Privacy Policy
Personal data (usually referred to just as „data“ below) will only be processed by us to the extent necessary and for the purpose of providing a functional and user-friendly website, including its contents, and the services offered there.
Per Art. 4 No. 1 of Regulation (EU) 2016/679, i.e. the General Data Protection Regulation (hereinafter referred to as the „GDPR“), „processing“ refers to any operation or set of operations such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, or combination, restriction, erasure, or destruction performed on personal data, whether by automated means or not.
The following privacy policy is intended to inform you in particular about the type, scope, purpose, duration, and legal basis for the processing of such data either under our own control or in conjunction with others. We also inform you below about the third-party components we use to optimize our website and improve the user experience which may result in said third parties also processing data they collect and control.
Our privacy policy is structured as follows:
I. Information about us as controllers of your data
II. The rights of users and data subjects
III. Information about the data processing
I. INFORMATION ABOUT US AS CONTROLLERS OF YOUR DATA
The party responsible for this website (the „controller“) for purposes of data protection law is:
SmartFox Group FZCO
Dubai Silicon Oasis, DDP, Building A1
Dubai, United Arab Emirates
E-Mail: info(@)smartfox.group
II. THE RIGHTS OF USERS AND DATA SUBJECTS
With regard to the data processing to be described in more detail below, users and data subjects have the right
- to confirmation of whether data concerning them is being processed, information about the data being processed, further information about the nature of the data processing, and copies of the data (cf. also Art. 15 GDPR);
- to correct or complete incorrect or incomplete data (cf. also Art. 16 GDPR);
- to the immediate deletion of data concerning them (cf. also Art. 17 DSGVO), or, alternatively, if further processing is necessary as stipulated in Art. 17 Para. 3 GDPR, to restrict said processing per Art. 18 GDPR;
- to receive copies of the data concerning them and/or provided by them and to have the same transmitted to other providers/controllers (cf. also Art. 20 GDPR);
- to file complaints with the supervisory authority if they believe that data concerning them is being processed by the controller in breach of data protection provisions (see also Art. 77 GDPR).
In addition, the controller is obliged to inform all recipients to whom it discloses data of any such corrections, deletions, or restrictions placed on processing the same per Art. 16, 17 Para. 1, 18 GDPR. However, this obligation does not apply if such notification is impossible or involves a disproportionate effort. Nevertheless, users have a right to information about these recipients.
Likewise, under Art. 21 GDPR, users and data subjects have the right to object to the controller’s future processing of their data pursuant to Art. 6 Para. 1 lit. f) GDPR. In particular, an objection to data processing for the purpose of direct advertising is permissible.
III. INFORMATION ABOUT THE DATA PROCESSING
Your data processed when using our website will be deleted or blocked as soon as the purpose for its storage ceases to apply, provided the deletion of the same is not in breach of any statutory storage obligations or unless otherwise stipulated below.
Cookie Manager
To obtain consent for the use of technically unnecessary cookies on the website, the provider uses a cookie manager.
When the website is called up, a cookie with the settings information is stored on the end device of the user so that the request for consent does not have to be made on a subsequent visit.
The cookie is required to obtain legally compliant user consent.
You can prevent cookies from being installed by adjusting the settings on your internet browser.
Cookies
a) Session cookies
We use cookies on our website. Cookies are small text files or other storage technologies stored on your computer by your browser. These cookies process certain specific information about you, such as your browser, location data, or IP address.
This processing makes our website more user-friendly, efficient, and secure, allowing us, for example, to display our website in different languages or to offer a shopping cart function.
The legal basis for such processing is Art. 6 Para. 1 lit. b) GDPR, insofar as these cookies are used to collect data to initiate or process contractual relationships.
If the processing does not serve to initiate or process a contract, our legitimate interest lies in improving the functionality of our website. The legal basis is then Art. 6 Para. 1 lit. f) GDPR.
When you close your browser, these session cookies are deleted.
b) Third-party cookies
If necessary, our website may also use cookies from companies with whom we cooperate for the purpose of advertising, analyzing, or improving the features of our website.
