configured to not allow the use of cookies via the browser settings. You may refuse the use of cookies or delete the data collected in this context at a later point in time. You do not need to allow the use of cookies to be able to use the Website in general.

Instructions for how to delete cookies in the most common browsers are provided in the following table:

Browser Instructions for deleting cookies
Microsoft Internet Explorer https://support.microsoft.com/en-us/help/278835/how-to-delete-cookie-files-in-internet-explorer
Mozilla Firefox https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox
Google Chrome https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDe
Apple Safari ktop&hl=en-GB
Opera https://support.apple.com/en-gb/guide/safari/sfri11471/mac

6.2 WEB ANALYTICS

On our Website we use Google Analytics. This is a web analysis service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, hereinafter referred to as “Google”.

The Google Analytics service is used to analyze the usage behavior on our Website. Usage and user-related information, such as the IP address, location, time or frequency of the visit to our Website, is transferred to a Google server in the USA and stored there. However, we use Google Analytics with the anonymization function. By using this function, Google truncates the IP address with the EU or EEA. Therefore, we cannot draw any conclusions about your person.

The so collected data is in turn used by Google to provide us with an evaluation of the visit to our Website and the usage activities there. This data may also be used to provide other services related to the use of our Website and the internet. Google states that it does not link your IP address with other data.

The legal basis for the processing of your personal data is our legitimate interest (Art. 6 (1) lit. f GPDR), which consists of analysing and evaluating the economic operation of our Website for optimisation purposes.

Google also offers a deactivation add-on, plus additional information, under https://tools.google.com/dlpage/gaoptout?hl=en. This add-on can be installed on common browsers and offers you a further opportunity to monitor the data captured by Google when you visit our Website. As part of this process, the add-on informs JavaScript (ga.js) of Google Analytics that information about your visit to our online presence is not to be transmitted to Google Analytics.

Google provides further information related to data privacy law under, including instructions for preventing data use under: https://policies.google.com/technologies/partner-sites?hl=en

7 YOUR DATA PROTECTION RIGHTS AS A DATA SUBJECT

According to applicable data protection law, you are, in particular, entitled to the following rights. For this purpose, please contact us via the contact details specified in section 1.

(a) Right to information: You have the right to request at any time information on your personal data stored by us.

(b) Right to rectification: When processing your personal data, we attempt to ensure through appropriate measures that your personal data is correct and up to date for the purposes for which it has been collected. If your personal data is incorrect or incomplete, you may request the rectification of the respective data.

(c) Right to erasure and restriction of processing: You may have the right to request the erasure and/or a restriction of processing of your personal data, e.g. if, according to this Privacy Policy or applicable law, a legitimate business purpose for such processing does no longer exist and if statutory retention obligations do not require a continued storage.

(d) Right to data portability: You may have the right to receive the respective personal data you provided to us in a structured, commonly used, and machine-readable format or to transmit those data to another controller.

(e) Right to object: You may have the right to object, on grounds relating to your particular situation, to the processing of your personal data. Further, you have the right at any time to object to the processing of your personal data for the purposes of direct marketing without any reasons.

(f) Right to withdraw your consent: If you have given consent to the collection and processing of your personal data, you may withdraw your consent at any time with effect for the future; however, the lawfulness of the processing performed based on the consent until its withdrawal shall not be affected by such a withdrawal. In addition, you have the option to object to the use of your personal data for market and opinion research and advertising purposes. Further information on the withdrawal of your consent to receiving our newsletter is available in section 3.2 lit.b.

(g) The competent supervisory authority in case of complaints: Furthermore, you may contact the Commissioner for Data Protection and Freedom of Information of Munich, Wagmüllerstr. 18, 80538 München,Germany, phone: 089-2126720, fax: 089-21267250, e-mail: poststelle@datenschutz-bayern.de , as Culture Shifts competent supervisory authority in case of complaints. A list of other supervisory authorities that you may consider contacting (e.g. the one competent at your place of business) is available at: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.

8 LINKS TO OTHER WEBSITES

The Website may also contain links to other websites. The present Privacy Policy does not apply to these other websites. We ask that you visit these other websites directly in order to obtain information on how these websites protect data and handle your personal data.

9 RIGHT TO MAKE CHANGES

We reserve the right to change this Privacy Policy at any time in accordance with the statutory provisions. Changes may, for example, be required for compliance with new statutory provisions, due to new technologies, or in case of new services.

LAST UPDATE: DECEMBER 2019