Privacy Policy
We take the protection of your personal data very seriously. This privacy policy informs you about how ECO EFX Solutions GmbH processes personal data on this website and what rights you have as a data subject.
Table of Contents
1. Controller and Data Protection Officer
Controller within the meaning of the GDPR
ECO EFX Solutions GmbH
Hamburger Straße 180
22083 Hamburg
Germany
Phone: +49-40-298 234 60
Fax: +49-40-298 234 61
Email: info@ecoefxsol.com
Managing Director: Sven-Oliver Robertson
Commercial Register: AG Hamburg HRB 185253
VAT ID: DE368007707
Data Protection Officer
Our Data Protection Officer is available to answer any questions about data protection:
Sven-Oliver Robertson
Data Protection Officer
ECO EFX Solutions GmbH
Hamburger Straße 180
22083 Hamburg
Germany
Email: cp@ecoefxsol.com
2. Principles of Data Processing
When processing personal data, we observe the following principles in accordance with Art. 5 GDPR:
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Lawfulness, fairness and transparency: We only process your data on a lawful basis and inform you transparently about the processing.
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Purpose limitation: We only collect your data for specified, explicit and legitimate purposes.
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Data minimization: We only process data that is necessary for the respective purpose.
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Accuracy: We ensure that your data is accurate and up to date.
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Storage limitation: We only store your data for as long as necessary for the respective purpose.
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Integrity and confidentiality: We protect your data through appropriate technical and organizational measures.
3. Legal Basis for Processing
The processing of personal data is based on the following legal grounds under the GDPR:
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Art. 6 (1) lit. a GDPR: Consent of the data subject
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Art. 6 (1) lit. b GDPR: Processing for the performance of a contract or pre-contractual measures
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Art. 6 (1) lit. c GDPR: Processing for compliance with a legal obligation
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Art. 6 (1) lit. f GDPR: Processing for the purposes of legitimate interests
4. Data Collection When Visiting the Website
4.1 Server Log Files
When you visit our website, our web server automatically collects certain information in server log files. This data is technically necessary for the display of the website and to ensure stability and security.
Collected data includes:
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IP address of the accessing computer (anonymized after 7 days)
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Date and time of access
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Name and URL of the retrieved file
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Amount of data transferred
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Notification of successful retrieval (HTTP response code)
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Browser type and browser version
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Operating system
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Referrer URL (previously visited page)
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Hostname of the accessing computer
Purpose of processing:
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Ensuring smooth connection establishment
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Ensuring comfortable use of our website
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Evaluation of system security and stability
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Detection and prevention of security threats
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Technical administration and optimization
Legal basis: Art. 6 (1) lit. f GDPR (legitimate interest in the technical functionality and security of the website)
Retention period: The data is deleted as soon as it is no longer required to achieve the purpose for which it was collected, at the latest after 7 days. IP addresses are anonymized after this period.
4.2 SSL/TLS Encryption
For security reasons and to protect the transmission of confidential content, this website uses SSL/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.
When SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties. This protects your personal data during transmission.
5. Cookies and Similar Technologies
5.1 What are Cookies?
Our website uses cookies. Cookies are small text files that are stored on your device and that your browser stores. They are used to make our offer more user-friendly, effective and secure. Some cookies remain on your device until you delete them. They allow us to recognize your browser on your next visit.
5.2 Types of Cookies We Use
Technically Necessary Cookies (Session Cookies)
These cookies are required for the basic functions of the website and cannot be deactivated.
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Purpose: Enabling navigation and basic functions, session management, security features
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Legal basis: Art. 6 (1) lit. f GDPR (technical necessity)
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Retention period: Session (deleted after closing the browser)
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Examples: Login status, shopping cart, language preferences, security tokens
Functional Cookies
These cookies enable advanced functionalities and personalization.
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Purpose: Storage of settings and preferences, improved user experience
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Legal basis: Art. 6 (1) lit. a GDPR (consent via cookie banner)
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Retention period: Up to 12 months
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Examples: Font size settings, video player preferences, chat widget settings
Analytics Cookies
These cookies help us understand how visitors interact with our website by collecting and reporting information anonymously.
