Privacy Policy

Information on the collection of your personal data
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(1) In the following we inform you about the collection of personal data when using our website. Personal data are all data that can be related to you personally, e.g. name, address, email addresses, user behavior.
(2) The person responsible in accordance with Art. 4 Para. 7 EU Data Protection Basic Regulation (GDPR) is
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‍Dominik Kugelmann, MD
22d OÜ
Ahtri tn 12,10151 Tallinn, Estland

‍Company Information
Register Number: 14743839
VAT ID: EE102167524
You can contact our Data Protection Officer at: privacy@22dconsulting.com 

(3) When you contact us by email or via a contact form, the data you provide (your email address, your name and telephone number if applicable) will be stored by us in order to answer your questions. We delete the data arising in this connection after storage is no longer necessary or restrict processing if there are legal storage obligations. The legal basis for the processing of data transmitted in the course of sending an email or contacting us via a contact form is Art. 6 Par. 1 lit. f GDPR. If the email contact is aimed at the conclusion of a contract, the additional legal basis for processing is Art. 6 para. 1 lit. b GDPR.
(4) If we use contracted service providers for individual functions of our offer or wish to use your data for advertising purposes, we will inform you in detail about the respective processes below. We will also state the specified criteria for the storage period.

‍Your rights

(1) You have the following rights against us with regard to the personal data concerning you:
- Right to information
- Right to correction or deletion
- Right to limit processing
- Right to object to the processing
- Right to data transferability.

(2) You also have the right to complain to a data protection supervisory authority about the processing of your personal data by us.

‍Collection of personal data when visiting our website

(1) If you use the website for informational purposes only, i.e. if you do not register or otherwise provide us with information, we only collect the personal data that your browser sends to our server. If you would like to view our website, we collect the following data, which is technically necessary for us to display our website and to ensure its stability and security (legal basis is Art. 6 para. 1 p. 1 lit. f GDPR)
- IP address
- Date and time of the request
- Time zone difference to UTC
- Content of the request (concrete page)
- Access Status/HTTP Status Code
- Amount of data transferred in each case
- Website from which the request comes
- Browser
- Operating system and its interface
- Language and version of the browser software.

(2) In addition to the data mentioned above, cookies are stored on your computer when you use our website. Cookies are small text files that are stored on your hard drive in accordance with the browser you are using and through which certain information is transmitted to the site that sets the cookie (in this case, by us). Cookies cannot execute programs or transfer viruses to your computer. They are used to make the services offered by the Internet more user-friendly and effective.
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(3) Use of cookies:
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(a) This website uses the following types of cookies, the scope and function of which are explained below:
(i) Transient cookies (in addition b)
(ii) Persistent cookies (see c).

(b) Transient cookies are automatically deleted when you close the browser. This includes in particular the session cookies. These store a so-called session ID, with which various requests from your browser can be assigned to the shared session. This enables your computer to be recognized when you return to our website. The session cookies are deleted when you log out or close the browser.

(c) Persistent cookies are automatically deleted after a specified period of time, which may vary depending on the cookie. You can delete the cookies in the security settings of your browser at any time.

(d) You can configure your browser settings according to your preferences and, for example, refuse to accept third-party cookies or all cookies. Please note that you may not be able to use all the features of this website.

(e) We use cookies to identify you for subsequent visits if you have an account with us. Otherwise you would have to log in again for each visit.

‍Other functions and offers on our website

(1) In addition to the purely informative use of our website, we offer various services which you can use if you are interested. For this purpose, you will generally have to provide additional personal data which we use to provide the respective service and to which the aforementioned data processing principles apply.
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(2) In some cases we use external service providers to process your data. These have been carefully selected and commissioned by us, are bound by our instructions and are checked regularly.

(3) Furthermore, we may pass on your personal data to third parties if we offer campaigns, competitions, contract conclusions or similar services together with partners. You will receive more detailed information on this when you provide your personal data or in the description of the offer below.

(4) Insofar as our service providers or partners have their headquarters in a state outside the European Economic Area (EEA), we will inform you of the consequences of this circumstance in the description of the offer.

‍Objection or revocation against the processing of your data

(1) If you have given your consent to process your data, you can revoke it at any time. Such revocation will affect the permissibility of processing your personal data after you have given it to us.

