Privacy Policy | Manuel Reis de Sousa

1. Data protection at a glance

General information

The following notes provide a simple overview of what happens to your personal data when you visit this website. Personal data is any data by which you can be personally identified. For detailed information on data protection, please refer to our privacy policy listed below this text.

Data collection on this website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find his contact details in the section “Note on the responsible party” in this privacy policy.

How do we collect your data?

On the one hand, your data is collected by you providing it to us. This can be, for example, data that you enter in a contact form.

Other data is collected automatically or after your consent when you visit the website by our IT systems. This is mainly technical data (e.g. Internet browser, operating system or time of page view). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Part of the data is collected to ensure error-free provision of the website. Other data may be used for analysis of your user behavior.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipient and purpose of your stored personal data. You also have a right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. You also have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

For this purpose, as well as for further questions on the subject of data protection, you can contact us at any time.

Analysis tools and third-party tools

When visiting this website, your surfing behavior may be statistically analyzed. This is done primarily with so-called analysis programs.

Detailed information about these analysis programs can be found in the following privacy policy.

2. Hosting

All-Inkl

We host our website at All-Inkl. Provider is ALL-INKL.COM – Neue Medien Münnich, Inh. René Münnich, Hauptstraße 68, 02742 Friedersdorf (hereinafter All-Inkl). For details, please refer to the privacy policy of All-Inkl: https://all-inkl.com/datenschutzinformationen/.

The use of All-Inkl is based on Art. 6 para. 1 lit. f DSGVO. We have a legitimate interest in the most reliable presentation of our website. Insofar as a corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6 Para. 1 lit. a DSGVO and § 25 Para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) as defined by the TTDSG. The consent can be revoked at any time.

Processing of data

We have concluded a data processing agreement (DPA) with the above-mentioned provider. This is a contract required by data protection law, which ensures that this provider only processes the personal data of our website visitors in accordance with our instructions and in compliance with the GDPR.

3. General notes and mandatory information

Privacy

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this privacy policy.

When you use this website, various personal data is collected. Personal data is data with which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We would like to point out that data transmission on the Internet (e.g. when communicating by e-mail) can have security gaps. Complete protection of data against access by third parties is not possible.

Note on the responsible body

The responsible party for data processing on this website is:

Manuel Reis de Sousa
Grönkamp 2
22399 Hamburg

Phone: +49 151 / 146 997 27
E-mail: manuel@reisdesousa.com

The responsible party is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, e-mail addresses or similar).

Storage period

Unless a more specific storage period has been stated within this privacy policy, your personal data will remain with us until the purpose for processing the data no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the data will be deleted once these reasons no longer apply.

General information on the legal basis for data processing on this website

If you have consented to data processing, we process your personal data on the basis of Art. 6 (1) lit. a GDPR or Art. 9 (2) lit. a GDPR, if special categories of data are processed according to Art. 9 (1) GDPR. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49 (1) a GDPR. If you have consented to the storage of cookies or to the access to information in your terminal device (e.g. via device fingerprinting), the data processing is additionally carried out on the basis of Section 25 (1) TTDSG. The consent can be revoked at any time. If your data is required for the performance of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6 para. 1 lit. b GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6 (1) lit. c GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6 para. 1 lit. f GDPR. Information about the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy.

Note on data transfer to the USA and other third countries

Among other things, we use tools from companies based in the USA or other third countries that are not secure under data protection law. If these tools are active, your personal data may be transferred to these third countries and processed there. We would like to point out that no level of data protection comparable to that in the EU can be guaranteed in these countries. For example, US companies are obliged to hand over personal data to security authorities without you as a data subject being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g. intelligence services) process, evaluate and permanently store your data located on US servers for monitoring purposes. We have no influence on these processing activities.

Revocation of your consent to data processing

Many data processing operations are only possible with your express consent. You can revoke consent you have already given at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Right to object to data collection in specific cases and to direct marketing (Art. 21 GDPR).