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Purpose: Statistical evaluation of website usage, performance measurement, user behavior analysis
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Legal basis: Art. 6 (1) lit. a GDPR (consent via cookie banner)
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Retention period: Up to 24 months
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Data collected: Page views, session duration, bounce rate, traffic sources, geographic location (country level)
Marketing Cookies
These cookies are used to display relevant advertising to visitors and track campaign effectiveness.
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Purpose: Delivery of personalized advertising, retargeting, campaign measurement
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Legal basis: Art. 6 (1) lit. a GDPR (consent via cookie banner)
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Retention period: Up to 24 months
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Third parties: May include cookies from advertising networks
5.3 Cookie Management and Your Choices
You have full control over cookies on our website:
Cookie Consent Banner: When you first visit our website, you will see a cookie consent banner where you can:
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Accept all cookies
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Reject all non-essential cookies
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Customize your preferences by cookie category
Browser Settings: You can also configure your browser settings to:
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Block all cookies
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Accept only first-party cookies
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Receive a notification before a cookie is stored
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Delete cookies after each browser session
Important: If you block all cookies, some features of our website may not function properly. Technically necessary cookies are required for basic website functionality.
5.4 Tracking Technologies and Web Beacons
In addition to cookies, we may use other tracking technologies:
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Web Beacons (Pixel Tags): Small, invisible images embedded in web pages or emails to track user behavior and email open rates
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Local Storage: HTML5 local storage for storing preferences and session data
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Fingerprinting Prevention: We do not use browser fingerprinting techniques
5.5 Wix-Specific Cookies
Since our website is hosted on the Wix platform, the website also uses Wix-specific cookies for:
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Session management and security
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Website analytics and performance monitoring
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A/B testing and website optimization
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Visitor authentication and preferences
For detailed information about Wix cookies, please see Wix's Privacy Policy and Wix Cookie Policy.
6. Contact Form and Email Contact
6.1 Contact Form
When you send us inquiries via the contact form, your details from the inquiry form, including the contact details you provide there, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions.
Processed data:
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Full name (required)
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Email address (required)
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Phone number (optional)
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Company name (optional)
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Message content (required)
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Time of inquiry (automatically recorded)
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IP address (for spam prevention, automatically deleted after 7 days)
Purpose: Processing your inquiry and communication with you, customer support, business correspondence
Legal basis: Art. 6 (1) lit. b GDPR (pre-contractual measures) or Art. 6 (1) lit. f GDPR (legitimate interest in answering inquiries)
Data storage: Your inquiry data is stored in our customer relationship management (CRM) system
Retention period: Until your inquiry has been fully processed, then according to statutory retention periods (typically 3 years for business correspondence)
Data security: All form submissions are encrypted via SSL/TLS. We use CAPTCHA or similar anti-spam measures to prevent automated submissions.
6.2 Email Contact
If you contact us by email, the data you transmit will be stored by us for the purpose of processing your inquiry.
Processed data:
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Email address
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Email content
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Attachments (if any)
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Email metadata (timestamp, subject line)
Legal basis: Art. 6 (1) lit. f GDPR (legitimate interest in communication)
Retention period: Emails are stored until the matter is resolved, then according to statutory retention periods. Business-related emails may be stored for up to 10 years due to tax law requirements.
Please note: Email communication is not always secure. For sensitive information, please use our encrypted contact form or contact us by phone.
7. Newsletter
7.1 Newsletter Subscription
With your consent, you can subscribe to our newsletter, which informs you about our latest products, services, and company news.
Newsletter data:
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Email address (required)
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First name and last name (optional)
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Company name (optional)
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Industry/interests (optional)
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Subscription date and time
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IP address at time of subscription (for legal protection)
Double Opt-In Procedure: After registration, you will receive a confirmation email with a link to verify your email address. Your newsletter subscription only becomes active after clicking this confirmation link. This prevents misuse of your email address.