(2) Insofar as we base the processing of your personal data on the weighing of interests, you can object to the processing. This is the case if the processing is in particular not necessary for the fulfillment of a contract with you, which is described by us in the following description of the functions. In the event of such an objection, please explain the reasons why we should not process your personal data as we have done. In the event of your justified objection, we will examine the facts of the case and will either stop or adapt the data processing or show you our compelling reasons worthy of protection on the basis of which we will continue the processing.

(3) Of course, you can object to the processing of your personal data for the purposes of advertising and data analysis at any time. You can inform us about your objection to the processing of your personal data at the following contact details: privacy@22dconsulting.com 
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‍Dominik Kugelmann, MD
22d OÜ
Ahtri tn 12,10151 Tallinn, Estland

‍Company Information
Register Number: 14743839
VAT ID: EE102167524

‍Newsletters

(1) With your consent, you can subscribe to our newsletter, with which we inform you about our current interesting offers. The advertised goods and services are named in the declaration of consent.

(2) For the registration to our newsletter we use the so-called double-opt-in procedure. This means that after your registration, we will send you an email to the email address you provided, in which we ask you to confirm that you wish to receive the newsletter. If you do not confirm your registration within 24 hours, your information will be blocked and automatically deleted after one month. In addition, we store your IP address and the time of registration and confirmation. The purpose of this procedure is to be able to prove your registration and, if necessary, to clarify a possible misuse of your personal data.

(3) Your email address is the only mandatory information for sending the newsletter. The provision of further, separately marked data is voluntary and is used to address you personally. After your confirmation we will save your email address for the purpose of sending the newsletter. The legal basis is Art. 6 para. 1 p. 1 lit. a DSGVO.

(4) You can revoke your consent to receive the newsletter at any time and unsubscribe. You can revoke your consent by clicking on the link provided in each newsletter email, by sending an email to privacy@22dconsulting.com or by sending a message to the contact data provided in the policy.

‍Use of Google Analytics

(1) This website uses Google Analytics, a web analysis service of Google Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of this website is usually transferred to a Google server in the USA and stored there. However, in the event that IP anonymization is activated on this website, your IP address will be shortened by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area before this happens. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage.

(2) The IP address transmitted by your browser within the framework of Google Analytics is not merged with other data from Google.You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plug-in available under the following link: tools.google.com/dlpage/gaoptout. 

(3) This website uses Google Analytics with the extension "_anonymizeIp()". This allows IP addresses to be processed in a shortened form, thus excluding the possibility of personal references. If the data collected about you contains a personal reference, this is immediately excluded and the personal data is immediately deleted.

(4) We use Google Analytics to analyze the use of our website and to improve it regularly. We can use the statistics obtained to improve our offer and make it more interesting for you as a user. For the exceptional cases in which personal data is transferred to the USA, Google has subjected itself to the EU-US Privacy Shield, www.privacyshield.gov/EU-US-Framework. The legal basis for the use of Google Analytics is Art. 6 para. 1 p. 1 lit. f DSGVO.

(5) Third Party Information: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. terms of use:
- www.google.com/analytics/terms/de.html, Privacy Overview
- www.google.com/intl/de/analytics/learn/privacy.html, as well as the privacy policy:
- www.google.de/intl/de/policies/privacy.

(6) This website also uses Google Analytics for a cross-device analysis of visitor flows, which is performed via a user ID. You can deactivate the cross-device analysis of your usage in your customer account under "My data", "personal data".

‍Integration of YouTube videos

(1) When you visit the site, YouTube receives information that you have visited the appropriate subpage of our site. In addition, the data mentioned under § 3 of this declaration is transmitted. This occurs regardless of whether YouTube provides a user account through which you are logged in or whether no user account exists. If you are logged in at Google, your data will be assigned directly to your account. If you do not want the assignment with your profile on YouTube, you have to log out before activating the button. YouTube stores your data as user profiles and uses them for the purpose of advertising, market research and/or demand-oriented design of its website. Such an evaluation is carried out in particular (even for users who are not logged in) for the purpose of providing need-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right.

(2) For more information on the purpose and scope of data collection and processing by YouTube, please see the Privacy Policy. There you will also find further information about your rights and setting options to protect your privacy: www.google.de/intl/de/policies/privacy. Google also processes your personal data in the USA and has submitted to the EU-US Privacy Shield, www.privacyshield.gov/EU-US-Framework.

‍Integration of Google Maps

(1) On this website we use Google Maps. This allows us to display interactive maps directly on the website and enables you to use the map function conveniently.