Please refer to the following information for details, in particular for the legal basis and purpose of such third-party collection and processing of data collected through cookies.
c) Disabling cookies
You can refuse the use of cookies by changing the settings on your browser. Likewise, you can use the browser to delete cookies that have already been stored. However, the steps and measures required vary, depending on the browser you use. If you have any questions, please use the help function or consult the documentation for your browser or contact its maker for support. Browser settings cannot prevent so-called flash cookies from being set. Instead, you will need to change the setting of your Flash player. The steps and measures required for this also depend on the Flash player you are using. If you have any questions, please use the help function or consult the documentation for your Flash player or contact its maker for support.
If you prevent or restrict the installation of cookies, not all of the functions on our site may be fully usable.
Contact
If you contact us via email or the contact form, the data you provide will be used for the purpose of processing your request. We must have this data in order to process and answer your inquiry; otherwise we will not be able to answer it in full or at all.
The legal basis for this data processing is Art. 6 Para. 1 lit. b) GDPR.
Your data will be deleted once we have fully answered your inquiry and there is no further legal obligation to store your data, such as if an order or contract resulted therefrom.
Newsletter
If you register for our free newsletter, the data requested from you for this purpose, i.e. your email address and, optionally, your name and address, will be sent to us. We also store the IP address of your computer and the date and time of your registration. During the registration process, we will obtain your consent to receive this newsletter and the type of content it will offer, with reference made to this privacy policy. The data collected will be used exclusively to send the newsletter and will not be passed on to third parties.
The legal basis for this is Art. 6 Para. 1 lit. a) GDPR.
You may revoke your prior consent to receive this newsletter under Art. 7 Para. 3 GDPR with future effect. All you have to do is inform us that you are revoking your consent or click on the unsubscribe link contained in each newsletter.
User posts, comments, and ratings
We offer you the opportunity to post questions, answers, opinions, and ratings on our website, hereinafter referred to jointly as „posts.“ If you make use of this opportunity, we will process and publish your post, the date and time you submitted it, and any pseudonym you may have used.
The legal basis for this is Art. 6 Para. 1 lit. a) GDPR. You may revoke your prior consent under Art. 7 Para. 3 GDPR with future effect. All you have to do is inform us that you are revoking your consent.
In addition, we will also process your IP address and email address. The IP address is processed because we might have a legitimate interest in taking or supporting further action if your post infringes the rights of third parties and/or is otherwise unlawful.
In this case, the legal basis is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in any legal defense we may have to mount.
Server data
For technical reasons, the following data sent by your internet browser to us or to our server provider will be collected, especially to ensure a secure and stable website: These server log files record the type and version of your browser, operating system, the website from which you came (referrer URL), the webpages on our site visited, the date and time of your visit, as well as the IP address from which you visited our site.
The data thus collected will be temporarily stored, but not in association with any other of your data.
The basis for this storage is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in the improvement, stability, functionality, and security of our website.
The data will be deleted within no more than seven days, unless continued storage is required for evidentiary purposes. In which case, all or part of the data will be excluded from deletion until the investigation of the relevant incident is finally resolved.
Order processing
The data you submit when ordering goods and/or services from us will have to be processed in order to fulfill your order. Please note that orders cannot be processed without providing this data.
The legal basis for this processing is Art. 6 Para. 1 lit. b) GDPR.
After your order has been completed, your personal data will be deleted, but only after the retention periods required by tax and commercial law.
In order to process your order, we will share your data with the shipping company responsible for delivery to the extent required to deliver your order and/or with the payment service provider to the extent required to process your payment.
The legal basis for the transfer of this data is Art. 6 Para. 1 lit. b) GDPR.
To advertise our products and services as well as to communicate with interested parties or customers, we have a presence on the Facebook platform.
On this social media platform, we are jointly responsible with Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Irland.
The data protection officer of Facebook can be reached via this contact form:
https://www.facebook.com/help/contact/540977946302970
We have defined the joint responsibility in an agreement regarding the respective obligations within the meaning of the GDPR. This agreement, which sets out the reciprocal obligations, is available at the following link:
https://www.facebook.com/legal/terms/page_controller_addendum
The legal basis for the processing of the resulting and subsequently disclosed personal data is Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in the analysis, communication, sales, and promotion of our products and services.