Legal basis: Art. 6 (1) lit. a GDPR (consent)
Purpose: Sending marketing communications, product updates, industry news, special offers
7.2 Newsletter Service Provider
We use the following service provider for sending newsletters:
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Email service provider for newsletter distribution
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Analytics for tracking open rates and click rates
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Segmentation and personalization tools
We have concluded a data processing agreement with our newsletter service provider to ensure GDPR compliance.
7.3 Newsletter Analytics
Our newsletters contain tracking technologies to measure:
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Open Rate: Whether and when you opened the newsletter (via invisible tracking pixel)
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Click Rate: Which links you clicked in the newsletter
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Device Information: Type of device used to open the newsletter
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Geographic Location: Approximate location based on IP address
This data helps us improve our newsletter content and relevance.
7.4 Unsubscribe
You can unsubscribe from the newsletter at any time:
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Click the "Unsubscribe" link at the bottom of any newsletter
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Send an email to info@ecoefxsol.com with subject "Unsubscribe"
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Contact our data protection officer at cp@ecoefxsol.com
After unsubscribing, your email address will be removed from our newsletter distribution list within 48 hours. We may retain your email address on a suppression list to prevent future newsletter subscriptions.
8. Social Media Plugins
Our website uses social media plugins from the following services. We use the "2-click solution" to protect your privacy - plugins are deactivated by default and only connect to the social network when you actively click on them.
8.1 LinkedIn
We use plugins from the professional network LinkedIn (LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA; European headquarters: LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland).
Functions: Share button, LinkedIn profile display, company page integration
Data transmitted: IP address, browser information, page visited, LinkedIn user ID (if logged in)
LinkedIn Privacy Policy: https://www.linkedin.com/legal/privacy-policy
8.2 Facebook
Plugins from the social network Facebook are integrated on this website (Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland).
Functions: Like button, Share button, Facebook page plugin
Data transmitted: IP address, browser information, page visited, Facebook user ID (if logged in), cookies
Facebook Privacy Policy: https://www.facebook.com/privacy/explanation
8.3 Instagram
We use plugins from Instagram (Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland).
Functions: Instagram feed display, Instagram stories, profile integration
Data transmitted: IP address, browser information, page visited, Instagram user ID (if logged in)
Instagram Privacy Policy: https://help.instagram.com/519522125107875
8.4 X (formerly Twitter)
Functions of the X service are integrated on this website (X Corp., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA).
Functions: Tweet button, timeline integration, X profile display
Data transmitted: IP address, browser information, page visited, X user ID (if logged in)
X Privacy Policy: https://twitter.com/en/privacy
8.5 TikTok
We use plugins from TikTok (TikTok Technology Limited, 10 Earlsfort Terrace, Dublin, D02 T380, Ireland; TikTok Inc., 5800 Bristol Parkway, Suite 100, Culver City, CA 90230, USA).
Functions: TikTok video embed, TikTok profile integration
Data transmitted: IP address, browser information, page visited, TikTok user ID (if logged in), device information
TikTok Privacy Policy: https://www.tiktok.com/legal/privacy-policy
8.6 Truth Social
We use plugins from Truth Social (T Media Tech LLC, 529 14th Street NW, Suite 1050, Washington, DC 20045, USA).
Functions: Truth Social sharing, profile integration, post embedding
Data transmitted: IP address, browser information, page visited, Truth Social user ID (if logged in)
Truth Social Privacy Policy: https://truthsocial.com/privacy-policy
8.7 Privacy Protection - 2-Click Solution
Important Privacy Feature: All social media plugins on our website are initially deactivated (2-click solution). This means:
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First Visit: No data is transmitted to social networks when you visit our page
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Activation: You must actively click on the plugin to activate it
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After Activation: Data transfer occurs and the plugin functions normally
Legal basis: Art. 6 (1) lit. a GDPR (consent through activation)
Purpose: Integration of social media content, increasing the reach of our content, social proof
9. Google Maps
This website uses Google Maps, a map service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").
9.1 Functionality and Purpose
Google Maps allows us to display interactive maps directly on our website and enables you to easily use the map function. This improves usability and helps visitors find our locations.