If the data processing is based on Art. 6 (1) (e) or (f) GDPR, you have the right to object to the processing of your personal data at any time on grounds relating to your particular situation; this also applies to profiling based on these provisions. The respective legal basis on which processing is based can be found in this privacy policy. If you object, we will no longer process your personal data concerned, unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the purpose of asserting, exercising or defending legal claims (objection under Article 21(1) GDPR).

If your personal data is processed for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling, insofar as it is related to such direct marketing. If you object, your personal data will subsequently no longer be used for the purpose of direct marketing (objection pursuant to Article 21 (2) GDPR).

Right of appeal to the competent supervisory authority

In the event of violations of the GDPR, data subjects shall have a right of appeal to a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged violation. The right of appeal is without prejudice to other administrative or judicial remedies.

Right to data portability

You have the right to have data that we process automatically on the basis of your consent or in fulfillment of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another controller, this will only be done insofar as it is technically feasible.

SSL or TLS encryption

For security reasons and to protect the transmission of confidential content, such as orders or requests that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Information, deletion and correction

Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipient and the purpose of data processing and, if necessary, a right to correction or deletion of this data. For this purpose, as well as for further questions on the subject of personal data, you can contact us at any time.

Right to restriction of processing

You have the right to request the restriction of the processing of your personal data. For this purpose, you can contact us at any time. The right to restriction of processing exists in the following cases:

If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the review, you have the right to request the restriction of the processing of your personal data.
If the processing of your personal data happened/is happening unlawfully, you can request the restriction of data processing instead of deletion.
If we no longer need your personal data, but you need it to exercise, defend or assert legal claims, you have the right to request restriction of the processing of your personal data instead of erasure.
If you have lodged an objection pursuant to Art. 21 (1) GDPR, a balancing of your and our interests must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data may – apart from being stored – only be processed with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest of the European Union or a Member State.

Objection to advertising e-mails

The use of contact data published within the framework of the imprint obligation for the transmission of advertising and information material not expressly requested is hereby objected to. The operators of the pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, such as spam e-mails.

4. Data collection on this website

Cookies

Our Internet pages use so-called “cookies”. Cookies are small text files and do not cause any damage to your terminal device. They are stored either temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your end device. Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your end device until you delete them yourself or until they are automatically deleted by your web browser.

In some cases, cookies from third-party companies may also be stored on your terminal device when you enter our site (third-party cookies). These enable us or you to use certain services of the third-party company (e.g. cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies are used to evaluate user behavior or display advertising.

Cookies that are necessary to carry out the electronic communication process, to provide certain functions that you have requested (e.g. for the shopping cart function) or to optimize the website (e.g. cookies for measuring the web audience) (necessary cookies) are stored on the basis of Art. 6 (1) lit. f GDPR, unless another legal basis is specified. The website operator has a legitimate interest in storing necessary cookies for the technically error-free and optimized provision of its services. If consent to the storage of cookies and comparable recognition technologies has been requested, the processing is carried out exclusively on the basis of this consent (Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG); the consent can be revoked at any time.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. If you disable cookies, the functionality of this website may be limited.

Insofar as cookies are used by third-party companies or for analysis purposes, we will inform you separately about this within the framework of this data protection declaration and, if necessary, request your consent.

Server log files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

Browser type and browser version
Operating system used
Referrer URL
Host name of the accessing computer
Time of the server request
IP address

This data is not merged with other data sources.

The collection of this data is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimization of its website – for this purpose, the server log files must be collected.

Contact form

If you send us inquiries via the contact form, your data from the inquiry form including the contact data you provided there will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We do not pass on this data without your consent.

The processing of this data is based on Art. 6 (1) lit. b GDPR, if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the requests sent to us (Art. 6 (1) (f) GDPR) or on your consent (Art. 6 (1) (a) GDPR) if this was requested; the consent can be revoked at any time.

