PRIVACY POLICY
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GENERAL
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This Privacy Policy provides you, in accordance with Article 13 GDPR (EU General Data Protection Regulation), with information on the processing of personal data by SHARP Interactive GmbH (hereinafter: „we", „us") when you visit our website or contact us.
As a rule we process data that you provide only for those purposes for which we have collected such data. We will process your data for other purposes only where there is another legal basis for the processing, in particular when we transfer data to third parties.
DATA CONTROLLER
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Contact data of the data controller:
SHARP Interactive GmbH
Wichertstraße 50a
10439 Berlin
Telefon: +49 176 43431227
E-Mail: contact@sharp-interactive.com
WHEN YOU VISIT OUR WEBSITE
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You can visit our website without registering or providing any personal information. Our website does not use cookies for tracking or analytics purposes. Only technically necessary cookies required for the basic functioning of the website may be set by our hosting provider.
3.1 LOG FILES
Whenever you access our website, our hosting provider collects the following information: IP address, information on your browser software and operating system, the contents you access, as well as date and time. This data will be stored for a limited period. The processing of personal data is based on our legitimate interests in the prevention and prosecution of unauthorized use and in ensuring the stability and security of our website. The legal basis is Article 6(1)(f) GDPR.
3.2 ANALYTICS
We use Framer Analytics, a privacy-friendly analytics tool provided by our hosting provider Framer B.V. Framer Analytics does not use cookies and does not collect personal data that could be used to identify individual users. It collects aggregated information such as page views, referrers, country and device type. The legal basis for this processing is Article 6(1)(f) GDPR (legitimate interest in analyzing the use of the website in order to improve and optimize the information we provide).
3.3 EMBEDDED AUDIO
Our website contains audio content hosted by Cloudinary Ltd. When you load a page containing this audio, your IP address is transmitted to Cloudinary so that the content can be delivered to your browser. Cloudinary does not set tracking cookies on our website. The legal basis is Article 6(1)(f) GDPR (legitimate interest in providing rich media content on our website).
3.4 EMBEDDED YOUTUBE VIDEO
Our website contains a video trailer embedded from YouTube (a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) in privacy-enhanced mode (youtube-nocookie.com). The video is embedded in a click-to-play manner: no connection to YouTube servers is established and no data is transmitted to YouTube until you actively click the play button to watch the video. Only after you initiate playback is a connection to YouTube established, at which point YouTube may receive information including your IP address and may set cookies or similar technologies required to deliver the video. By clicking play, you actively consent to this data transmission. No consent banner is necessary for the mere presence of the embed, as no data is transmitted until you explicitly request playback.
For information on how YouTube/Google processes personal data, please refer to Google's Privacy Policy at https://policies.google.com/privacy.
The legal basis for the data transmission initiated by your playback is Article 6(1)(a) GDPR (consent, expressed through the act of clicking play) and Article 6(1)(f) GDPR (legitimate interest in providing video content).
3.5 WHEN YOU CONTACT US
When you contact us via email, we will process the personal data you provide, including the subject-matter of your request, in order to handle your request. The legal basis of the processing is Article 6(1)(b) GDPR (taking steps prior to entering into a contract) or Article 6(1)(f) GDPR (legitimate interest in responding to inquiries).
3.6 NEWSLETTER
If you register for our newsletter via the subscribe form on our website, we will process your email address for the purpose of sending you updates about our projects, including BAZA. The form is handled by our service provider Formspree (see section 5), which forwards your submission to our contact email. The legal basis for processing your email address is your consent pursuant to Article 6(1)(a) GDPR. You may withdraw your consent at any time with effect for the future, for example by replying to any of our emails or contacting us at contact@sharp-interactive.com.
PURSUIT OF LEGITIMATE INTERESTS
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Where this is necessary, we will process your data beyond the purposes stated above also for the pursuit of legitimate interests. Such legitimate interests include: customer relations management; development and optimization of our services; establishment, exercise or defense of legal claims; ensuring the safety of our operations.