Features used:
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Interactive map display of our office locations
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Route planning and directions
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Street view integration
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Location markers and information windows
9.2 Data Processing
When you visit a page with an integrated Google Map, the following data is transmitted to Google:
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IP address of your device
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Date and time of your visit
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URL of the visited page
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Browser information and device type
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Operating system information
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Geographic location data (if you have enabled location services)
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Map interactions (zoom, pan, clicks)
This data is processed by Google to provide the map service and may be transmitted to Google servers in the USA.
9.3 Legal Basis and Consent
Legal basis: Art. 6 (1) lit. a GDPR (consent via cookie banner) or Art. 6 (1) lit. f GDPR (legitimate interest in user-friendly presentation of our locations)
We use Google Maps with the "2-click solution" - the map is only loaded and data transmitted to Google after you actively consent by clicking.
9.4 Data Transfer to Third Countries
Google processes data partly in the USA. Data transfer to the USA is based on EU Standard Contractual Clauses. Google is also certified under the EU-US Data Privacy Framework.
Google Maps Privacy Policy: https://policies.google.com/privacy
Google Maps Terms of Service: https://www.google.com/intl/en_US/help/terms_maps/
9.5 Opt-Out
You can prevent Google Maps from loading by:
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Not clicking on the map activation button on our website
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Disabling JavaScript in your browser (this will affect website functionality)
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Managing your Google account settings at https://adssettings.google.com
10. YouTube
Our website embeds videos from YouTube, a service operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").
10.1 Extended Privacy Mode
We use YouTube in "extended privacy mode" (youtube-nocookie.com). This means that YouTube does not store information about visitors to this website unless they actively play a video.
Before video playback: No cookies are set and no data is transmitted to YouTube
After clicking play: YouTube may set cookies and collect the following data:
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IP address
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Date and time of visit
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URL of the page containing the video
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Browser information and device type
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Video playback behavior (pause, rewind, watch duration)
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YouTube user ID (if logged into YouTube)
10.2 Purpose of Data Processing
YouTube uses this data to:
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Provide video streaming functionality
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Analyze video performance and viewer engagement
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Display personalized video recommendations
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Prevent fraud and abuse
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Display advertising (if applicable)
10.3 Legal Basis
Legal basis: Art. 6 (1) lit. a GDPR (consent via activation) or Art. 6 (1) lit. f GDPR (legitimate interest in attractive presentation of content)
10.4 Data Transfer
YouTube may transfer data to Google LLC in the USA. This transfer is based on EU Standard Contractual Clauses and Google's certification under the EU-US Data Privacy Framework.
YouTube Privacy Policy: https://policies.google.com/privacy
YouTube Terms of Service: https://www.youtube.com/t/terms
10.5 Your Choices
You can control YouTube data collection by:
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Not playing embedded videos
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Logging out of your YouTube/Google account before visiting our site
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Managing your Google advertising settings at https://adssettings.google.com
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Using browser extensions that block YouTube tracking
11. Web Analytics and Marketing
11.1 Wix Analytics
This website uses Wix Analytics, a web analytics service provided by Wix.com Ltd., 40 Hanamal Tel Aviv St., Tel Aviv 6350671, Israel.
Collected data:
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Page views and unique visitors
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Session duration and bounce rate
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Traffic sources (direct, search, referral, social)
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Geographic location (country, city level)
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Device type, browser, and operating system
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Screen resolution and viewport size
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User flow and navigation paths
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Form submissions and conversion tracking
Purpose: Understanding user behavior, improving website performance, optimizing user experience, measuring marketing effectiveness
Legal basis: Art. 6 (1) lit. a GDPR (consent via cookie banner)
Data processing: Wix Analytics uses cookies and may store data for up to 24 months
IP anonymization: IP addresses are anonymized before storage
11.2 Conversion Tracking
We track conversions to measure the effectiveness of our marketing campaigns:
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Contact form submissions
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Newsletter sign-ups
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Download of product information
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Specific page visits (e.g., pricing page)
This data is aggregated and anonymized for reporting purposes.