The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies (e.g. after we have completed processing your request). Mandatory legal provisions – in particular retention periods – remain unaffected.

Inquiry by e-mail, telephone or fax

If you contact us by e-mail, telephone or fax, your inquiry including all resulting personal data (name, inquiry) will be stored and processed by us for the purpose of processing your request. We will not pass on this data without your consent.

The data you send to us via contact requests will remain with us until you request us to delete it, revoke your consent to store it or the purpose for storing the data no longer applies (e.g. after your request has been processed). Mandatory legal provisions – in particular legal retention periods – remain unaffected.

5. Analysis tools and advertising

Matomo

This website uses the open source web analytics service Matomo. Matomo uses technologies that enable the recognition of the user across pages for the analysis of user behavior (e.g. cookies or device fingerprinting). The information collected by Matomo about the use of this website is stored on our server. The IP address is anonymized before storage.

With the help of Matomo, we are able to collect and analyze data about the use of our website by website visitors. This allows us to find out, among other things, when which page views were made and from which region they come. We also collect various log files (e.g. IP address, referrer, browsers and operating systems used) and can measure whether our website visitors perform certain actions (e.g. clicks, purchases, etc.).

The use of this analysis tool is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in the anonymized analysis of user behavior in order to optimize both its website and its advertising. Insofar as a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a GDPR and § 25 para. 1 TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) as defined by the TTDSG. The consent can be revoked at any time.

IP anonymization

We use IP anonymization for the analysis with Matomo. Your IP address is shortened before the analysis so that it can no longer be clearly assigned to you.

Hosting

We host Matomo exclusively on our own servers, so all analytics data remains with us and is not shared.

6. Newsletter

Newsletter data

If you would like to receive the newsletter offered on the website, we require an e-mail address from you as well as information that allows us to verify that you are the owner of the e-mail address provided and that you agree to receive the newsletter. Further data is not collected or only on a voluntary basis. For the handling of the newsletter we use newsletter service providers, which are described below.

Sendinblue

This website uses Sendinblue to send newsletters. The provider is Sendinblue GmbH, Köpenicker Straße 126, 10179 Berlin, Germany.

Sendinblue is a service with which, among other things, the sending of newsletters can be organized and analyzed. The data you enter for the purpose of receiving the newsletter is stored on Sendinblue’s servers in Germany.

Data analysis through Sendinblue

With the help of Sendinblue, we are able to analyze our newsletter campaigns. For example, we can see whether a newsletter message was opened and which links, if any, were clicked. In this way, we can determine, among other things, which links were clicked on particularly often.

In addition, we can see whether certain previously defined actions were performed after opening/clicking (conversion rate). For example, we can see whether you have made a purchase after clicking on the newsletter.

Sendinblue also allows us to subdivide (“cluster”) the newsletter recipients based on various categories. In doing so, newsletter recipients can be subdivided by age, gender or place of residence, for example. In this way, the newsletters can be better adapted to the respective target groups.

If you do not want any analysis by Sendinblue, you must unsubscribe from the newsletter. For this purpose, we provide a corresponding link in every newsletter message.

For detailed information on the Sendinblue functions, please refer to the following link: https://de.sendinblue.com/newsletter-software/.

Legal basis

The data processing is based on your consent (Art. 6 para. 1 lit. a GDPR). You can revoke this consent at any time. The legality of the data processing operations already carried out remains unaffected by the revocation.

Storage period

The data you provide for the purpose of receiving the newsletter will be stored by us or the newsletter service provider until you unsubscribe from the newsletter and will be deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data that has been stored by us for other purposes remains unaffected by this.

After you have unsubscribed from the newsletter distribution list, your e-mail address will be stored by us or the newsletter service provider in a blacklist if necessary to prevent future mailings. The data from the blacklist will only be used for this purpose and will not be merged with other data. This serves both your interest and our interest in complying with legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 Para. 1 lit. f GDPR). The storage in the blacklist is not limited in time. You can object to the storage if your interests outweigh our legitimate interest.