The legal basis may also be your consent per Art. 6 para. 1 lit. a GDPR granted to the platform operator. Per Art. 7 para. 3 GDPR, you may revoke this consent with the platform operator at any time with future effect.
When accessing our online presence on the Facebook platform, Facebook Ireland Ltd. as the operator of the platform in the EU will process your data (e.g. personal information, IP address, etc.).
This data of the user is used for statistical information on the use of our company presence on Facebook. Facebook Ireland Ltd. uses this data for market research and advertising purposes as well as for the creation of user profiles. Based on these profiles, Facebook Ireland Ltd. can provide advertising both within and outside of Facebook based on your interests. If you are logged into Facebook at the time you access our site, Facebook Ireland Ltd. will also link this data to your user account.
If you contact us via Facebook, the personal data your provide at that time will be used to process the request. We will delete this data once we have completely responded to your query, unless there are legal obligations to retain the data, such as for subsequent fulfillment of contracts.
Facebook Ireland Ltd. might also set cookies when processing your data.
If you do not agree to this processing, you have the option of preventing the installation of cookies by making the appropriate settings in your browser. Cookies that have already been saved can be deleted at any time. The instructions to do this depend on the browser and system being used. For Flash cookies, the processing cannot be prevented by the settings in your browser, but instead by making the appropriate settings in your Flash player. If you prevent or restrict the installation of cookies, not all of the functions of Facebook may be fully usable.
Details on the processing activities, their suppression, and the deletion of the data processed by Facebook can be found in its privacy policy:
https://www.facebook.com/privacy/explanation
It cannot be excluded that the processing by Facebook Ireland Ltd. will also take place in the United States by Meta Platforms, Inc., 1601 Willow Road, Menlo Park, California 94025.
To advertise our products and services as well as to communicate with interested parties or customers, we have a presence on the Instagram platform.
On this social media platform, we are jointly responsible with Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Irland.
The data protection officer of Instagram can be reached via this contact form:
https://www.facebook.com/help/contact/540977946302970
We have defined the joint responsibility in an agreement regarding the respective obligations within the meaning of the GDPR. This agreement, which sets out the reciprocal obligations, is available at the following link:
https://www.facebook.com/legal/terms/page_controller_addendum
The legal basis for the processing of the resulting and subsequently disclosed personal data is Art. 6 para. 1 lit. f GDPR. Our legitimate interest lies in the analysis, communication, sales, and promotion of our products and services.
The legal basis may also be your consent per Art. 6 para. 1 lit. a GDPR granted to the platform operator. Per Art. 7 para. 3 GDPR, you may revoke this consent with the platform operator at any time with future effect.
When accessing our online presence on the Instagram platform, Facebook Ireland Ltd. as the operator of the platform in the EU will process your data (e.g. personal information, IP address, etc.).
This data of the user is used for statistical information on the use of our company presence on Instagram. Facebook Ireland Ltd. uses this data for market research and advertising purposes as well as for the creation of user profiles. Based on these profiles, Facebook Ireland Ltd. can provide advertising both within and outside of Instagram based on your interests. If you are logged into Instagram at the time you access our site, Facebook Ireland Ltd. will also link this data to your user account.
If you contact us via Instagram, the personal data your provide at that time will be used to process the request. We will delete this data once we have completely responded to your query, unless there are legal obligations to retain the data, such as for subsequent fulfillment of contracts.
Facebook Ireland Ltd. might also set cookies when processing your data.
If you do not agree to this processing, you have the option of preventing the installation of cookies by making the appropriate settings in your browser. Cookies that have already been saved can be deleted at any time. The instructions to do this depend on the browser and system being used. For Flash cookies, the processing cannot be prevented by the settings in your browser, but instead by making the appropriate settings in your Flash player. If you prevent or restrict the installation of cookies, not all of the functions of Instagram may be fully usable.
Details on the processing activities, their suppression, and the deletion of the data processed by Instagram can be found in its privacy policy:
https://help.instagram.com/519522125107875
It cannot be excluded that the processing by Facebook Ireland Ltd. will also take place in the United States by Meta Platforms, Inc., 1601 Willow Road, Menlo Park, California 94025.