11.3 Opt-Out from Analytics
You can opt out of web analytics by:
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Rejecting analytics cookies in our cookie banner
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Using browser "Do Not Track" settings
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Installing browser extensions that block analytics scripts
12. Hosting and Content Delivery
12.1 Wix.com Hosting
Our website is hosted on the Wix.com platform. The provider is Wix.com Ltd., 40 Hanamal Tel Aviv St., Tel Aviv 6350671, Israel.
Wix is a comprehensive tool for creating and hosting websites. When you visit our website, Wix collects various log files including your IP addresses for security and performance purposes.
Wix processes the following data:
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Server log files (see section 4.1)
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Website performance metrics
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Security and abuse detection data
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CDN (Content Delivery Network) data for fast content delivery
Legal basis: Art. 6 (1) lit. f GDPR (legitimate interest in secure and efficient provision of our website)
Data Processing Agreement: We have concluded a comprehensive data processing agreement (DPA) with Wix that ensures:
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Processing only according to our instructions
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Compliance with GDPR requirements
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Appropriate technical and organizational measures
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Confidentiality obligations for Wix employees
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Support for data subject rights
12.2 Content Delivery Network (CDN)
Wix uses a global CDN to deliver website content efficiently:
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Faster loading times through geographically distributed servers
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Improved reliability and uptime
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DDoS protection and security features
CDN servers may temporarily cache your IP address and request data for performance optimization.
12.3 Data Security Measures
Wix implements comprehensive security measures:
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SSL/TLS encryption for all data transmission
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Regular security audits and penetration testing
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24/7 security monitoring
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Compliance with SOC 2, ISO 27001, and other security standards
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Regular backups and disaster recovery procedures
12.4 Data Location and International Transfers
Wix's servers are located in multiple regions:
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Primary data centers in the USA and Israel
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European data centers for EU visitors (where possible)
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Global CDN network for content delivery
Legal safeguards for international transfers:
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EU Standard Contractual Clauses (SCCs)
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Adequacy decision for Israel (Commission Implementing Decision 2011/61/EU)
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Additional safeguards including encryption and access controls
Wix Privacy Policy: https://www.wix.com/about/privacy
Wix Security: https://www.wix.com/about/security
13. Data Security
We take the protection of your personal data very seriously and implement comprehensive technical and organizational measures to protect your data against accidental or intentional manipulation, loss, destruction, or access by unauthorized persons.
13.1 Technical Security Measures
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Encryption: SSL/TLS encryption for all data transmission; AES-256 encryption for data at rest
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Firewalls: Multiple layers of firewall protection
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Intrusion Detection: 24/7 monitoring and intrusion detection systems
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Access Control: Multi-factor authentication for administrative access
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Regular Updates: Automatic security updates and patch management
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Backups: Daily encrypted backups with offsite storage
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DDoS Protection: Protection against distributed denial-of-service attacks
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Vulnerability Scanning: Regular security scans and penetration testing
13.2 Organizational Security Measures
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Access Management: Strict access controls based on need-to-know principle
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Employee Training: Regular data protection and security training for all employees
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Confidentiality Agreements: All employees sign confidentiality agreements
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Incident Response: Documented incident response procedures
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Data Protection Impact Assessments: Regular DPIAs for high-risk processing
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Third-Party Management: Due diligence and monitoring of data processors
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Physical Security: Secure server rooms with restricted access
13.3 Security Certifications and Compliance
Our hosting provider Wix maintains the following certifications:
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ISO/IEC 27001 (Information Security Management)
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ISO/IEC 27018 (Cloud Privacy)
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SOC 2 Type II (Security, Availability, Confidentiality)
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PCI DSS (Payment Card Industry Data Security Standard)
13.4 Data Breach Notification
In the unlikely event of a data breach affecting your personal data, we will:
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Notify the relevant supervisory authority within 72 hours
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Notify affected individuals without undue delay if there is a high risk to their rights and freedoms
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Provide information about the nature of the breach and measures taken
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Offer advice on protective measures you can take
13.5 Continuous Improvement
Our security measures are continuously reviewed and improved in line with:
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Technological developments
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Emerging threats and vulnerabilities
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Regulatory requirements and best practices
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Results from security audits and assessments
14. Your Rights as a Data Subject
Under the GDPR, you have comprehensive rights regarding your personal data. You can exercise these rights at any time by contacting us.