(2) By visiting the website, Google receives the information that you have called up the corresponding subpage of our website. In addition, the data mentioned under § 3 of this declaration is transmitted. This happens regardless of whether Google provides a user account through which you are logged in or whether no user account exists. If you are logged in at Google, your data will be assigned directly to your account. If you do not want the assignment with your profile at Google, you have to log out before activating the button. Google stores your data as user profiles and uses them for the purposes of advertising, market research and/or demand-oriented design of its website. Such an evaluation is carried out in particular (even for users who are not logged in) to provide needs-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles, whereby you must contact Google to exercise this right.

(3) For more information on the purpose and scope of data collection and its processing by the plug-in provider, please refer to the provider's privacy policy. There you will also find further information about your rights and settings to protect your privacy: www.google.de/intl/de/policies/privacy. Google also processes your personal data in the USA and has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

‍Use of Google Adwords Conversion

(1) We use the offer of Google Adwords to draw attention to our attractive offers by means of advertising material (so-called Google Adwords) on external websites. We can determine in relation to the data of the advertising campaigns, how successful the individual advertising measures are. In this way, we pursue the interest to show you advertising that is of interest to you, to make our website more interesting for you and to achieve a fair calculation of advertising costs.

(2) These advertising media are delivered by Google via so-called "Ad Servers". For this purpose, we use ad server cookies, through which certain parameters can be measured to measure success, such as the display of ads or clicks by users. If you reach our website via a Google ad, Google Adwords will store a cookie on your PC. These cookies usually expire after 30 days and are not intended to identify you personally. The unique cookie ID, number of ad impressions per placement (frequency), last impression (relevant for post-view conversions) and opt-out information (marking that the user no longer wishes to be contacted) are usually stored as analysis values for this cookie.
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(3) These cookies enable Google to recognize your internet browser. If a user visits certain pages of an AdWords client's website and the cookie stored on their computer has not expired, Google and the client can recognize that the user clicked on the ad and was redirected to that page. A different cookie is assigned to each Adwords client. Cookies cannot be tracked through the websites of Adwords clients. We ourselves do not collect and process any personal data in the advertising measures mentioned above. We only receive statistical evaluations from Google. By means of these evaluations we can recognize which of the advertising measures used are particularly effective. We do not receive any further data from the use of the advertising material, in particular we cannot identify the users on the basis of this information.

(4) Due to the marketing tools used, your browser automatically establishes a direct connection with the Google server. We have no influence on the scope and further use of the data collected by Google through the use of this tool and therefore inform you according to our state of knowledge: Through the integration of AdWords Conversion, Google receives the information that you have called up the corresponding part of our website or clicked on an advertisement from us. If you are registered with a Google service, Google can assign the visit to your account. Even if you are not registered with Google or have not logged in, it is possible that the provider will find out and save your IP address.

(5) You can prevent participation in this tracking process in various ways: a) by setting your browser software accordingly, in particular by suppressing third-party cookies, which means that you will not receive third-party ads; b) by deactivating cookies for conversion tracking by setting your browser to block cookies from the domain "www.googleadservices.com", www.google. de/settings/ads, whereby this setting will be deleted if you delete your cookies; c) by disabling interest-based ads from providers that are part of the self-regulatory campaign "About Ads" via the link www.aboutads.info/choices, whereby this setting will be deleted if you delete your cookies; d) by permanently disabling them in your Firefox, Internet Explorer or Google Chrome browsers via the link www.google.com/settings/ads/plugin. We would like to point out that in this case you may not be able to use all functions of this offer to their full extent.

(6) The legal basis for the processing of your data is Art. 6 para. 1 sentence 1 lit. f DSGVO.

Further information on data protection at Google can be found here:www.google.com/intl/de/policies/privacy and services.google.com/sitestats/en.html. Alternatively, you can visit the website of the Network Advertising Initiative (NAI) at www.networkadvertising.org. Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.

‍Remarketing

‍Besides Adwords Conversion we use the application Google Remarketing. This is a procedure with which we would like to address you again. This application allows us to show you our advertisements after your visit to our website during your further internet use. This is done by means of cookies stored in your browser, which are used by Google to record and evaluate your usage behavior when you visit various websites. In this way Google can determine your previous visit to our website. A combination of the data collected within the scope of remarketing with your personal data, which may be stored by Google, does not take place by Google according to its own statements. According to Google, pseudonymisation is used in remarketing.