We maintain an online presence on LinkedIn to present our company and our services and to communicate with customers/prospects. LinkedIn is a service of LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Irland, a subsidiary of LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, CA 94085, USA.
We would like to point out that this might cause user data to be processed outside the European Union, particularly in the United States. This may increase risks for users that, for example, may make subsequent access to the user data more difficult. We also do not have access to this user data. Access is only available to LinkedIn.
The LinkedIn privacy policy can be found here:
https://www.linkedin.com/legal/privacy-policy
YouTube
We maintain an online presence on YouTube to present our company and our services and to communicate with customers/prospects. YouTube is a service of Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, a subsidiary of Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043 USA.
We would like to point out that this might cause user data to be processed outside the European Union, particularly in the United States. This may increase risks for users that, for example, may make subsequent access to the user data more difficult. We also do not have access to this user data. Access is only available to YouTube.
The YouTube privacy policy can be found here:
https://policies.google.com/privacy
General introduction
Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland, a subsidiary of Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA.
Privacy Policy: https://www.facebook.com/policy.php
Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland, a subsidiary of Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA.
Privacy Policy: https://help.instagram.com/519522125107875
LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Irland, a subsidiary of LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, CA 94085 USA.
Privacy Policy: https://www.linkedin.com/legal/privacy-policy
YouTube
Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland, a subsidiary of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA
Privacy Policy: https://policies.google.com/privacy
Google Analytics
We use Google Analytics on our website. This is a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland (hereinafter: Google).
The Google Analytics service is used to analyze how our website is used. The legal basis is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in the analysis, optimization, and economic operation of our site.
Usage and user-related information, such as IP address, place, time, or frequency of your visits to our website will be transmitted to a Google server in the United States and stored there. However, we use Google Analytics with the so-called anonymization function, whereby Google truncates the IP address within the EU or the EEA before it is transmitted to the US.
The data collected in this way is in turn used by Google to provide us with an evaluation of visits to our website and what visitors do once there. This data can also be used to provide other services related to the use of our website and of the internet in general.
Google states that it will not connect your IP address to other data. In addition, Google provides further information with regard to its data protection practices at
https://www.google.com/intl/de/policies/privacy/partners,
including options you can exercise to prevent such use of your data.
In addition, Google offers an opt-out add-on at
https://tools.google.com/dlpage/gaoptout?hl=en
in addition with further information. This add-on can be installed on the most popular browsers and offers you further control over the data that Google collects when you visit our website. The add-on informs Google Analytics‘ JavaScript (ga.js) that no information about the website visit should be transmitted to Google Analytics. However, this does not prevent information from being transmitted to us or to other web analytics services we may use as detailed herein.
CloudFlare
To secure our website and to optimize loading times, we use the CloudFlare CDN (content delivery network). This is a service of Cloudflare Inc., 101 Townsend Street, San Francisco, California 94107, USA, hereinafter referred to as „CloudFlare“.
The legal basis for collecting and processing this information is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in the secure operation of our website and in its optimization.
If you access our website, your queries are forwarded to CloudFlare servers. Statistical access data about your visit to our website is collected and CloudFlare stores a cookie on your terminal device via your browser. Access data includes
– your IP address;
– the page(s) on our site that you access;
– type and version of internet browser you are using;
– your operating system;
– the website from which you came prior to visiting our website (referrer URL);
– your length of stay on our site; and
– the frequency with which our pages are accessed.
The data is used by CloudFlare for statistical evaluations of the accesses as well as for the security and optimization of the offer.
If you do not agree to this processing, you have the option of preventing the installation of cookies by making the appropriate settings in your browser. Further details can be found in the section about cookies above.
CloudFlare offers further information about its data collection and processing as well your rights and your options for protecting your privacy at this link:
https://www.cloudflare.com/privacypolicy/.
Google reCAPTCHA
Our website uses Google reCAPTCHA to check and prevent automated servers („bots“) from accessing and interacting with our website. This is a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland (hereinafter: Google).
This service allows Google to determine from which website your request has been sent and from which IP address the reCAPTCHA input box has been used. In addition to your IP address, Google may collect other information necessary to provide and guarantee this service.
The legal basis is Art. 6 Para. 1 lit. f) GDPR. Our legitimate interest lies in the security of our website and in the prevention of unwanted, automated access in the form of spam or similar.