14.1 Right of Access (Art. 15 GDPR)
You have the right to request confirmation from us as to whether and what personal data we process about you. You can request information about:
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The purposes of processing
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The categories of personal data concerned
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The recipients or categories of recipients to whom the data has been or will be disclosed
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The envisaged period for which the data will be stored
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The existence of the right to rectification, erasure, restriction, or objection
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The right to lodge a complaint with a supervisory authority
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Where the data was not collected from you, any available information as to its source
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The existence of automated decision-making, including profiling
We will provide you with a copy of your personal data free of charge. For additional copies, we may charge a reasonable administrative fee.
14.2 Right to Rectification (Art. 16 GDPR)
You have the right to request the rectification of inaccurate personal data or the completion of incomplete personal data stored by us without undue delay.
How to exercise: Contact us with the corrected information, and we will update your data within one month.
14.3 Right to Erasure ("Right to be Forgotten") (Art. 17 GDPR)
You have the right to request the erasure of your personal data without undue delay if one of the following grounds applies:
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The data is no longer necessary for the purposes for which it was collected
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You withdraw your consent and there is no other legal ground for processing
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You object to the processing and there are no overriding legitimate grounds
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The data has been unlawfully processed
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Erasure is necessary to comply with a legal obligation
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The data was collected in relation to information society services offered to children
Exceptions: We may not be able to erase your data if retention is necessary for:
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Compliance with legal obligations
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Establishment, exercise, or defense of legal claims
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Archiving purposes in the public interest, scientific or historical research, or statistical purposes
14.4 Right to Restriction of Processing (Art. 18 GDPR)
You have the right to request the restriction of processing if:
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You contest the accuracy of the data (restriction during verification period)
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The processing is unlawful, but you oppose erasure and request restriction instead
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We no longer need the data, but you need it for legal claims
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You have objected to processing pending verification of whether our legitimate grounds override yours
During restriction, we may only process your data with your consent or for legal claims, protection of others' rights, or important public interests.
14.5 Right to Data Portability (Art. 20 GDPR)
You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit this data to another controller where:
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The processing is based on consent or contract
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The processing is carried out by automated means
We will provide your data in common formats such as CSV, JSON, or XML.
14.6 Right to Object (Art. 21 GDPR)
You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Art. 6 (1) lit. e (public interest) or f (legitimate interests) GDPR, including profiling based on those provisions.
We will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing serves the establishment, exercise, or defense of legal claims.
Direct Marketing: If your data is processed for direct marketing purposes, you have the right to object at any time. If you object, we will immediately stop processing your data for direct marketing purposes.
14.7 Right to Withdraw Consent (Art. 7 (3) GDPR)
Where processing is based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
How to withdraw consent:
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For cookies: Adjust your cookie preferences via our cookie banner
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For newsletter: Click unsubscribe link in any newsletter
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For all other processing: Contact us at cp@ecoefxsol.com
14.8 Right to Lodge a Complaint (Art. 77 GDPR)
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, place of work, or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.
Competent supervisory authority for our company:
The Hamburg Commissioner for Data Protection and Freedom of Information
Ludwig-Erhard-Straße 22
20459 Hamburg
Germany
Phone: +49 40 428 54-4040
Fax: +49 40 428 54-4000
Email: mailbox@datenschutz.hamburg.de
Website: https://datenschutz-hamburg.de
You can also contact the supervisory authority in your own country. A list of EU supervisory authorities is available at: https://edpb.europa.eu/about-edpb/board/members_en
14.9 Automated Individual Decision-Making, Including Profiling (Art. 22 GDPR)
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
Our practice: We do not use automated decision-making or profiling that produces legal effects or similarly significantly affects you. Any analytics or personalization on our website does not result in automated decisions that affect your rights.
14.10 How to Exercise Your Rights
To exercise any of your rights, please contact us:
ECO EFX Solutions GmbH
Data Protection Officer: Sven-Oliver Robertson
Hamburger Straße 180
22083 Hamburg
Germany
Email: cp@ecoefxsol.com
Phone: +49-40-298 234 60
We will respond to your request:
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Without undue delay
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Within one month of receipt of the request
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Extended to two months if necessary due to complexity (we will inform you of the extension)
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Free of charge (we may charge a reasonable fee for repetitive or excessive requests)
To protect your privacy, we may ask you to verify your identity before responding to requests concerning your personal data.