For more details, please see Sendinblue’s privacy policy at: https://de.sendinblue.com/datenschutz-uebersicht/.

Order processing

We have concluded an order processing agreement (AVV) with the above-mentioned provider. This is a contract required by data protection law, which ensures that this provider only processes the personal data of our website visitors in accordance with our instructions and in compliance with the GDPR.

7. Plugins and Tools

YouTube with enhanced privacy

This website embeds videos from YouTube. The operator of the pages is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

We use YouTube in extended data protection mode. According to YouTube, this mode means that YouTube does not store any information about visitors to this website before they watch the video. However, the transfer of data to YouTube partners is not necessarily excluded by the extended data protection mode. Thus, YouTube – regardless of whether you watch a video – establishes a connection to the Google DoubleClick network.

As soon as you start a YouTube video on this website, a connection to the YouTube servers is established. This tells the YouTube server which of our pages you have visited. If you are logged into your YouTube account, you enable YouTube to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account.

Furthermore, YouTube can save various cookies on your end device after starting a video or use comparable recognition technologies (e.g. device fingerprinting). In this way, YouTube can obtain information about visitors to this website. This information is used, among other things, to collect video statistics, improve the user experience, and prevent fraud attempts.

If necessary, further data processing processes may be triggered after the start of a YouTube video, over which we have no influence.

YouTube is used in the interest of an appealing presentation of our online offers. This represents a legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR. Insofar as a corresponding consent has been requested, processing is carried out exclusively on the basis of Art. 6 (1) lit. a GDPR and Section 25 (1) TTDSG, insofar as the consent includes the storage of cookies or access to information in the user’s terminal device (e.g. device fingerprinting) within the meaning of the TTDSG. The consent can be revoked at any time.

For more information about privacy at YouTube, please see their privacy policy at: https://policies.google.com/privacy?hl=de.

8. Audio and video conferencing

Data processing

We use online conferencing tools, among others, to communicate with our customers. The specific tools we use are listed below. When you communicate with us via video or audio conference over the Internet, your personal data is collected and processed by us and the provider of the respective conference tool.

In doing so, the conferencing tools collect all data that you provide/enter to use the tools (email address and/or your phone number). Furthermore, the conference tools process the duration of the conference, start and end (time) of participation in the conference, number of participants and other “context information” related to the communication process (metadata).

Furthermore, the provider of the tool processes all technical data required to handle the online communication. This includes in particular IP addresses, MAC addresses, device IDs, device type, operating system type and version, client version, camera type, microphone or speaker, and the type of connection.

If content is exchanged, uploaded or otherwise made available within the tool, this is also stored on the servers of the tool providers. Such content includes, in particular, cloud recordings, chat/ instant messages, voicemails uploaded photos and videos, files, whiteboards, and other information shared while using the service.

Please note that we do not have full control over the data processing operations of the tools used. Our options are largely based on the company policy of the respective provider. For further information on data processing by the conference tools, please refer to the privacy statements of the respective tools used, which we have listed below this text.

Purpose and legal basis

The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6 para. 1 lit. b GDPR). Furthermore, the use of the tools serves the general simplification and acceleration of communication with us or our company (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). Insofar as consent has been requested, the tools in question are used on the basis of this consent; consent can be revoked at any time with effect for the future.

Storage period

The data collected directly by us via the video and conference tools is deleted from our systems as soon as you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies. Stored cookies remain on your terminal device until you delete them. Mandatory legal retention periods remain unaffected.

We have no influence on the storage period of your data, which is stored by the operators of the conference tools for their own purposes. For details, please contact the operators of the conference tools directly.

Conference tools used

We use the following conferencing tools:

Zoom

We use Zoom. The provider of this service is Zoom Communications Inc, San Jose, 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA. For details on data processing, please refer to Zoom’s privacy policy: https://zoom.us/de-de/privacy.html.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://zoom.us/de-de/privacy.html.