RECIPIENTS OF PERSONAL DATA / PROCESSORS
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We employ service providers which process personal data on our behalf and limited to our instructions (processors according to Article 28 GDPR). Where data is transferred to countries outside the European Economic Area, the transfer is safeguarded by Standard Contractual Clauses pursuant to Article 46(2)(c) GDPR.
Our processors are:
Framer B.V., Bloemgracht 82-HS, 1015TM Amsterdam, Netherlands (website hosting and analytics)
Cloudinary Ltd., 3400 Central Expressway, Suite 110, Santa Clara, CA 95051, USA (media hosting for audio content)
Formspree Inc., 1111B S Governors Ave #6823, Dover, DE 19904, USA (handling of newsletter subscription form submissions)
In addition, when you actively choose to play the embedded YouTube video (see section 3.4), data is transmitted to Google Ireland Limited (YouTube). Google is not a processor of ours but an independent controller for the data it receives upon video playback.
COMPLIANCE WITH LEGAL OBLIGATIONS
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We also process your data if this is necessary for compliance with a legal obligation to which we are subject. This applies in particular when we store your data beyond a contractual relationship due to legal obligations to retain data under commercial law or tax law and when we provide information to courts and authorities, e.g. the tax office. The legal basis is Article 6(1)(c) GDPR (compliance with a legal obligation).
CONSENT
We will process your data for purposes for which none of the abovementioned legal bases applies only with your consent. Where personal data is processed based on your consent, you may, pursuant to Article 7(3) GDPR, withdraw your consent at any time with effect for the future.
PERIOD FOR WHICH PERSONAL DATA IS STORED
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8.1 GENERAL
We store personal data only as long as it is necessary for the relevant purpose.
8.2 LEGAL OBLIGATIONS TO RETAIN DATA
To the extent that there are legal obligations to retain data, in particular in accordance with commercial law and tax law, the relevant personal data will be stored for the term of such obligation. After this term has expired we will consider if the processing is still necessary. If it is not necessary any more, the data will be erased. The obligation to retain data has a term of six years (for business correspondence and other documents) or ten years (for accounting records and invoices). Where we store data for the pursuit of legitimate interests by establishing, exercising or defending legal claims, the period of storage is determined by the statute of limitation. The regular statute of limitation according to Sections 195 et seq. of the German Civil Code is three years from the end of the year in which the claim arose and the obligee obtained knowledge of the circumstances giving rise to the claim.
8.3 NEWSLETTER
We will store your email address for as long as you remain subscribed to our newsletter. If you withdraw your consent, your email address will be erased, unless legal retention obligations apply.
YOUR RIGHTS AS A DATA SUBJECT
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Where the respective legal requirements are met, you have the following rights: You have the right to obtain information on what personal data relating to you are stored (Article 15 GDPR). You have the right to request the rectification of inaccurate data (Article 16 GDPR). You have the right to request the erasure (Article 17 GDPR) or the restriction of processing (Article 18 GDPR) of data which is no longer necessary. Where there is a legal obligation to retain data, e.g. for business correspondence according to commercial law and tax law, or another statutory exception, data will not be erased, but the processing will be restricted. You have the right to data portability (Article 20 GDPR), i.e. the right to receive the data you have provided to us in a structured, commonly used and machine-readable format and to transmit this data to another controller without hindrance from us; this may include the right to have such data transmitted directly to another controller where technically feasible. If you consider that the processing of your data infringes data protection laws, you have the right to lodge a complaint with a supervisory authority (Article 77 GDPR). The supervisory authority with local jurisdiction for us is: Die Berliner Beauftragte für Datenschutz und Informationsfreiheit, Friedrichstr. 219, 10969 Berlin, www.datenschutz-berlin.de.
RIGHT TO OBJECT
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You may at any time object to the processing of your data for direct marketing purposes according to Article 21(2) GDPR.
You may at any time object to the processing of your data for the pursuit of legitimate interests on grounds relating to your particular situation according to Article 21(1) GDPR. Unless one of the statutory exemptions applies, we will no longer process your data for that purpose.