15. Data Sharing
We respect your privacy and only share your personal data with third parties in the following carefully controlled circumstances.
15.1 Data Processors (Art. 28 GDPR)
We share your data with carefully selected service providers who support us in operating this website and providing our services. These are data processors who process data only on our behalf and according to our instructions:
Categories of data processors:
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Hosting and Infrastructure: Wix.com (website hosting, CDN, security)
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Email Services: Email delivery and newsletter platforms
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Analytics: Web analytics and marketing analytics tools
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Communication: Email, chat, and customer support tools
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IT Services: Technical support, maintenance, and security providers
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Payment Processing: Payment service providers (if applicable)
Data Processing Agreements: We have concluded comprehensive data processing agreements (DPAs) with all data processors that ensure:
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Processing only according to documented instructions
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Confidentiality of processing personnel
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Appropriate technical and organizational measures
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Restrictions on engaging sub-processors
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Assistance with data subject rights requests
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Deletion or return of data after end of processing
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Audit and inspection rights
15.2 Legal Obligations and Authorities
In certain cases, we are legally obliged to share your data with external authorities:
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Law Enforcement: When required by law or court order
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Tax Authorities: For tax compliance and reporting obligations
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Regulatory Bodies: When required by applicable regulations
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Legal Claims: For establishment, exercise, or defense of legal claims
Legal basis: Art. 6 (1) lit. c GDPR (legal obligation) or Art. 6 (1) lit. f GDPR (legitimate interests)
15.3 Business Transfers
If we are involved in a merger, acquisition, or sale of assets, your personal data may be transferred as part of that transaction. We will provide notice before your data is transferred and becomes subject to a different privacy policy.
15.4 With Your Consent
We may share your data with third parties if you have given us explicit consent to do so. You can withdraw this consent at any time.
15.5 No Sale of Personal Data
Important: We do not sell your personal data to third parties under any circumstances. We do not share your data with third parties for their own marketing purposes without your explicit consent.
15.6 Social Media Sharing
If you choose to share content from our website on social media (using share buttons), data will be transmitted to the respective social media platform. This occurs only after you actively click the share button. See Section 8 for details on social media plugins.
16. Data Retention Period
We only store personal data for as long as necessary to fulfill the purposes for which it was collected or as required by law.
16.1 Retention Periods Overview
16.2 Statutory Retention Obligations
German and European law requires us to retain certain business and tax documents for specified periods:
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10 years: Books and records, inventories, opening balance sheets, annual financial statements, commercial letters, accounting documents (§ 147 AO, § 257 HGB)
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6 years: Other business letters, sent and received commercial letters (§ 257 (4) HGB)
After expiration of the retention period, data is routinely deleted unless further storage is necessary for contract fulfillment or legal claims.
16.3 Deletion Procedures
We have implemented systematic deletion procedures:
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Automatic Deletion: Data subject to fixed retention periods is automatically deleted when the period expires
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Regular Review: Manual review of data every 6 months to identify data that should be deleted
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Secure Deletion: All deleted data is securely erased and cannot be recovered
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Backup Deletion: Deletion also applies to backup copies after backup retention period
16.4 Exceptions to Deletion
Data may be retained beyond normal retention periods if:
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You have consented to longer retention
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We have a legal obligation to retain the data
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Retention is necessary for legal claims (statute of limitations: typically 3 years in Germany)
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Retention is necessary for compliance with a court order or regulatory requirement
17. International Data Transfers
In the context of our business operations and use of service providers, your personal data may be transferred to or made accessible in countries outside the European Economic Area (EEA).
17.1 Third Countries We Transfer Data To
We transfer data to the following third countries:
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United States: Through our hosting provider Wix and various service providers (Google, Meta, etc.)
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Israel: Through our hosting provider Wix.com Ltd.