Google offers detailed information at
https://policies.google.com/privacy
concerning the general handling of your user data.
YouTube
We use YouTube on our website. This is a video portal operated by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland, hereinafter referred to as „YouTube“.
We use YouTube in its advanced privacy mode to show you videos. In case you have granted your consent to this processing the legal basis is Article 6 para. 1 lit. a GDPR. The legal basis can also be Article 6 para. 1 lit. f GDPR. Our legitimate interest lies in improving the quality of our website. According to YouTube, the advanced privacy mode means that the data specified below will only be transmitted to the YouTube server if you actually start a video.
Without this mode, a connection to the YouTube server in the USA will be established as soon as you access any of our webpages on which a YouTube video is embedded.
This connection is required in order to be able to display the respective video on our website within your browser. YouTube will record and process at a minimum your IP address, the date and time the video was displayed, as well as the website you visited. In addition, a connection to the DoubleClick advertising network of Google is established.
If you are logged in to YouTube when you access our site, YouTube will assign the connection information to your YouTube account. To prevent this, you must either log out of YouTube before visiting our site or make the appropriate settings in your YouTube account.
For the purpose of functionality and analysis of usage behavior, YouTube permanently stores cookies on your device via your browser. If you do not agree to this processing, you have the option of preventing the installation of cookies by making the appropriate settings in your browser. Further details can be found in the section about cookies above.
Further information about the collection and use of data as well as your rights and protection options in Google’s privacy policy found at
https://policies.google.com/privacy
Use of Stripe as a payment method
If you decide to pay with the online payment service provider Stripe during your order process, your contact data is transmitted to Stripe as part of the order thus triggered. Stripe is an offer of Stripe Payments Europe, Limited (SPEL), 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Irland. Stripe thereby assumes the function of an online payment service provider and a trustee.
The personal data transmitted to Stripe is mostly first name, last name, address, telephone number, IP address, e-mail address, or other data, which is required for order processing,as well as data related to the order, such as the number of items, item number, invoice amount and tax percentage, billing information, etc.
This transmission is necessary to process your order with the payment method you have selected, in particular to confirm your identity, to administer your payment and the customer relationship. Your data is therefore transmitted to Stripe on the basis of Article 6 para. 1 lit. b GDPR.
However, please note: Stripe may transfer the personal data to service providers, to subcontractors or other affiliated companies, to the extent necessary to fulfill the contractual obligations arising from your order or to process the data in the order on your behalf.
Depending on the payment method selected via Stripe, e.g., invoice or direct debit, the personal data transmitted to Stripe will be transmitted to credit agencies by Stripe. This transmission is used to check your identity and creditworthiness in relation to the order you have placed. For information on which credit agencies are involved and which data is generally collected, processed, saved and forwarded by Stripe, please refer to Stripe data protection statement at https://stripe.com/de/privacy
Google Remarketing
We use the remarketing function on our website. This is a service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Irland (hereinafter: Google).
We use this feature to deliver interest-based, personalized advertising on third-party websites that also participate in Google’s advertising network.
In case you have granted your consent to this processing the legal basis is Article 6 para. 1 lit. a GDPR. The legal basis can also be Article 6 para. 1 lit. f GDPR. Our legitimate interest lies in the analysis, optimization, and economic operation of our site.
To allow this advertising service to function, Google stores a cookie with a sequence of numbers on your device via your browser when you visit our website. This cookie records both your visit and the use of our website in anonymous form. However, personal data will not be passed on. If you subsequently visit a third-party website that also uses the Google advertising network, advertising may appear that refers to our website or our offers there.
To permanently disable this feature, Google provides a browser plugin for most common browsers at
https://www.google.com/settings/ads/plugin?hl=de
Likewise, the use of cookies from certain providers, e.g. via
http://www.youronlinechoices.com/uk/your-ad-choices/
or
http://www.networkadvertising.org/choices/
can be deactivated by opt-out.
Cross-device marketing allows Google to track your usage patterns across multiple devices, so you may see interest-based, personalized advertising even when you switch devices. However, this requires that you have agreed to link your browsing history to your existing Google account.
Google offers more information about Google Remarketing at