17.2 Legal Safeguards for Data Transfers
We ensure that all international data transfers are protected by appropriate safeguards as required by Art. 44-49 GDPR:
Adequacy Decisions
Israel: The European Commission has determined that Israel ensures an adequate level of data protection (Commission Implementing Decision 2011/61/EU of 31 January 2011). Therefore, data transfers to Israel are permitted without additional safeguards.
EU Standard Contractual Clauses (SCCs)
For transfers to countries without an adequacy decision (such as the USA), we rely on EU Standard Contractual Clauses:
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Commission Implementing Decision (EU) 2021/914 of 4 June 2021
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Legally binding agreements between us and data recipients
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Ensures equivalent level of data protection as in the EU
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Includes data subject rights and remedies
EU-US Data Privacy Framework
Some of our US-based service providers are certified under the EU-US Data Privacy Framework:
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Google LLC
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Meta Platforms, Inc.
The EU-US Data Privacy Framework has been recognized by the European Commission as providing adequate protection for personal data transferred from the EU to participating US organizations (Commission Implementing Decision (EU) 2023/1795 of 10 July 2023).
17.3 Additional Safeguards
In addition to legal mechanisms, we implement additional technical and organizational measures:
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Encryption: All data transfers are encrypted in transit (TLS 1.2 or higher)
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Minimization: We transfer only the minimum necessary data
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Access Controls: Strict limitations on who can access transferred data
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Impact Assessments: Regular assessment of risks related to data transfers
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Monitoring: Ongoing monitoring of service providers' compliance
17.4 Specific Service Providers and Transfer Mechanisms
17.5 Your Rights Regarding International Transfers
You have the right to:
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Receive information about which countries your data is transferred to
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Obtain a copy of the safeguards in place (e.g., Standard Contractual Clauses)
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Object to specific transfers under certain circumstances
To obtain copies of the safeguards or for questions about international transfers, contact our Data Protection Officer at cp@ecoefxsol.com.
17.6 Monitoring and Compliance
We continuously monitor developments in international data transfer law and adjust our practices as necessary to ensure compliance with GDPR requirements. This includes:
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Regular review of adequacy decisions and their validity
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Monitoring of political and legal developments in third countries
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Assessment of whether additional measures are necessary
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Updates to data processing agreements as needed
18. Changes to the Privacy Policy
18.1 Right to Update
We reserve the right to update this privacy policy to reflect:
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Changes in our data processing practices
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New features or services on our website
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Changes in applicable laws and regulations
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Technological developments and security improvements
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Changes in our service providers
18.2 Notification of Changes
Minor Changes: For minor updates that do not materially affect how we process your data, we will update this page and note the revision date at the top.
Material Changes: For significant changes that materially affect your rights or how we process your data, we will:
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Display a prominent notice on our website for at least 30 days
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Send an email notification to registered users and newsletter subscribers
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Where required by law, obtain your consent for the new processing activities
18.3 Your Options
When we make material changes:
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You can review the updated privacy policy before it takes effect
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You can object to the changes by exercising your data protection rights
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You can withdraw consent for data processing that requires consent
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You can discontinue use of our services if you disagree with the changes
18.4 Version History
We maintain a version history of significant privacy policy updates. You can request previous versions by contacting our Data Protection Officer.
We recommend that you review this privacy policy periodically to stay informed about how we protect your personal data. The "Last Updated" date at the top of this page indicates when the privacy policy was last revised.
Contact for Data Protection Questions
If you have any questions about this privacy policy, our data processing practices, or wish to exercise your rights, please contact us:
General Inquiries:
ECO EFX Solutions GmbH
Hamburger Straße 180
22083 Hamburg
Germany
Email: info@ecoefxsol.com
Phone: +49-40-298 234 60
Fax: +49-40-298 234 61
Data Protection Officer:
Sven-Oliver Robertson
ECO EFX Solutions GmbH
Hamburger Straße 180
22083 Hamburg
Germany
Email: cp@ecoefxsol.com
Phone: +49-40-298 234 60
Response Time: We aim to respond to all privacy-related inquiries within one business day and will provide a substantive response within one month as required by GDPR.
